US D2C Brands Selling to France: EPR Checklist (2026)

A US brand shipping consumer goods direct to French customers needs French EPR registration from its first French order, through a representative established in France and appointed by written mandate under Article L. 541-10-9-1 of the French Environmental Code, in force since 10 July 2026. There is no revenue threshold. Below, the checklist from stream mapping to annual declarations.

Do you actually need French EPR?#

Yes, if three things are true: you sell consumer goods covered by a French EPR stream, French customers receive them from you (your warehouse, FBA in the EU, drop-shipping), and your company has no establishment in France. The obligation comes from Article L. 541-10 of the Code de l'environnement and has no volume threshold.

Try our scope-check tool for a structured first opinion.

What is the compliance checklist for US D2C brands?#

Seven steps: map your streams, appoint a representative, file the memberships, obtain and verify the identifiers, load them where they are checked, mark your packaging, then declare. Steps 1 to 5 happen once; 6 and 7 recur.

Step 1: identify your EPR streams#

Map your catalogue against the 19 French EPR streams. Most US D2C brands fall under at least two:

Household packaging (Citeo, Léko): shipping box, tape, void fill, branded mailer. Applies to almost everyone.
WEEE (Ecosystem, Ecologic): any product with electronic circuitry.
Batteries (Ecosystem, Batribox): any embedded or replacement battery.
Textile, household linen and footwear (Refashion): clothing, linen, shoes.
Furniture (Ecomaison, Valdelia, Valobat): structural home goods, mattresses.
Toys (Ecomaison): products designed for children under 14.
Sports and leisure (Ecologic): sports and fitness goods.
DIY and garden (Ecomaison, Ecologic, Valobat): hand tools, non-motorised garden equipment.

A Bluetooth speaker = packaging + WEEE + batteries. A clothing brand = packaging + textile. An exercise equipment brand = packaging + sports and leisure (and WEEE and batteries if motorised).

Step 2: appoint a France-established representative#

Foreign producers cannot register on their own: since 10 July 2026 the law requires the representative. One representative and one written mandate cover all your French streams. The mandate is signed electronically, and the work starts once it is signed and the first invoice and the deposit are received. See our authorized representative guide.

This is not the EU Authorised Representative used for product safety, nor a VAT fiscal representative: see EPR representative vs EU authorised representative.

Step 3: file the eco-organisation memberships#

Your representative files one membership per stream, with:

The catalogue of your French SKUs with categories, weights and material composition.
An estimate of annual French sales (units or revenue).
A company register extract less than three months old (a US Certificate of Good Standing or equivalent).
Your tax identifier at home, and an EU VAT number if you have one.

The full list is in the documents checklist.

Step 4: obtain and verify the identifiers#

It depends on the eco-organisation. Citeo issues the identifier about seven business days after the membership is validated. Léko issues it about five business days after its initial invoice is paid; that invoice must be paid within five business days, otherwise the membership is cancelled. Refashion issues it after membership, the signed contract and your first declaration and payment, then about ten business days. Ecosystem issues it after your first declaration has been filed and paid. We file your membership within two business days of receiving the signed mandate, the first invoice payment and the deposit.

Check each IDU on SYDEREP before any marketplace upload. See our IDU guide.

Step 5: put the identifiers where they are checked#

Your French terms of sale: the IDU must appear there, and it is good practice to show it on invoices and in the storefront footer.
Amazon, Cdiscount, ManoMano, Fnac Darty: each has an EPR or environmental compliance section asking for the IDU per stream.
Shopify: no platform upload, but the same terms-of-sale and packaging obligations.

Step 6: mark your packaging#

Triman logo on household packaging, required since 1 January 2022, at least 10 mm (6 mm in the compact format).
Info-tri showing each separable element and where it goes.
The official files come from Citeo or Léko once you are a member. See the Info-tri and Triman guide and, for shipping boxes, E-commerce parcels and stickers.

For packaging printed in the US, update the artwork at your next print run; Léko accepts a sticker to relabel stock already produced.

Step 7: declare#

Most streams are declared once a year. Exceptions: Ecomaison declares quarterly by default (annual on option below 15 t, 1,000 pieces and EUR 2 million of turnover in the stream), Valdelia quarterly, Ecominéro monthly, and Ecosystem electrical equipment quarterly unless contributions are paid by SEPA direct debit. Each declaration gives quantities per stream and material, and produces the eco-contribution. Your eco-contributions stay invoiced to you and paid by you directly to the eco-organisation.

Need a French EPR representative for your business?

We are EPR France specialists for foreign sellers. Fixed annual fee per stream, from €190/year excl. VAT, confirmed in a written quote within one business day. IDU in days, not weeks.

How our pricing works →

What does French EPR cost a US D2C brand?#

Two separate costs: the representative's fee and the eco-contributions set by each eco-organisation. Our fee is a fixed annual amount per stream, from €190/year excl. VAT for streams under the eco-organism flat-fee regime, confirmed in a written quote within one business day; a one-time setup per stream and a refundable security deposit are stated in the same quote (pricing).

Eco-organisation membership runs from €0 to €450 a year depending on the stream. Eco-contributions follow each published barème: household packaging weight rates run from €0.02 to €2.80/kg depending on material in the Citeo and Léko grids, and Citeo charges a €110 flat fee below 10,000 units. Every stream is detailed on the 2026 barèmes hub. We take no percentage and no margin on eco-contributions.

Which mistakes do US founders make most often?#

Assuming a French subsidiary is needed, mixing EPR with VAT, skipping batteries, and treating packaging marking as optional. Each one either costs money or leaves a listing exposed.

Assuming a French subsidiary is required. It is not: a France-established representative is the route the law provides. See Do I need a French entity for EPR?.

Confusing EPR with VAT. Separate regimes, separate contracts: EPR through your representative, VAT through a tax adviser.

Skipping batteries because they are "small". Coin cells, embedded lithium and USB-C rechargeable cells are all in scope.

Treating Info-tri and Triman as optional. They are required, and a missing marking is fined per non-compliant reference. The 2027 Citeo and Léko scales carry no bonus or malus linked to Info-tri; the only related premium (4%) rewards off-pack media awareness campaigns.

FAQ#

What does a US D2C brand need to sell legally in France under EPR?#

Four things: a written mandate with a representative established in France (compulsory since 10 July 2026 under Article L. 541-10-9-1 of the French Environmental Code), one membership and one identifier (IDU) per EPR stream, the Triman logo and Info-tri on household packaging, and declarations to each eco-organisation, usually once a year. There is no revenue or volume exemption.

I am incorporated in Delaware and ship to France from a Texas warehouse. Am I in scope?#

Yes. Article L. 541-10 of the Code de l'environnement applies on the basis of the first placing on the French market, not where the producer is based. Because all your operations are in the US, you have no establishment in France, and that is exactly the case in which a France-established representative is compulsory.

I have French sales below $50,000 a year. Is there an exemption?#

No. The obligation to register exists from the first unit shipped. What scales down is the eco-contribution: several eco-organisations run a flat fee for small producers, for example Citeo at €110 a year under 10,000 household packaging units. Marketplaces check your identifier whatever your size.

Do I need French VAT registration in addition to EPR?#

Possibly, but it is a separate regime handled by a tax adviser. You may owe French VAT through IOSS, OSS or a non-resident French VAT registration depending on your model. A VAT fiscal representative does not cover EPR, and an EPR representative does not cover VAT.

Does a Shopify brand need to upload its IDU anywhere?#

Not to a platform, since there is no marketplace in between. The identifier must appear in your French terms of sale, and it is good practice to show it in the storefront footer and on invoices. Marketplace sellers upload it to each platform's EPR compliance section.

Start your US-to-France EPR file#

We are a France-established representative for producers without a French establishment, working in English and French. Request a written quote with your catalogue and shipping volume; it comes back within one business day.

Sources & references#

All legal and regulatory claims in this article trace back to the following primary sources (Légifrance, EUR-Lex, ADEME and equivalents). Verified 24 May 2026; Article L. 541-10-9-1 added after its entry into force on 10 July 2026.

Ready to start your French EPR registration?

Three-minute application form. Written quote within one business day. IDU in days, not weeks.

How EPR registration works, step by step →

US Brands Selling D2C to France: The Complete EPR Compliance Checklist