EPR authorized representative.
What it is, who needs one, and how to appoint one in France.
If you sell into France without a French establishment, an EPR authorized representative, in French, a mandataire REP, is the legal entity that makes your French Extended Producer Responsibility compliance possible. France does not let a non-French company register directly. This page is the complete, accurate reference: the definition, who is in scope, what the representative does and cannot do, the statutory subrogation in force since 10 July 2026, the PPWR Article 45 change on 12 August 2026, the streams and eco-organisms, how to choose, and what it costs. Every legal claim is sourced.
Préférez le français ? Lisez notre page mandataire REP en France.
What an EPR authorized representative is
Extended Producer Responsibility (EPR) makes whoever first places a product on a national market responsible for financing its end-of-life management. When that producer is established abroad, EU Member States may, under Article 8a(5) of Directive 2008/98/EC, let it comply through a locally established authorized representative. France took up that option and extended it to producers established entirely outside the EU.
So the EPR authorized representative is the France-established entity that holds your producer file: it joins the eco-organisms in your name, obtains your IDU, files your declarations and is the administration's French point of contact. It represents you: it does not become you, and producer status is not transferable. What it does carry, since 10 July 2026, are the EPR obligations covered by the mandate it accepts, by operation of law (see the statutory subrogation below).
Who needs one
You need a French EPR authorized representative if your company is not established in France and you place products in scope of a French EPR stream on the French market, whether through Amazon France, Cdiscount, ManoMano, TikTok Shop FR, your own Shopify store, or B2B wholesale. The first placing on the market triggers the obligation regardless of where you are incorporated: a US LLC, a UK Ltd, a Chinese or Swiss company selling to a French customer is a French EPR producer.
Two converging legal anchors make this concrete in 2026:
- French law. Article L. 541-10 II of the Code de l'environnement and the AGEC law (2020-105) require non-established producers to designate a representative; the SYDEREP register will not accept a non-French entity as the registered party.
- EU law, PPWR Article 45. Regulation (EU) 2025/40 (PPWR) becomes applicable on 12 August 2026 and requires producers of packaging not established in a Member State to appoint an authorized representative in each Member State where they place packaging on the market. There is no single EU window, one representative per country. See our PPWR 2026 cornerstone and Article 45 guide.
- EU Batteries Regulation 2023/1542 (in force since 18 August 2025) carries an equivalent authorized-representative logic for batteries, on top of the French Batribox/Ecosystem registration.
Selling from a specific country? We map the exact obligations by origin in our by-country hub (US, UK, China).
What it does, and what it cannot do
The standard mandate covers six operational functions:
Opens and signs membership dossiers with each eco-organism in scope (Citeo, Refashion, Ecosystem, Ecomaison, Valobat, Citeo Pro / Léko Pro / Twiice for professional packaging). You are named as the registered producer; the representative is the operational contact.
Registers you in the ADEME national producer registry, which issues your unique producer identifier (IDU) per stream and publishes it on the public SYDEREP teleservice that marketplaces query.
Files your declarations of volumes placed on the French market each year, using the data you provide. It formats and submits, it does not invent figures.
The eco-contribution is set by each eco-organism on its published barème and stays separate from the service fee. A clean representative never takes a cut: we take no percentage on it, we check every amount against your declared volumes, and we work on optimisation (eco-modulation) with you.
Receives all correspondence from eco-organisms, ADEME, DGCCRF and marketplaces as your French point of contact; translates, replies, and flags anything that needs your decision.
Monitors PPWR delegated acts, new streams (professional packaging, launch postponed from 1 July 2026, start now set for 1 January 2027), barème changes and marketplace enforcement trends so your file stays current.
Equally important is the boundary, what an EPR authorized representative does not do, where misunderstanding causes the most trouble:
- Become the producer, you keep that status and you answer for the accuracy of the data you provide and for any period before the mandate took effect.
- Import your goods, it is not an importer of record and does not clear customs.
- Warehouse or fulfil, EPR representation is administrative, not logistics.
- File your French VAT, EPR and VAT are separate regimes with separate registrations.
- Redesign your products, PPWR upstream duties (recycled content, design-for-recycling, labelling) stay on the producer.
The statutory subrogation, the detail competitors miss
On 10 November 2023, the Conseil d'État (case n° 449213, the EcoDDS ruling) annulled Article R. 541-174 of the Code de l'environnement insofar as it provided for subrogation of the representative into the producer's obligations. The court's reasoning: the Waste Framework Directive provides for representation, not substitution; modifying civil obligations between operators belongs to the law, not to a decree. The annulment took immediate effect.
That was the state of the law until 8 July 2026, when the legislator restored subrogation at the level the Conseil d'État said it belonged to: statute. Law n° 2026-602, creating Article L. 541-10-9-1 of the Code de l'environnement, applies from 10 July 2026 and provides that a producer not established in France must appoint a France-established representative by written mandate, and that this representative is subrogated into the EPR obligations whose mandate it accepts.
Four practical consequences follow, and they should shape the mandate you sign:
- Subrogation is now statutory, not contractual. It does not depend on a clause, and it cannot be waived by one. It also does not depend on the PPWR: it applies to every French EPR stream, in national law.
- It is prospective and bounded by the mandate. Declarations, contributions and breaches predating the mandate remain the producer's, and so does the accuracy of the data you provide.
- Producer status is not transferred. You remain the producer; what moves is the burden of the obligations covered by the mandate, for its scope and its duration.
- The exposure has to be secured. A representative that carries your obligations will ask for a security, which is why our quote states a refundable deposit calibrated on your estimated annual eco-contributions.
A 2026 mandate that still promises “no subrogation, the producer stays the obligated party” to a producer without a French establishment is the one that is now outdated. Our template is built for the statutory regime, see the full legal analysis in our EcoDDS deep dive and the authorized representative legal guide.
The French streams and their eco-organisms
A French EPR authorized representative can cover any combination of the 19 French REP streams. A typical non-EU consumer brand falls into two to four. One representative, one mandate, every stream. The most common are shown below:
| Stream | Eco-organisms | Typically in scope |
|---|---|---|
| Household packaging | Citeo, Léko, Adelphe | Anyone shipping packaged goods to French consumers |
| Professional packaging (EPRO) | Citeo Pro, Léko Pro, Twiice | B2B packaging that reaches French businesses, eco-contributions start 1 January 2027 |
| WEEE (electricals) | Ecosystem, Ecologic | Any product with a plug, battery, cable or chip |
| Batteries | Batribox, Ecosystem (ex-Corepile) | Portable batteries and battery-powered devices |
| Textile, linen, footwear | Refashion | Apparel, household linen and footwear brands |
| Furniture (DEA) | Ecomaison, Valdelia | Furniture and home decor |
| Toys | Ecomaison | Toy importers and brands |
| Sports, DIY, garden | Ecomaison | Sporting goods, DIY and gardening products |
| Graphic paper | Citeo, Léko | Catalogues, manuals, printed paper |
| Construction (PMCB) | Valobat, Ecominéro | Construction products and materials |
The newest of these, professional (B2B) packaging, was due to start charging eco-contributions on 1 July 2026, but the launch was postponed sine die on 26 June 2026, then set for 1 January 2027 by ministerial announcement (late July 2026). Its eco-organisms (Citeo Pro, Léko Pro, Twiice) were accredited in early June 2026 with their barèmes published. If your packaging reaches French businesses, read our professional packaging barème guide. Browse every stream on our services hub and every eco-organism on the eco-organisms hub.
How to choose, and the red flags
Five criteria filter the market cleanly. Use them on every shortlist call, including ours:
- France establishment. Article L. 541-10-9-1 requires the representative to be established in France. Pan-EU platforms run the France leg through an undisclosed sub-provider.
- A public entry price and a fixed written quote. Opaque, quote-only pricing with no public reference point tends to cost more and hides per-SKU or volume surprises. Ours is at /pricing.
- A mandate built for the statutory subrogation. Ask to see the template before you sign: since 10 July 2026 it should state the scope covered, the duration, the prospective effect and the security, not deny that anything transfers.
- All streams in one engagement. A catalogue spanning packaging + WEEE + batteries wants one representative, not three.
- Marketplace recovery SLA. For an Amazon France suspension, a documented playbook recovering in days, not weeks.
Red flags to walk away from, whatever the provider: a mandate that still tells a producer without a French establishment that nothing transfers; uncapped tonnage-based fees; a fee indexed on your eco-contributions; refusal to identify who drafted the mandate; and a template left untouched since law n° 2026-602. For a full market map by provider archetype, see compare French EPR providers.
What it costs
Three layers, per stream per year. Knowing all three is how you avoid surprises:
- The authorized-representative fee. Ours is a fixed annual fee per stream, from €190/year excl. VAT, confirmed in a written quote within one business day. It depends on the stream's declaration regime (flat-fee, simplified or itemised) and on your number of product references, not on your sales volume; a one-time setup per stream and a refundable security deposit are stated in the quote. Opaque providers quote €3,500 to €10,000 or more per stream per year for the same scope.
- Eco-organism membership. A small annual floor set by Citeo, Refashion, Ecosystem, Ecomaison or Valobat, roughly €0 to €450/year depending on the stream, and we take no percentage and no markup on it either.
- The eco-contribution. Variable, on your declared tonnage and materials, after eco-modulation. It is set by the eco-organism on its published barème and stays separate from our fee: we take no percentage and no markup on it.
A non-EU consumer brand with packaging + WEEE + batteries (three streams) receives one written quote covering all three within one business day; opaque providers commonly land between €10,000 and €30,000 per year for the same scope. See our pricing for the entry price and the two-cost structure, or read the full breakdown in our EPR cost guide.
How to appoint one, process and timeline
- Scope your streams. One product often triggers several (a Bluetooth speaker = packaging + WEEE + batteries). Use our scope check or application wizard.
- Get a written quote within one business day, fixed scope, fixed price.
- Sign the written mandate electronically, the same week. No notary, scope and duration stated.
- Eco-organism membership within 48 to 72 hours of signature.
- IDU issued by ADEME via the eco-organism within 2 to 3 weeks per stream, published on SYDEREP.
- Load the IDU on each marketplace, suspended listings re-activate within 48 to 72 hours.
- Declare annually the prior year's tonnage; the eco-organism then sets the eco-contribution due on those volumes.
Already with another representative? Switching does not lose your IDU, it belongs to you and is portable. See the mechanics in our switching guide.
Frequently asked questions
What is an EPR authorized representative?
An EPR authorized representative (in France, mandataire REP) is a legal entity established in the country of sale that a producer not established there appoints by written mandate to perform Extended Producer Responsibility registration, declaration and administrative tasks in the producer's name and on its behalf. In France, since 10 July 2026, Article L. 541-10-9-1 of the Code de l'environnement makes that appointment compulsory and subrogates the representative into the EPR obligations whose mandate it accepts. The mandate itself is a written mandate under the Code civil (Articles 1984 et seq.); producer status stays with you, and the subrogation runs only for the scope and duration of the mandate.
Who needs an EPR authorized representative for France?
Any company not established in France that places products in scope of a French EPR stream on the French market, manufacturers, brand owners, importers, wholesalers and e-commerce sellers from the US, UK, China, Switzerland, Turkey and elsewhere. France does not allow a non-French entity to be the registered party on the SYDEREP register, so a France-established representative must register on your behalf. For packaging, PPWR Article 45 makes this an EU-wide legal duty from 12 August 2026; the EU Batteries Regulation 2023/1542 (in force 17 August 2023, its EPR chapters applying from 18 August 2025) carries an equivalent representative logic for batteries.
Is the authorized representative the same as a fiscal (VAT) representative?
No. They are distinct mandates governed by different laws. The EPR authorized representative handles EPR only (eco-organism membership, IDU, declarations, eco-contribution). A fiscal representative (Article 289 A of the Code général des impôts) handles VAT and engages joint VAT liability. A customs representative (Article 18 of the Union Customs Code) handles customs clearance. A product-safety authorized representative (Regulation (EU) 2019/1020) handles CE marking and market surveillance. You may need several of these, but they are separate engagements.
Does the authorized representative take legal responsibility for my compliance?
In France, yes, within the scope of the mandate. The Conseil d'État's EcoDDS ruling of 10 November 2023 (case 449213) had annulled Article R. 541-174 insofar as it provided subrogation, holding that such a transfer belongs to statute rather than decree. Parliament then legislated: since 10 July 2026, Article L. 541-10-9-1 of the Code de l'environnement (law n° 2026-602 of 8 July 2026) subrogates the representative into the EPR obligations whose mandate it accepts. Producer status stays with you, the subrogation is prospective and bounded by the mandate, and you still answer for the accuracy of the data you provide and for any period before the mandate took effect. A company established in France is outside that regime: it declares in its own name, and its mandate remains an ordinary civil mandate without subrogation. In 2026, the contract to be wary of is the one that still tells a producer without a French establishment that nothing transfers.
How much does an EPR authorized representative cost?
Ours is a fixed annual fee per stream, from €190/year excl. VAT, confirmed in a written quote within one business day. The fee depends on the stream's declaration regime (flat-fee, simplified or itemised) and on your number of product references, not on your sales volume; a one-time setup per stream and a refundable security deposit are stated in the quote. The fee is fixed for the twelve months it covers and can be revised at each annual renewal, any change being stated in writing before it takes effect. On top sit the eco-organism membership fee (roughly €0 to €450/year depending on the stream) and the variable eco-contribution (set by the eco-organism on its published barème). We take no percentage and no markup on either. Opaque providers quote on tonnage or turnover, typically €3,500 to €10,000 or more per stream per year for the same scope.
How long does it take to appoint one and get an IDU?
Fast. Written quote within one business day, written mandate signed electronically the same week (no notary), and the IDU issued by ADEME via the eco-organism within 2 to 3 weeks per stream. Suspended marketplace listings (Amazon France, Cdiscount, ManoMano) typically re-activate within 48 to 72 hours of SYDEREP publication. The IDU belongs to you, the producer, and is portable, if you switch representative later, your IDU stays with you.
Can a non-French company be my French EPR authorized representative?
No. The representative must be a legal entity established in France that can sign mandates with French eco-organisms, declare on SYDEREP and hold the operational producer relationship. Pan-EU compliance platforms that are not French operate the France leg through a France-established sub-provider whose identity is often undisclosed. For French outcomes, fast IDU, marketplace recovery, a mandate drafted for the statutory subrogation regime, a France-established specialist is the cleaner route.
Sources & references
All legal claims trace back to the primary sources below. Verified 1 August 2026.
- Article L. 541-10 du Code de l'environnement, Légifrance
- Article L. 541-9-5 (sanctions REP), Légifrance
- Conseil d'État, 10 novembre 2023, n° 449213 (EcoDDS), Actu-Environnement
- Regulation (EU) 2025/40 (PPWR), Article 45, EUR-Lex
- Regulation (EU) 2023/1542 (Batteries), EUR-Lex
- Directive 2008/98/EC, Article 8a(5), EUR-Lex
- Code civil, Articles 1984 à 1990 (mandat civil), Légifrance
- SYDEREP, public producer register (ADEME)
A France-established EPR authorized representative, on a public entry price.
Tell us your streams and destination markets. We return a written quote within one business day, a mandate built for the statutory subrogation to sign the same week, and your IDU in 2 to 3 weeks. Scope, duration and security stated in writing, no markup on the eco-contribution.