EPR authorized representative in France.
Who needs an EPR authorised representative, what it covers, and how to appoint one.

What is an EPR authorized representative?

It is the France-established company that holds your French producer file when you have no establishment in France: it files your eco-organisation memberships, obtains your identifier (IDU), files your declarations and handles the exchanges with the eco-organisation.

Extended Producer Responsibility (EPR) makes whoever first places a product on the French market responsible for financing its end-of-life management. When that producer is established abroad, French law requires a representative: A written mandate under Article L. 541-10-9-1 of the French Environmental Code, created by Law No. 2026-602 of 8 July 2026. Since 10 July 2026, any producer not established in France and subject to EPR must appoint a representative established in France, for every stream. For packaging, Article 45 of Regulation (EU) 2025/40 (PPWR) adds the same requirement at EU level.

Who needs one?

Any company not established in France that places products in scope of a French EPR stream on the French market, whether through Amazon France, Cdiscount, ManoMano, TikTok Shop FR, its 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, Swiss or German company selling to a French customer is a French EPR producer.

Three legal anchors apply in 2026:

• French law, every stream. Since 10 July 2026, Article L. 541-10-9-1 of the French Environmental Code (Law No. 2026-602 of 8 July 2026) requires any producer not established in France and subject to EPR to appoint a representative established in France.
• EU law, packaging. Since 12 August 2026, Article 45 of Regulation (EU) 2025/40 requires a producer that makes packaging available in a member state where it is not established, including from another EU country, to appoint an authorised representative for extended producer responsibility in that member state. See our PPWR 2026 hub and Article 45 guide.
• EU Batteries Regulation 2023/1542 (in force since 17 August 2023, its EPR chapters applying since 18 August 2025) carries an equivalent authorized-representative logic for batteries, on top of the French registration with Ecosystem.

One exception: If a marketplace takes on the EPR obligation for your products under Article L. 541-10-9 of the French Environmental Code (as Amazon offers to do in France), the obligation is deemed met for those products only, and only while you are not registered yourself. Anything sold outside that scheme, or once you register, remains your obligation. Selling from a specific country? We map the obligations by origin in our by-country hub (US, UK, China).

What does it do, and what does it not do?

It runs your French EPR formalities: memberships, identifier, declarations, eco-organisation exchanges and audits, archiving. It does not import, store, file your VAT or redesign your products.

Equally important is the boundary, what an EPR authorized representative does not do:

• Become the producer: you remain the producer, and you answer for the accuracy of the data you provide.
• 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 or your markings: upstream duties (recycled content, design for recycling, labelling) stay with the producer and its designer.

Nor is it any of three other representatives foreign sellers often already have: the fiscal representative for VAT, the customs representative, or the product-safety representative for CE marking. Those are separate mandates with separate providers.

What does the mandate cover, and what stays with you?

You remain the producer. Under the written mandate required by Article L. 541-10-9-1 of the French Environmental Code, we take charge of and answer for your registration, your identifier, your declarations, the exchanges with the eco-organisation and audits, and the archiving of your files. Your eco-contributions stay invoiced to you and paid by you directly to the eco-organisation.

The legal basis is the one set out above: A written mandate under Article L. 541-10-9-1 of the French Environmental Code, created by Law No. 2026-602 of 8 July 2026. Since 10 July 2026, any producer not established in France and subject to EPR must appoint a representative established in France, for every stream. For packaging, Article 45 of Regulation (EU) 2025/40 (PPWR) adds the same requirement at EU level. The Conseil d'État's EcoDDS ruling of 10 November 2023 now only concerns producers established in France, who declare in their own name and appoint no representative.

Two consequences of Article L. 541-10-9-1 are often missed. First, it reaches online marketplaces: a platform covered by Article L. 541-10-9 that is not established in France must appoint its own France-established representative, and the obligation is treated as met only for the products whose EPR compliance a France-established platform actually ensures. Second, it catches producers who hold a membership with no representative on file: the membership and the IDU stand, but a representative must now be appointed and the mandate sent to each eco-organisation so the membership and the SYDEREP record are updated. The IDU does not have to be lost in the process. Full analysis in our breakdown of Law No. 2026-602.

Which streams and eco-organisations are involved?

Any combination of the 19 French EPR streams; a typical non-EU consumer brand falls into two to four. One representative, one mandate, every stream. We currently register clients with Citeo, Léko and Léko Pro, Ecosystem (electrical equipment, lamps, batteries), Ecologic (electrical equipment, sports and leisure articles, thermal DIY and garden tools), Twiice, Refashion, Ecomaison and Valobat. For the other approved eco-organisations, we confirm availability with your quote. The most common streams and their approved eco-organisations:

For professional packaging: register now; contributions and identifiers start on 1 January 2027. Professional packaging is any packaging that is not household packaging. Under the arrêté of 2 December 2025, pallets and palletisation items are always professional; transport packaging is professional, except for products sold online to households; grouped packaging is professional, except multipacks split at the point of sale; sales packaging is professional only when the product is designed exclusively for professionals and nobody sells it to households. Browse every stream on our services hub and every eco-organisation on the eco-organisations hub.

What documents do you need to appoint one?

Thirteen items, all about your company, your products and your volumes. Never an identity document.

1. Exact company name, legal form and registered address
2. Registration number and tax identifier in your country, EU VAT number if you have one
3. Company register extract less than three months old
4. Name and position of the signatory, who must appear on the extract, otherwise a written delegation
5. Full product scope, by reference or by product family
6. Volumes per stream in the stream’s unit, and volumes of the three previous years if you already sell
7. Date of your first sale in France
8. Sales channels and customers, households or professionals
9. Who imports and who owns the goods when they enter France
10. Identifiers and memberships you already hold, with access or certificate
11. Billing details and operational contact, with phone number
12. Written acceptance of the deposit amount
13. Bank details on a document issued by your bank

Never an identity document. These are the same documents as a membership without a representative.

How do you choose a representative?

Check that it is established in France, that it puts a fixed price in writing before you sign, and that its mandate states exactly what it covers. Five criteria filter the market:

• France establishment. Article L. 541-10-9-1 requires the representative to be established in France. Pan-EU platforms run the France leg through a sub-provider.
• A public entry price and a fixed written quote. Quote-only pricing with no public reference point tends to hide per-SKU or volume surprises. Ours is at /pricing.
• A mandate written for Article L. 541-10-9-1. Ask to see the template before you sign: it should state the streams and products covered, the start date and the duration.
• All streams in one engagement. A catalogue spanning packaging, electrical equipment and batteries wants one representative, not three.
• A documented marketplace process. Who enters your identifiers in Seller Central and the other platforms, and how.

Red flags to walk away from: a mandate that is silent on its scope and start date; uncapped tonnage-based fees; a fee indexed on your eco-contributions; refusal to say who drafted the mandate; and a template still written on a pre-July 2026 legal basis. For a market map by provider archetype, see compare French EPR providers.

What does it cost?

Three layers, per stream per year:

1. The authorized-representative fee. Ours starts from €190/year excl. VAT per stream, confirmed in a written quote within one business day. Your annual fee is a fixed amount per stream and per calendar year, independent of your eco-contributions. It depends on the declaration regime and frequency, the number of references and, above EUR 1,000 of eco-contribution per stream, its size. It is fixed in writing for the year and can only change for the following year, notified in writing by 15 September, or during the year if your scope changes, for example a new stream or a change of declaration regime. Quote-only providers commonly charge €3,500 to €10,000 or more per stream per year for the same scope.
2. Eco-organisation membership. A small annual fee set by the eco-organisation, roughly €0 to €450/year depending on the stream; we take no percentage and no markup on it.
3. The eco-contribution. Variable, on your declared tonnage and materials, after eco-modulation, set by the eco-organisation on its published barème. Your eco-contributions stay invoiced to you and paid by you directly to the eco-organisation; we take no percentage and no markup on them.

The quote also states a one-time setup per stream and the deposit: A refundable security deposit equal to one year of your estimated eco-contributions, at least the eco-organisation's minimum billing, paid once by separate transfer to a dedicated account, never invoiced. It covers sums left unpaid under the mandate and is returned within sixty days of the end of the mandate, once the last contributions are paid. See our pricing for the entry price, or the full breakdown in our EPR cost guide.

How do you appoint one, and how long does it take?

Scope your streams, accept a written quote, sign the mandate, then pay the first invoice and the deposit; we file your membership within two business days and the identifier follows on each eco-organisation's timeline.

1. Scope your streams. One product often triggers several (a Bluetooth speaker = packaging + electrical equipment + batteries). Use our scope check or the onboarding form.
2. Get a written quote within one business day, fixed scope, fixed annual fee.
3. Sign the written mandate electronically, with the streams and start date stated.
4. Pay the first invoice and the deposit. Service starts once the mandate is signed and the first invoice and deposit are received.
5. Membership filed within two business days, then the identifier: about seven business days after the membership is validated at Citeo, about five business days after the initial invoice is paid at Léko (payable within five business days, otherwise the membership is cancelled), after the first declaration has been filed and paid at Ecosystem.
6. Enter the identifier on each marketplace and in your terms of sale where required.
7. Declare on each eco-organisation's cycle; most streams are declared once a year.

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

Sources & references

All legal claims trace back to the primary sources below. Penalty amounts checked on Légifrance on 6 October 2026.

• Loi n° 2026-602 du 8 juillet 2026, creating Article L. 541-10-9-1 of the Code de l'environnement (JO of 9 July 2026), in force 10 July 2026
• Article L. 541-10 du Code de l'environnement, Légifrance
• Article L. 541-10-9 (marketplaces), Légifrance
• Article L. 541-9-5 (sanctions REP), Légifrance
• Regulation (EU) 2025/40 (PPWR), Article 45, EUR-Lex
• Regulation (EU) 2023/1542 (Batteries), EUR-Lex
• SYDEREP, public producer register (ADEME)