EPR compliance.
The complete 2026 guide for producers.

What is EPR compliance?

Extended Producer Responsibility (EPR) is the policy approach that shifts the financial and operational burden of end-of-life product management, collection, sorting, transport, recycling, disposal, from municipalities and taxpayers to the producers who put the products on the market in the first place. The principle has been embedded in EU waste law since the late 1990s and has steadily expanded in scope. In 2026 it covers packaging, electrical and electronic equipment (WEEE), batteries, textiles, furniture, toys, construction materials, sports goods, vehicles, graphic paper, professional packaging and a growing list of other product streams.

EPR compliance is the producer-side execution of this obligation. It is operationally similar to indirect tax compliance (VAT, sales tax) in that it requires registration, periodic declarations, financial contributions and audit-readiness, but the regulatory framework is environmental rather than fiscal, the obligations are stream-specific rather than transaction-specific, and the enforcement bodies are environmental ministries (ADEME in France, UBA / ZSVR in Germany, CONAI consortia in Italy) rather than tax authorities.

For producers selling cross-border, the complexity multiplies. Each country sets its own EPR framework, its own accredited Producer Responsibility Organisations (PROs), its own declaration cadence and its own enforcement architecture. There is no EU-wide one-stop-shop equivalent to VAT IOSS / OSS. The harmonisation that exists comes from PPWR Article 45 (packaging only) since 12 August 2026, and even then, the producer still designates one representative per Member State, not a single EU representative.

Who is the producer under EPR rules?

The producer concept is the foundational definition of any EPR regime. It is broader than common-sense usage of "manufacturer" or "brand owner". The producer is the entity that first places a product on the market of a given country, regardless of where that entity is established. Three real-world examples:

• A US LLC shipping packaged goods to French consumers via Amazon FBA.The US LLC is the producer for French EPR under Article L. 541-10 II of the Code de l’environnement. The fact that Amazon France handles fulfilment does not change the producer status. The LLC is a non-EU producer and must designate a France-established representative.
• A German GmbH shipping textile products to Italian consumers via its Shopify store.The GmbH is the producer for Italian textile EPR. German LUCID registration does not satisfy Italian obligations. The GmbH must register with the Italian textile EPR scheme as it becomes operational, and designate an Italian-established representative if it is not Italian-established.
• A Chinese factory shipping containers to a French importer for resale.Ownership decides. If the French importer already owns the goods when they enter France, the French importer is the producer. If the Chinese factory still owns them when they enter France, the Chinese factory is the producer. Neither the Incoterm nor the customs clearance decides; the transfer of ownership does.

For producers without a local establishment, every major EU EPR regime requires designation of a locally-established authorised representative (in French: mandataire REP; in German: Bevollmächtigter). The representative acts in the producer’s name to register and declare; the eco-contributions themselves are set by each scheme on its published schedule and are distinct from the representative's fee. In France, the basis is 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. You remain the producer. Under the written mandate required by Article L. 541-10-9-1 of the French Environmental Code, the representative takes charge of and answers 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 EPR compliance map, country by country

A non-exhaustive but representative country-by-country map of the regimes our clients most commonly need to satisfy. The legal architecture differs significantly; the operational pattern (register → pay → declare → renew) is roughly similar across all.

We operate as authorised representative in France only. We sign the French mandate, file dossiers with French eco-organisms, obtain the IDU on ADEME SYDEREP, and file French declarations. For other EU Member States, a separate authorised representative established in each country is required; that is outside our scope and the producer arranges it separately.

The 19 EPR streams, France focus

France runs the most stream-intensive EPR regime in the EU under the AGEC law (Loi n° 2020-105 du 10 février 2020). A non-EU consumer brand shipping to France typically falls under 2 to 4 streams. The core consumer streams below are each operated by one or more accredited eco-organisms; producers without a French establishment must register per stream through a France-established mandataire.

• Household packaging (Citeo, Léko, Adelphe), any consumer product shipped in a box, polybag, jar, bottle.
• WEEE, electrical and electronic equipment (Ecosystem, Ecologic), anything that plugs, charges, or contains an electronic circuit.
• Textile / TLC (Refashion), clothing, footwear, household linen, fashion accessories.
• Furniture / DEA (Ecomaison, Valdelia), furniture, mattresses, bedding, structural home decor.
• Batteries (Ecosystem (ex-Corepile), which we register battery clients with; and Batribox (ex-Screlec), approved by arrêté of 27 March 2025; Recycler Mon Véhicule for vehicle batteries, category 5), loose cells and batteries embedded in any device.
• Toys (Ecomaison), any product intended for children under 14.
• Sports, DIY, garden (Ecologic, the only approved eco-organisation for sports and leisure articles; Ecomaison, Valobat or Ecologic for DIY and garden), sports and leisure articles, hand tools, non-motorised garden items.
• Graphic paper (Citeo, Léko), printed catalogs, magazines, advertising mailings distributed in France.
• Construction / PMCB (Valobat, Ecominéro), building materials, panels, insulation, tiles, plumbing fixtures.
• Professional packaging / EPRO (Citeo Pro, Léko Pro, Twiice), packaging of products used only by professionals; a package also sold to households stays household packaging, even when a business buys it. Contributions and identifiers start on 1 January 2027.

For the full stream-by-stream playbook see our streams overview pillar.

What did PPWR Article 45 change on 12 August 2026?

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.

Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation (PPWR), was adopted by the European Parliament and Council on 19 December 2024, published in the Official Journal of the EU on 22 January 2025, and has applied since 12 August 2026. Article 45 is the single most important provision for non-EU producers and for cross-border EU producers shipping packaging between Member States.

In practice: since 12 August 2026, every Member State on a producer’s shipping list requires a locally-established authorised representative for packaging EPR. There is no single-window mechanism. A US D2C brand shipping packaged goods to France, Germany, Italy and Spain needs four separate representative engagements, one per Member State. A German GmbH shipping packaging to France needs a France-established representative; a French SARL shipping to Germany needs a German Bevollmächtigter.

The strategic implication: the per-Member-State representative requirement multiplies the number of mandates a cross-border producer must hold. We focus exclusively on the France leg. Detailed paragraph-by-paragraph analysis of Article 45 lives in our PPWR Article 45 deep dive.

The six-step path to EPR compliance

For a producer without a local establishment entering France (or any other Member State with similar architecture), the path from "we have a problem" to "we are compliant and our IDU is on the public registry" runs through six steps. In France, we file your membership within two business days of receiving the signed mandate, the first invoice payment and the deposit; the identifier then follows within days, about seven business days after the membership is validated at Citeo.

1. Step 1, Identify your EPR scope. Map your product catalog against the EPR streams of each country you ship to. A single product often triggers multiple streams (a Bluetooth speaker = packaging + WEEE + batteries). For France, use our scope-check tool to get a verdict in 90 seconds.
2. Step 2, Engage local authorised representatives. Where you are not established in the country of sale, the representative must be locally-established. France: mandataire REP appointed by written mandate under Article L. 541-10-9-1 of the French Environmental Code, compulsory since 10 July 2026 for every producer not established in France, for every stream. Germany: Bevollmächtigter under VerpackG Section 7. Per Member State engagement has been required since 12 August 2026 for packaging under PPWR Article 45.
3. Step 3, Register with each accredited PRO. One filing per stream per country. France: Citeo, Refashion, Ecosystem etc. Germany: LUCID + chosen PRO. Italy: CONAI sub-consortia. The representative handles the dossier in your name.
4. Step 4, Wait for the producer ID to publish. Each national registry publishes a Unique Producer ID (IDU in France, LUCID number in Germany, ID in Italy, etc.). France: it depends on the eco-organisation, about seven business days after the membership is validated at Citeo, after the first declaration has been filed and paid at Ecosystem. Without a published ID, marketplaces deactivate listings.
5. Step 5, Upload IDs to your sales channels. Amazon Seller Central → Compliance → EPR. Cdiscount Seller Zone → Conformité environnementale. ManoMano back office. Listings reactivate once each platform’s check passes.
6. Step 6, File declarations and maintain compliance. France: most streams are declared once a year; Ecomaison quarterly by default, Valdelia quarterly, Ecominéro monthly, and Ecosystem electrical equipment quarterly unless contributions are paid by SEPA direct debit. Germany: rolling per LUCID. Italy: per CONAI sub-consortium. Missing declarations puts the ID at risk and triggers the marketplace cascade.

What does EPR compliance cost?

Three cost layers stack annually per stream per country. Numbers below are for a typical non-EU consumer brand.

• Representative fee. €2,000 to €5,000 per country per year is a common market range. Our France fee is a fixed annual fee per stream, from €190/year excl. VAT, 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. A one-time setup per stream and a refundable security deposit are stated in the quote. Quote-only providers commonly charge €3,500 to €10,000 or more per stream per year for the same scope, with volume tiers and per-SKU surcharges making the all-in cost hard to predict. See our pricing page.
• Eco-organism membership. €0 to €450 per year per stream, depending on the eco-organism. Refashion membership scales with volume. This fee is set by the eco-organism and sits outside the representative's fee: we take no percentage and no markup on it.
• Eco-contribution. Variable, scaled to declared tonnage and material mix. €0.02 to €2.80 per kilogram of packaging in France, from glass to PVC-containing packaging (2027 grids), is the published span; lightweight cardboard sits at the low end, mixed plastics and laminates at the high end. Eco-modulation grids reward recycled content and recyclability (typically 5 to 15% discount), penalise problematic formats (typically 5 to 50% surcharge). For year-by-year calculation see our eco-contribution calculation guide.

For a non-EU consumer brand shipping packaged goods to four EU Member States (FR/DE/IT/ES), all-in EPR cost typically runs €15,000 to €25,000 per year just for packaging. Adding WEEE doubles or triples the cost. The interactive eco-contribution simulator gives a more precise estimate of the eco-contribution layer for your specific catalog.

Common EPR compliance mistakes

Five mistakes account for most of the enforcement files we see. Each is preventable with the right framing upfront.

How do non-EU producers comply in France?

The bulk of our practice is non-EU producers, US LLCs, UK Ltd companies (post-Brexit), Hong Kong companies, Chinese exporters, Swiss and Norwegian firms. The structural fact for all of them is identical: you cannot legally be the French EPR mandataire from outside France. Article L. 541-10-9-1 of the Code de l’environnement, created by law n° 2026-602 of 8 July 2026 and applicable from 10 July 2026, requires any producer not established in France and subject to EPR to appoint a representative established in France, for every stream, by written mandate. For packaging, Article 45 of Regulation (EU) 2025/40 (PPWR) adds the same requirement at EU level. You remain the producer. Under the written mandate required by Article L. 541-10-9-1 of the French Environmental Code, the representative takes charge of and answers 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 Conseil d’État’s EcoDDS ruling of 10 November 2023 now concerns producers established in France.

The country-specific guides for non-EU producers:

• EPR France from the United States, US LLC playbook, FBA, Shopify, D2C.
• EPR France from the United Kingdom, post-Brexit, UK Ltd companies are non-EU.
• EPR France from China, fast-track for Shenzhen electronics exporters.
• EPR France from Canada, Canadian brands shipping to France.

For an at-a-glance comparison with other Member State regimes, see our EPR by country pillar. For the broad regulatory framework, the French EPR legal framework pillar.

Frequently asked questions

Sources & references

Every legal claim on this page traces to one of the primary sources below. Verified 24 May 2026.

• Regulation (EU) 2025/40 (PPWR), EUR-Lex · Adopted 19 December 2024, OJEU 22 January 2025, applicable since 12 August 2026.
• Directive 2008/98/EC (Waste Framework Directive, consolidated), EUR-Lex · Article 8a(5) on authorised representatives.
• Article L. 541-10 du Code de l’environnement, Légifrance · French producer definition and authorised representative regime.
• Article L. 541-10-9 du Code de l’environnement, Légifrance · Joint liability of online marketplaces.
• Article L. 541-9-5 du Code de l’environnement, Légifrance · Substantive sanctions.
• Article L. 541-9-4 du Code de l’environnement, Légifrance · Info-tri sanction: up to €3,000 (individual) or €15,000 (company) per reference.
• Loi n° 2020-105 du 10 février 2020 (AGEC), Légifrance
• Conseil d’État, 10 novembre 2023, n° 449213 (EcoDDS), Actu-Environnement
• Cadre général des filières REP, Ministère de la Transition écologique
• SYDEREP, registre public des producteurs (ADEME)