EU company selling into France?
French EPR applies to you too.
French EPR is often described as a rule for non-EU sellers. It is not. The trigger is establishment in France, not nationality. A German, Dutch, Danish, Spanish or Slovak company with no French entity that ships products to French customers is a producer under Article L. 541-10 of the Code de l’environnement, must register, obtain an IDU, and, because it is not established in France, appoint a France-established authorized representative.
- ✓ Same obligation as non-EU sellers
- ✓ IDU in 2 to 3 weeks
- ✓ PPWR Article 45 ready (12 August 2026)
The two-question test
EU membership appears nowhere in the French producer test. Two questions decide your position:
- Do you place the products on the French market? If a France-established importer or distributor takes title before the goods reach France, that entity is the producer, not you. If you ship to French consumers or businesses while keeping title (webshop, Amazon, eBay, direct B2B deliveries), you are the producer.
- Are you established in France? If yes, you register directly with the eco-organisms. If no, you must appoint a France-established authorized representative (mandataire) who registers, obtains the IDU and files the declarations in your name.
What does NOT count as “established in France”
Your German, Spanish or Italian EPR registration does not travel
EPR is national law implemented country by country. LUCID (Germany), Ecoembes (Spain) or CONAI (Italy) registrations have no effect in France. France runs its own producer registry (ADEME SYDEREP, issuing the IDU), its own eco-organisms per stream, and its own labeling rules (Triman and Info-tri). French marketplaces (Amazon FR, Cdiscount, ManoMano) verify the French IDU specifically and suspend listings without it, whether the seller is Chinese or German. See our France vs Germany EPR comparison.
From 12 August 2026, PPWR makes it explicit
Until now the representative rule for EU producers flowed from the French Code de l’environnement. Article 45 of Regulation (EU) 2025/40 (PPWR), applicable from 12 August 2026, states it at EU level: any producer placing packaging in a Member State where it is not established must designate an authorized representative established there. A Dutch company selling packaged goods into France needs a France-established representative exactly as a US one does.
Which streams typically apply to EU sellers
| You sell… | Streams in scope | Eco-organisms |
|---|---|---|
| Any packaged consumer product | Household packaging (+ graphic paper if printed material) | Citeo, Léko, Adelphe |
| B2B goods with transport packaging | Professional packaging (EPRO) | Citeo Pro, Léko Pro, Twiice |
| Electronics, anything with a plug or battery | WEEE + batteries | Ecosystem, Ecologic, Screlec |
| Apparel, footwear, household linen | Textile (TLC) | Refashion |
| Furniture, toys, sports & DIY items | DEA / toys / ASL | Ecomaison, Valdelia |
| Construction products | PMCB | Valobat, Ecominéro |
Full details per stream on the services pages, or run the 90-second scope check.
Frequently asked questions
We are an EU company. Do we really need French EPR?
If your company is not established in France and you place products on the French market, yes. The legal trigger is establishment in France, not nationality or EU membership. A Danish, Spanish or German company not established in France that places products on the French market is a producer under Article L. 541-10 and must register, appointing a France-established authorized representative because it is not established in France.
Does having an FBA warehouse, a French VAT number or a French bank account make us established?
No. Establishment means a registered legal entity in France (subsidiary or branch at the RCS) or a permanent establishment with real substance. Stock in a 3PL or FBA warehouse, a VAT registration, a bank account or a .fr domain do not make you established for EPR purposes. You remain a non-established producer and need a French representative.
Our German LUCID registration covers packaging. Does it apply in France?
No. EPR is national. The German LUCID/VerpackG registration has no effect in France, which runs its own registry (ADEME SYDEREP, issuing the French IDU) and its own eco-organisms (Citeo, Léko, Adelphe for household packaging). Each country where you sell requires its own registration.
Does PPWR change anything for EU companies from August 2026?
Yes, it makes the rule explicit for packaging. PPWR (Regulation (EU) 2025/40), Article 45, applicable from 12 August 2026, requires any producer not established in a Member State where it places packaging to designate a representative established in that Member State. For France that means a France-established representative, regardless of whether the producer is EU or non-EU.
We sell through a French distributor who imports our goods. Are we still the producer?
Usually not. If a France-established distributor takes title to the goods and places them on the French market, that distributor is the producer and carries the EPR obligations. The analysis turns on who first places the products on the French market, check your Incoterms and title transfer. If you also sell direct to French customers (D2C, marketplaces), you are the producer for those flows.
What does it cost for an EU company?
The same published grid as for any foreign producer: per stream, setup from €290 and a monthly fee from €49 (Light tier) depending on volumes, plus the eco-contributions billed by each eco-organism at cost. Most EU sellers need 1 to 3 streams. The 60-second calculator gives your exact price.
Go deeper
- Do EU companies need French EPR too? The full legal analysis
- If a French distributor imports my goods, who is the producer?
- Avoiding double declaration with a French importer
- How EPR registration works in France, step by step
See your price before you commit
Our pricing is published, not hidden behind a quote form. Use the cost calculator for an instant estimate across every EPR stream that applies to you, then start your application when you are ready.