French EPR representative vs EU Authorised Representative.
Seven roles, one question: who covers French EPR?
Sellers from the US, the UK, China and elsewhere often already pay an EU Authorised Representative, a VAT representative or a UK Responsible Person, and assume French EPR is handled. It is not. This page sets each role side by side: legal basis, who needs it, what it covers, and whether it covers French EPR.
What is the difference between an EPR representative and an EU Authorised Representative?
They answer to different laws. The EU Authorised Representative answers for product safety across the EU; the French EPR representative answers for your registration, identifier and declarations with French eco-organisations. Neither replaces the other, and the same goes for VAT, customs and UK roles.
| Role | Legal basis | Who needs it | What it covers | Covers French EPR? |
|---|---|---|---|---|
| French EPR representative (mandataire REP) | Article L. 541-10-9-1, French Environmental Code (Law No. 2026-602), in force since 10 July 2026 | Any producer subject to French EPR and not established in France, from inside or outside the EU | Eco-organisation memberships, identifier (IDU), declarations, exchanges with the eco-organisation and audits, archiving, for every French stream | Yes. This is the role French EPR requires. |
| PPWR authorised representative for EPR | Article 45 of Regulation (EU) 2025/40 (PPWR), in force since 12 August 2026 | A producer that makes packaging available in a Member State where it is not established | Packaging EPR obligations in that one Member State; one representative per Member State | For packaging only. In France it is met by the same France-established representative and mandate. |
| EU Authorised Representative / responsible person for product safety (欧代) | Article 16 of the GPSR, Regulation (EU) 2023/988; Article 4 of Regulation (EU) 2019/1020 | Manufacturers outside the EU placing products on the EU market with no EU manufacturer or importer | Product safety and conformity: technical documentation, CE marking files, contact point for market surveillance authorities | No. It does not touch EPR, eco-organisations or the IDU. |
| Fiscal (VAT) representative | Article 289 A, French General Tax Code (CGI) | Businesses established outside the EU that register for French VAT, in most cases | French VAT registration, VAT returns and payments, with joint VAT liability | No. VAT and EPR are separate regimes with separate registrations. |
| IOSS intermediary | EU VAT rules on the Import One-Stop Shop | Sellers outside the EU using IOSS for consignments of goods up to €150 | VAT on low-value imports, collected at the point of sale and declared monthly | No. IOSS has no effect on EPR. |
| Customs representative | Article 18, Union Customs Code | Importers that delegate their customs formalities | Customs declarations and clearance | No. |
| UK Responsible Person / UK authorised representative | UK product law (UKCA marking, UK cosmetics rules) | Businesses selling regulated products in Great Britain | UK product conformity; UK packaging EPR is a separate UK registration | No. It covers neither the EU nor France. |
Does my EU Authorised Representative cover French EPR?
No. The EU Authorised Representative, or responsible economic operator, is required by Article 16 of the General Product Safety Regulation (Regulation (EU) 2023/988) and Article 4 of Regulation (EU) 2019/1020 when a product is placed on the EU market without a manufacturer or importer established in the EU. Its job is product safety: holding conformity documentation, answering market surveillance authorities and appearing on the product or its packaging. Chinese sellers usually call it 欧代.
French EPR is a different obligation: financing the end of life of products and packaging through an approved eco-organisation. Its legal basis is the following. 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. Your 欧代 does not file eco-organisation memberships, does not obtain your IDU and does not declare your volumes. One responsible person established anywhere in the EU can serve the whole EU for product safety; the EPR representative must be established in France.
Is the PPWR representative the same as the French EPR representative?
For France and for packaging, yes in practice. Since 12 August 2026, Article 45 of Regulation (EU) 2025/40 (PPWR) 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 EPR in that Member State. In France, the France-established representative you appoint under Article L. 541-10-9-1 holds that role for packaging and for every other French stream, in one mandate.
The PPWR rule is per Member State: there is no single EU window, so Germany, Italy or Spain each need their own local representative. Paragraph by paragraph analysis in our PPWR Article 45 guide.
Does my VAT, IOSS or customs representative cover EPR?
No. A fiscal representative under Article 289 A of the French General Tax Code handles French VAT and shares your VAT liability. An IOSS intermediary handles VAT on imported consignments of up to €150. A customs representative under Article 18 of the Union Customs Code handles customs declarations. None of them deals with eco-organisations, and a French VAT number does not make you established in France for EPR. More on the two regimes in our VAT and EPR comparison.
Does my UK or US registration cover France?
No. A UK Responsible Person, UKCA marking and UK packaging EPR registration are UK regimes: they cover neither the EU nor France. US state EPR programmes stop at the state border. Whatever you hold at home, selling to French customers makes you a producer under French EPR, with a France-established representative. Country by country obligations are in our by-country hub (US, UK, China, Switzerland).
Do I need one representative per EPR stream?
No. One France-established representative and one written mandate cover all your French streams, whether you sell packaged goods, electrical equipment, batteries, textiles or furniture. Each stream keeps its own eco-organisation membership, identifier and declarations, all handled under that single mandate. See what the mandate covers on our EPR authorized representative page.
Can one company need several of these representatives?
Yes, and most foreign sellers do. A US or Chinese brand selling consumer products to French customers typically needs an EU responsible person for product safety, a French EPR representative and a VAT set-up. Each is a separate engagement, often with a separate provider.
- Non-EU seller (US, UK, China, Switzerland...): EU responsible person for product safety, French EPR representative, VAT set-up (fiscal representative or IOSS intermediary), customs arrangements, and a PPWR representative in every other Member State where it sells packaged goods.
- EU seller with no French entity (Germany, Spain, Italy...): no 欧代 needed, being itself established in the EU, but a French EPR representative is required since 10 July 2026, as our EU companies page explains.
- Company established in France: no French EPR representative; it registers and declares in its own name.
Which of these roles do we cover?
French EPR only. We act as the France-established EPR representative under Article L. 541-10-9-1 for all your French streams, which also meets PPWR Article 45 for France. We are not an EU Authorised Representative for product safety, a fiscal or customs representative, an IOSS intermediary or a UK Responsible Person, and we do not act outside France.
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.
Frequently asked questions
Does my EU Authorised Representative cover French EPR?
No. An EU Authorised Representative or responsible person under Article 16 of the GPSR (Regulation (EU) 2023/988) or Article 4 of Regulation (EU) 2019/1020 handles product safety and conformity. French EPR is a waste-financing obligation with its own legal basis, Article L. 541-10-9-1 of the French Environmental Code, and requires a separate France-established representative under a separate written mandate.
Is the PPWR authorised representative the same as the French EPR representative?
For France, in practice yes, for packaging. PPWR Article 45 requires one EPR representative per Member State where you make packaging available and are not established. In France, the France-established representative you appoint under Article L. 541-10-9-1 covers packaging and every other French stream in one mandate. Germany, Italy or Spain each need their own representative.
Does my VAT fiscal representative or IOSS intermediary cover EPR?
No. A fiscal representative under Article 289 A of the French General Tax Code handles French VAT, and an IOSS intermediary handles VAT on low-value imports. Neither files eco-organisation memberships, obtains an IDU or declares volumes placed on the market. Holding a French VAT number does not make you established in France for EPR purposes.
Does my UK or US registration cover France?
No. UK packaging EPR, UKCA marking, a UK Responsible Person and US state EPR programmes are domestic regimes with no recognition under French law. A UK, US, Swiss or Chinese company selling to French customers must register in France through a France-established EPR representative.
Do I need one representative per EPR stream?
No. One France-established representative and one written mandate cover all of your French EPR streams. Each stream keeps its own eco-organisation membership, identifier and declarations, which the representative handles under that single mandate.
Can one company need several of these representatives?
Yes, and most foreign sellers do. A US or Chinese brand selling consumer products to French customers typically needs an EU responsible person for product safety, a French EPR representative, and a VAT set-up (fiscal representative or IOSS intermediary). An EU company with no French entity usually needs only the French EPR representative, plus a VAT set-up if it registers for French VAT.
Which of these roles does EPR Representative cover?
Only French EPR: we act as the France-established representative under Article L. 541-10-9-1 for all your French streams, which also meets PPWR Article 45 for France. We do not act as EU Authorised Representative for product safety, fiscal or customs representative, IOSS intermediary or UK Responsible Person, and we do not act outside France.
Does an EU company need a French EPR representative?
Yes, if it has no establishment in France. Article L. 541-10-9-1 applies to any producer not established in France, from inside or outside the EU. A German, Spanish or Italian seller with no French entity needs no GPSR responsible person, being itself established in the EU, but does need a French EPR representative.
Sources and references
- Loi n° 2026-602 du 8 juillet 2026, creating Article L. 541-10-9-1 of the Code de l'environnement, in force 10 July 2026
- Regulation (EU) 2025/40 (PPWR), Article 45, EUR-Lex
- Regulation (EU) 2023/988 (GPSR), Article 16, EUR-Lex
- Regulation (EU) 2019/1020 (market surveillance), Article 4, EUR-Lex
- Article 289 A of the Code général des impôts (fiscal representative); Article 18 of the Union Customs Code (customs representative)
Your France-established EPR representative, one mandate for every stream.
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