Frequently asked questions about French EPR.

A French legal entity appointed in writing by a producer with no establishment in France, whether it is based outside the EU or inside it, to carry its Extended Producer Responsibility obligations. The role is anchored in Article 8a §5 of Directive 2008/98/EC, transposed into the French Environment Code (L. 541-10), and since 10 July 2026 it is compulsory under Article L. 541-10-9-1, which subrogates the representative into the obligations whose mandate it accepts. The representative registers with the relevant eco-organisms, obtains an Identifiant Unique Producteur (IDU) from ADEME and files periodic declarations; the eco-contributions themselves are set by each eco-organism on its published barème and stay separate from the representative’s fee.

Yes, if you place products subject to French EPR on the French market without an establishment in France. The test is establishment in France, not nationality and not EU membership: a German, Spanish or Italian company with no French entity is in the same position as a US or Chinese one. This applies to packaging, electronics, textile, furniture, batteries, toys, sports, DIY, garden, paper, construction, and professional packaging streams. Marketplaces (Amazon, eBay, ManoMano, Cdiscount) are required by L. 541-10-9 to verify your EPR registration number, and they suspend listings when it is missing.

Since 10 July 2026. Law n° 2026-602 of 8 July 2026, the so-called "Fast Fashion" law (Journal officiel n° 0159 of 9 July 2026), created Article L. 541-10-9-1 of the Code de l’environnement: any person not established on French territory who is subject to EPR under Article L. 541-10 or L. 541-10-9 must appoint, by written mandate, a natural or legal person established in France. Despite the textile title of the law, the measure is horizontal and covers all 19 French EPR streams. The test is establishment in France, not nationality, so an EU company with no French entity is covered exactly like a US or Chinese one. Before that date appointing a representative was an option; it is now a statutory obligation, independent of PPWR.

Yes, in both directions. A platform that facilitates distance sales or delivery on behalf of third-party sellers, and is therefore covered by Article L. 541-10-9, must itself appoint a France-established representative if it is not established in France. Conversely, Article L. 541-10-9-1 provides that the appointment obligation is treated as satisfied for products whose EPR compliance a France-established person covered by Article L. 541-10-9 actually ensures. Two caveats: the statute frames that cover per product and per stream, and in practice it is also channel-specific, since a platform only ensures compliance for what it sells. As soon as you sell elsewhere, the uncovered perimeter is yours again. Confirm it in writing with the platform rather than assuming it.

Only if a France-established representative is recorded on the file. Eco-organisms have long required a French counterpart to open a membership, but some producers not established in France reached a membership and an IDU without a representative on file, and since 10 July 2026 that no longer satisfies the statute. Regularisation runs in five steps: identify a France-established representative for the streams concerned, conclude the written mandate, send that mandate to the eco-organism so it updates your membership, have the representative sign or take over the membership contract, then let the eco-organism update the data in SYDEREP. The IDU does not have to be lost: this is a file update, not a re-registration.

A unique producer identifier issued by ADEME through the SYDEREP system after registration with the relevant eco-organisms. Each EPR stream gives you a different IDU. Marketplaces ask for these numbers to keep your listings active.

No. France has more EPR streams than any other EU country (currently 19 official streams) and runs them through several eco-organisms (Citeo, Léko, Ecosystem, Ecologic, Refashion, Ecomaison, Valdelia, Batribox, Ecosystem (ex-Corepile), Valobat, Ecominéro, Citeo Pro). A German LUCID number does not cover France. You need a separate French registration per stream.

A written mandate, governed by articles 1984 et seq. of the French Civil Code, and authorized by Article 8a §5 of Directive 2008/98/EC. Since 10 July 2026, Article L. 541-10-9-1 of the Code de l’environnement makes that mandate compulsory for a producer without a French establishment and subrogates us into the EPR obligations it covers. It is revocable and limited to French EPR: you remain the producer.

No, producer status is not transferable and stays with you. What did change on 10 July 2026 is the liability behind it: Article L. 541-10-9-1 of the Code de l'environnement (law n° 2026-602 of 8 July 2026) subrogates your French representative into the EPR obligations whose mandate it accepts, for the scope and the duration of that mandate. You keep control of your product data and your relationship with the eco-organisms, and you still answer for the accuracy of what you declare and for any period before the mandate took effect.

Yes. As any mandate under the Code civil, it is revocable at any time, with notice. Since the appointment itself is compulsory for a producer without a French establishment, revocation goes hand in hand with appointing another France-established representative. Practically, we hand over your registration data, your IDU numbers, and the open declarations to your next representative or to your own French entity if you incorporate one.

No. We are a French entity that represents you for EPR purposes only. We do not handle your VAT, your customs, or your corporate filings.

Our fee 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 your written quote. We do not add per-tonne mark-ups, opaque adders, or eco-organism rebates kept by the representative. 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. Eco-contributions are set by each eco-organism on its published barème and stay separate from our fee: we take no percentage on them.

Because EPR work for a foreign seller is mostly administrative, register, declare, pay, repeat, and the workload is driven by each stream's declaration regime (flat-fee, simplified or itemised) and by the number of product references we declare, not by your sales volume or the euro value of your eco-contributions. A fixed annual fee per stream, stated in writing before you commit, is the most honest way to price that work.

Each stream is priced as its own fixed annual fee, and everything is consolidated in one mandate and one written quote. A typical Amazon FBA seller with packaging, WEEE and batteries receives a single quote covering all three streams within one business day.

No. Eco-contributions are set by each eco-organism (Citeo, Refashion, etc.) on its published barème, based on your declared volumes, materials and eco-design criteria. They stay entirely separate from our fee: we take no percentage and no markup on them, none on the eco-organism membership fees either, and our fee is never indexed on what you contribute.

After the mandate is signed: typically 2 to 3 weeks per stream to reach an active IDU, depending on the eco-organism workload. We start all streams in parallel.

Yes. We file periodic declarations (typically annual, sometimes quarterly depending on the eco-organism), check every eco-contribution amount against the volumes declared and the applicable barème, and keep you informed with a short report each cycle.

Yes. We provide your IDU numbers in the format each marketplace requires, and we respond to compliance notices on your behalf, with you in copy.

Tell us. We update the scope, add the new stream if needed (a one-time setup applies per new stream, stated in an updated written quote), and keep declarations consistent. If a change in your catalogue moves a stream to a different declaration regime, we confirm the updated fee in writing before it applies.

The French Environment Code (L. 541-9-5) provides administrative penalties up to €30,000 per non-registration episode, plus €7,500 per unit or per tonne for a company (€1,500 for an individual) for a substantive breach. L. 541-10-9 obliges marketplaces to verify your registration and to deactivate your listings if it is missing. Repeat or aggravated cases can trigger judicial penalties under L. 541-46.

Yes. We prioritise files where Amazon has already issued a notice. We register with the relevant eco-organisms, obtain the IDU numbers, and submit them in the format Amazon Seller Central requires.

In practice, French enforcement focuses on the current sales year. The fastest way to limit exposure is to register now and declare current-year volumes accurately.

Regulation (EU) 2025/40, known as the PPWR, applies from 12 August 2026. Article 45 requires non-EU producers placing packaging on any EU market to appoint an authorized representative in each member state where they sell. France was already requiring this; the PPWR makes it uniform across the EU.

No. It harmonises the obligation to appoint a representative for packaging across member states. The French system, its eco-organisms and its 19 streams remain in force.