Frequently asked questions about French EPR.

A person established in France and appointed in writing by a producer with no establishment in France, whether it is based outside the EU or inside it, to handle its Extended Producer Responsibility in France. 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. 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.

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. 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. Confirm the cover 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, Valobat, Ecominéro, Citeo Pro, Léko Pro, Twiice and others). A German LUCID number does not cover France. You need a separate French registration per stream.

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 mandate is limited to French EPR: you remain the producer.

No, producer status is not transferable and 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. You keep control of your product data, and you still answer for the accuracy of what you declare and for any period before the mandate took effect.

Yes. The mandate runs for the calendar year from 1 January and renews tacitly each year. Either party may end it by registered letter received by 30 September, effective 31 December. Since the appointment itself is compulsory for a producer without a French establishment, ending the mandate 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. 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 your written quote. We do not add per-tonne mark-ups, opaque adders, or eco-organism rebates kept by the representative. 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, answer the eco-organisation, archive) and does not grow with the euro value of your eco-contributions. 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.

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. Your eco-contributions stay invoiced to you and paid by you directly to the eco-organisation. 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.

It depends on the eco-organisation. Citeo issues the identifier about seven business days after the membership is validated. Léko issues it about five business days after its initial invoice is paid; that invoice must be paid within five business days, otherwise the membership is cancelled. Refashion issues it after membership, the signed contract and your first declaration and payment, then about ten business days. Ecosystem issues it after your first declaration has been filed and paid. Professional packaging (EPRO): registration is open now, eco-contributions from 1 January 2027. We file your membership within two business days of receiving the signed mandate, the first invoice payment and the deposit.

Yes. Most streams are declared once a year. Exceptions: Ecomaison declares quarterly by default (annual on option below 15 t, 1,000 pieces and EUR 2 million of turnover in the stream), Valdelia quarterly, Ecominéro monthly, and Ecosystem electrical equipment quarterly unless contributions are paid by SEPA direct debit. We 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 the documents needed to answer their compliance requests, 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 of up to €30,000, plus up to €7,500 per unit or per tonne for a company (€1,500 for an individual) for a substantive breach (checked on Légifrance on 6 October 2026). 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.

Registration is due from your first sale in France, and eco-organisations can claim contributions for earlier years: up to five years at Refashion (the current year and four previous ones), three at Ecomaison, Ecosystem and Valobat, one at Citeo, none at Léko. Identifiers are never backdated. We tell you before signing whether earlier years are at stake.

Regulation (EU) 2025/40, known as the PPWR, has applied since 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. France already requires a representative for every stream since 10 July 2026 (Article L. 541-10-9-1); the PPWR makes the packaging rule 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.

Yes. Household packaging and graphic papers placed on the French market carry the Info-tri, with the Triman logo, whatever their origin, EU or non-EU. The obligation applies since 1 January 2022; the sell-off period for older stock ended on 9 March 2023. Packaging of products used only by professionals is out of scope.

From your eco-organisation, once you are a member. Citeo provides the Easy Info-tri generator in its client area; Léko provides licensed files in its member document area, which you compose yourself. Neither eco-organisation validates your artwork. We open the membership for you; the artwork stays with you and your designer.

Léko accepts a sticker on the packaging, including to relabel stock already produced. The marking must sit on the packaging, never inside it. If you are a Citeo member, follow the Citeo guide.

Citeo treats the shipping box delivered to a consumer as packaging to be marked, and its 2027 guide counts a parcel made of a box, tape and void fill as three units. Packaging sold only to professionals is out of scope, but a package also sold to households stays household packaging.

No. The 2027 Citeo and Léko scales carry no bonus or malus linked to Info-tri; the marking is a legal requirement. The only related premium (4%) rewards off-pack media awareness campaigns.

Glass beverage bottles are exempt from the obligation; voluntary marking is recommended. The exemption covers glass beverage packaging only: other household packaging keeps the Info-tri and the Triman.

Up to €3,000 for an individual or €15,000 for a company, per non-compliant reference, under Article L. 541-9-4 of the French Environmental Code. Checks are carried out by the DGCCRF, the French consumer protection authority.