Frequently asked questions about French EPR.

A French legal entity appointed in writing by a non-EU producer to execute its Extended Producer Responsibility obligations. The role is anchored in Article 8a §5 of Directive 2008/98/EC and transposed into the French Environment Code (L. 541-10). The representative registers with the relevant eco-organisms, obtains an Identifiant Unique Producteur (IDU) from ADEME, files periodic declarations, and pays eco-contributions for the producer.

Yes, if you place products subject to French EPR on the French market without a French or EU establishment. 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.

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 10+) and runs them through several eco-organisms (Citeo, Léko, Ecosystem, Ecologic, Refashion, Ecomaison, Valdelia, Ecosystem (ex-Corepile), Screlec, 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. The mandate is civil, revocable, and limited in scope to French EPR execution. You remain the producer.

No. The Conseil d Etat ruling of 10 November 2023 (case 449213, EcoDDS) annulled the subrogation clause that would have transferred producer obligations to the representative. We execute your obligations; we do not absorb them. This is a positive thing: it protects your control over your product data and your relationship with the eco-organisms.

Yes. As any civil mandate, it is revocable at any time, with notice. 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.

Three published tiers per stream — Light from €49/month for small producers under the eco-organism simplified regimes (Citeo <10k UVC, Refashion <5k pieces, Valobat <100t or CA <€2M, Ecomaison ABJ <10k pieces & <15t), Standard from €199/month for mid-market, Volume from €349/month for high-volume single-segment, plus Enterprise on quote for multi-entity groups or volumes beyond the Volume threshold. Setup €290–€1,290 per stream depending on filière complexity (Textile and PMCB carry the highest setup due to retroactive declaration / 4-eco-organism arbitration). We do not add per-tonne mark-ups, opaque adders, or eco-organism rebates kept by the representative. Eco-contributions billed by the eco-organism are passed through at cost.

Because EPR work for a non-EU seller is mostly administrative — register, declare, pay, repeat — and the workload scales primarily with declared volume in the stream's natural unit (UVC, pieces, references, tonnes). Publishing a tier per band of declared volume is the most honest way to price: small producers pay Light, mid-market pays Standard, large volume pays Volume. The variable is volume, never the euro value of your eco-contribution.

Multi-stream discount applies progressively to the monthly fee: −10% on the 2nd stream, −15% on the 3rd, −20% on the 4th and beyond (capped). The setup fee is paid in full per stream. A typical Amazon FBA seller with packaging, WEEE and batteries at Standard tier across all three pays roughly €5,500–€6,000/year (after multi-stream discount). The exact figure is computed in 60 seconds by the calculator at /tools/cost-calculator.

No. Eco-contributions are set by each eco-organism (Citeo, Refashion, etc.) based on your declared volumes, materials, and eco-design criteria. We pass them through at cost on a separate invoice line. We do not mark them up.

After the mandate is signed: typically 2 to 4 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), pay the eco-contributions, 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 (setup €290–€1,290 depending on filière complexity, with the multi-stream discount applied to the monthly fee), and keep declarations consistent. If the change moves you between tiers (e.g. Light → Standard because volume crossed the threshold), we re-tier at the next anniversary with 60-day notice.

The French Environment Code (L. 541-9-6) provides administrative penalties up to €30,000 per non-registration episode plus €7,500 per unit or per tonne under Article L. 541-9-5. 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 other 9+ streams remain in force.