Direct-to-consumer to France? You need an EPR representative.
Shipping from a US, UK or Asian warehouse to French consumers makes you the producer for French EPR purposes. We register you with the relevant eco-organism so your French sales stay compliant and do not trigger administrative action.
Does Shopify D2C trigger French EPR?
Yes, it is a textbook EPR trigger. Under article L. 541-10 II of the French Environment Code, the producer is whoever places the product on the French market for the first time. For a Shopify brand shipping from outside the EU directly to a French customer, that is the brand.
Unlike the traditional importer chain, where a French distributor takes the producer role, Shopify D2C bypasses any French intermediary. The obligation lands on the seller.
Since 10 July 2026 the response to that trigger is prescribed, not chosen. Article L. 541-10-9-1 of the French Environment Code, created by law n° 2026-602 of 8 July 2026, requires any producer not established in France and subject to EPR to appoint a representative established in France, for every stream, under a written mandate. You remain the producer. The test is establishment in France, not nationality, so a European brand shipping into France from its home market is covered exactly like a brand shipping from outside the Union. Selling on your own storefront also means no platform is absorbing any part of the obligation for you: the statutory exemption for products whose EPR obligation a marketplace takes on under Article L. 541-10-9 does not reach D2C sales. Our breakdown of the statute covers the scope and the conditions of the mandate.
Which streams does a Shopify brand need?
Most cross-border D2C operations need two or three: household packaging for every order, plus the stream of the product itself.
Packaging
Required for any product sold to French consumers in packaging (boxes, polybags, fillers, bottles, jars).
WEEE
Required for any product with a plug, battery, cable or electronic component sold to French consumers.
Textile
Required for any apparel, linen or footwear product shipped to French consumers.
Furniture
Required for any item of furniture, mattress or bedding shipped to French consumers, plus most home decor.
Batteries
Required for standalone portable batteries, plus rechargeable cells embedded in any device.
Do my Shopify parcels need the Triman?
In Citeo's interpretation, yes: the shipping box delivered to a French consumer is household packaging to be marked with the Triman and the Info-tri, like the product packaging inside it. Léko accepts a sticker on the packaging, including to relabel stock already packed.
The official files come with your Citeo or Léko membership, which we open for you; the artwork stays with you and your designer. Read e-commerce parcels and stickers and the Info-tri and Triman guide.