Direct-to-consumer to France? You need an EPR representative.

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 person subject to French EPR without an establishment in France to appoint a France-established representative by written mandate, and subrogates that representative into the obligations it accepts, across all 19 EPR streams. 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 handled by a France-established marketplace does not reach D2C sales. Our breakdown of the statute covers the scope and the conditions of the mandate.