French EPR compliance,
for producers in Australia.
Australia is a non-EU jurisdiction for French EPR. An Australian Pty Ltd, sole trader or registered business shipping packaged consumer goods to French addresses must designate a France-established mandataire REP. Our workflow accepts ASIC certificates and ABN-registered entities. The 8-10 hour time zone difference is managed via async dossier preparation.
Why Australia exporters end up here.
Australian brands in wellness, beauty, food, fashion and electronics increasingly expand to France via Amazon FBA-EU and Shopify. France is one of the top-3 EU expansion markets for ANZ brands, alongside UK (post-Brexit, also non-EU) and Germany.
Appointing a representative is no longer optional.
Law n° 2026-602 of 8 July 2026 created Article L. 541-10-9-1 of the French Environment Code, in force on 10 July 2026. Any person with no establishment in France who is subject to Extended Producer Responsibility must appoint, by written mandate, a natural or legal person established in France, and that representative is subrogated into the EPR obligations for which it accepts the mandate. Until that date the appointment was an option; it is now a statutory obligation, and it covers all 19 French EPR streams rather than packaging alone.
Two consequences matter for Australia-based sellers. The test is establishment in France, not nationality and not EU membership, so nothing about your home jurisdiction exempts you. And if you already hold a French eco-organism membership with no representative recorded on the file, it no longer satisfies the statute on its own: a representative has to be appointed and the mandate registered with each eco-organism. That is a file update rather than a re-registration, so the IDU does not have to be lost.
Our breakdown of law n° 2026-602 sets out the scope, the three conditions of the mandate, how it reaches online marketplaces, and the regularisation path.
The documents we file for you.
- Business registration
- ASIC Company Certificate (certificate of registration) or ASIC current company extract. ABN (Australian Business Number) registration confirmation from ABR.
- Tax identifier
- ABN (11-digit Australian Business Number). Optional: GST registration if above AUD 75,000 turnover threshold.
- Invoicing & currency
- We invoice in EUR. Australian Pty Ltd companies receive in AUD via international wire. Australian GST does not apply to our service (export of intangible services). No French VAT applies to the EPR representative service.
What Australia sellers need to watch.
Time zone management
AU is 8-10 hours ahead of Paris. Dossier preparation runs async, we send signed documents via electronic signature platform that works regardless of time zone. Live calls scheduled for AU mornings = Paris evenings.
Australia has its own packaging EPR (APCO)
The Australian Packaging Covenant Organisation regulates Australian packaging EPR. APCO has no extraterritorial effect on French obligations. Australian brands shipping to France need independent French registration.
Post-Brexit UK comparison
AU brands often consider UK as the EU launchpad. Since Brexit, UK is also non-EU for French EPR, UK registration does not cover France. France must be registered independently if you ship there.
The streams Australia sellers most often need.
Household packaging
Required for any product sold to French consumers in packaging (boxes, polybags, fillers, bottles, jars).
Stream details →Electrical and electronic equipment (WEEE)
Required for any product with a plug, battery, cable or electronic component sold to French consumers.
Stream details →Textile, household linen and footwear (TLC)
Required for any apparel, linen or footwear product shipped to French consumers.
Stream details →Furniture (DEA)
Required for any item of furniture, mattress or bedding shipped to French consumers, plus most home decor.
Stream details →Portable batteries and accumulators
Required for standalone portable batteries, plus rechargeable cells embedded in any device.
Stream details →Toys
Required for any toy intended for use by children under 14, shipped to French consumers.
Stream details →Australia-specific questions.
- My Australian brand sells exclusively via Amazon UK. Do I need French EPR?
- Only if Amazon UK fulfils orders to French consumers via FBA-EU. If your inventory in Amazon UK warehouses ships only to UK and Ireland, no French EPR needed. If FBA-EU redistributes your stock to French warehouses for French orders, you become a French producer and need EPR.
- Does the EU-Australia FTA cover EPR?
- No, the EU-Australia FTA is still under negotiation (as of mid-2026). Even when ratified, it will cover trade tariffs, not environmental regulation. EPR is independent of trade agreements.
- Can I pay annually in AUD upfront?
- We invoice in EUR at the fee set in your written quote. You can wire in AUD; the bank converts on transfer. Annual billing accepted on request.
- Established and registered in France
- No percentage on your eco-contributions or membership fees
- All 19 French EPR streams covered
- Statutory subrogation (law n° 2026-602, Art. L. 541-10-9-1)
Representative cases we handle
Anonymized examples of real mandates and scoping. Each producer sells into France without a French entity. (Named references available on request, with client consent.)
PC-hardware brand selling its own products D2C into France (cases, coolers, power supplies).
Scope: household packaging (Citeo or Léko) + WEEE (Ecosystem or Ecologic). We handle the adhesions, the IDU on ADEME SYDEREP and the declarations.
Automotive-parts seller shipping to French consumers from an EU warehouse.
Scope: consumer packaging. We act as the authorized representative for the packaging stream and file on their behalf.
Gardening and outdoor brand selling packaged goods into France via marketplaces.
Scope: packaging, with a scope check on WEEE for the powered items. Registration built to satisfy marketplace UIN requests.
Post-Brexit micro-brand with no French entity, shipping small orders into France.
Scope: packaging (cardboard, paper, compostable). Flat-fee regime mandate, kept proportionate to their volumes.
Multi-brand retailer preparing its entry into the French market.
Scope: multi-stream mapping across packaging, WEEE and batteries, sequenced so listings go live compliant.
Electronics seller with battery-powered products, no French establishment.
Scope: batteries (Batribox or Ecosystem) + WEEE. We compare eco-organisms on the real product mix and register with the best fit.