French EPR compliance,
for producers in Hong Kong.
Hong Kong is a non-EU jurisdiction for French EPR purposes, same regime as US LLCs and UK Ltd companies. A Hong Kong Limited shipping packaged consumer goods to French addresses is a producer under Article L. 541-10 II of the Code de l’environnement and must designate a France-established mandataire REP. We handle the full file for HK exporters, with translation of the Business Registration certificate built into the workflow.
Why Hong Kong exporters end up here.
France is the second-largest EU e-commerce market after Germany. For HK trading companies serving European brand owners or operating direct-to-consumer via Amazon France, Cdiscount or Shopify, France is typically the second EU market launched after 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 Hong Kong-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
- Hong Kong Business Registration Certificate (商業登記證) issued by the Inland Revenue Department. Original Chinese + English translation accepted. Standard certificate is sufficient, no apostille required.
- Tax identifier
- Business Registration Number (BR Number). Used as the tax identifier for cross-border filings. Optional: Companies Registry CR number if filed as a limited company.
- Invoicing & currency
- We invoice the client directly in EUR. HK companies often receive in HKD via wire, we provide HKD-equivalent on the invoice for reference. No HK or French VAT applies to our service for a HK Ltd buyer (B2B service outside EU VAT scope).
What Hong Kong sellers need to watch.
Chinese-language documents
HK certificates are commonly bilingual (Chinese + English). Where the certificate is Chinese-only, we coordinate the English translation as part of dossier preparation. No notarisation required for the translation.
Amazon FBA HK seller status
HK-incorporated sellers using Amazon FBA-EU programs are treated as non-EU producers for French EPR. FBA fulfilment does not transfer producer status to Amazon. Compliance burden stays with the HK Ltd.
PPWR Article 45 cross-border multiplier
From 12 August 2026, HK companies shipping packaging to multiple EU Member States need a representative in each. We coordinate the France leg + refer trusted partners in DE, IT, ES, NL.
The streams Hong Kong 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 →Hong Kong-specific questions.
- Can a HK trading company act as the mandataire REP for the brand it represents?
- No. The mandataire must be established in France (Article L. 541-10-9-1 of the Code de l’environnement). A HK Ltd cannot register clients on SYDEREP directly. The HK trading company can introduce the European brand owner to us for the mandate.
- My HK business is structured as a Limited Liability Partnership. Same regime?
- Yes. Any HK business entity placing products on the French market is a producer for French EPR. The legal form does not affect the obligation; only the documentation set varies slightly (LLP agreement vs incorporation certificate).
- Do I need a French bank account?
- No. We invoice our fee in EUR; you pay by international wire from any bank. Eco-contributions are a separate cost, set by the eco-organism on its published schedule, and we take no percentage on them.
- 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.