French EPR compliance,
for producers in India.
India is a non-EU jurisdiction for French EPR. An Indian Private Limited, LLP, OPC or sole proprietorship shipping packaged consumer goods to French addresses is a producer under Article L. 541-10 II and must designate a France-established mandataire REP. Our workflow accepts MCA Certificate of Incorporation and GST registration documents directly.
Why India exporters end up here.
Indian brands in textiles, jewellery, beauty, food, and consumer electronics increasingly target France via Amazon FBA-EU and direct D2C. France is in the top-5 EU expansion markets for Indian SMEs.
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 India-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
- MCA (Ministry of Corporate Affairs) Certificate of Incorporation. For LLPs: LLP Agreement + Form 17. For partnerships: partnership deed.
- Tax identifier
- CIN (Corporate Identification Number, 21 characters) or LLPIN for LLPs. PAN (Permanent Account Number) and GSTIN (GST Identification Number) if registered.
- Invoicing & currency
- We invoice in EUR. Indian Pvt Ltd companies receive in INR via international wire (LRS / advance payment for imports of services). RBI compliance handled by your bank, we provide the standard EUR invoice for your inwards documentation.
What India sellers need to watch.
GST + LUT context
Indian exports of services qualify for LUT (Letter of Undertaking) zero-rating under GST. Our invoice (EU B2B service) is outside the Indian GST chargeable scope. Your CA handles the inwards classification.
RBI / FEMA compliance for outward payments
Payment for foreign EPR services flows under LRS or Form A2 for the business entity. Your bank handles the FEMA reporting. We provide the invoice with our SAS registration details for the bank file.
India has its own EPR regime (E-Waste, Plastic Packaging)
India’s E-Waste (Management) Rules 2022 and Plastic Waste Management Rules cover Indian-sold products. They have no extraterritorial effect. French EPR is independent.
The streams India 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 →India-specific questions.
- Indian e-commerce exporters via Flipkart-MENA do not ship to France. Why would I need French EPR?
- You would not, in that case. French EPR applies only if you place product on the French market. If your Indian e-commerce only ships within India or to non-France markets, no French obligation. If you expand to Amazon France FBA, French EPR applies from the first French sale.
- I am an Indian importer of European goods who re-exports to India. Do I have French EPR exposure?
- No. You are a French importer in reverse, the European entity that placed the product on the French market originally is the producer. Re-exporting from India to other markets does not create French EPR exposure for the Indian entity.
- How does the Indian Companies Act CIN compare to other jurisdictions?
- The CIN is functionally equivalent to the US EIN, UK company number, French SIREN, German Handelsregister number. Eco-organisms accept it as the producer’s primary identifier.
- 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.