French EPR compliance,
designed for Italy-based sellers.
An Italian Srl or SpA selling into France is a French EPR producer whenever it is the first to place goods on the French market. EU membership makes no difference: the French mandataire obligation is triggered by not being established in France, not by being outside the EU. Your CONAI participation covers Italy, not France.
When the obligation kicks in.
The trigger is the first placement on the French market, not your country of establishment. An Italian company shipping to French consumers (Amazon.fr, Cdiscount, your own shop) or selling to French buyers who do not take title as importer is the producer under Article L. 541-10 II. From 12 August 2026, PPWR Article 45 makes the per-Member-State authorised representative explicit EU-wide: one representative in each Member State where you are not established.
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 Italy-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.
Three enforcement pressures.
French eco-organisms require a France-established entity to sign the adhésion, hold the IDU and file declarations; an Italian entity cannot register on SYDEREP directly. Amazon France verifies the French IDU regardless of your Italian registration and suspends listings without one (L. 541-10-9). And L. 541-9-5 fines reach €30,000 per non-registration episode plus €7,500 per unit or tonne for a company.
Marketplaces and storefronts.
Italian brands reach French buyers via Amazon.fr, Cdiscount, ManoMano, and D2C Shopify, often with fashion, furniture, food and homeware catalogues. Shared EU logistics with France do not remove the obligation: goods reaching a French consumer trigger French EPR, separate from CONAI.
- A Milan fashion label shipping D2C to French consumers
- A Tuscan furniture brand selling via a French retailer and Cdiscount
- A Bologna food brand whose packaging triggers household packaging EPR
- A Veneto homeware brand on Amazon.fr FBA
The streams Italy-based 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 →Italy-specific questions.
- We are an EU company, does the single market not exempt us from a French representative?
- No. The obligation turns on establishment in France, not on EU membership. An Italian company with no French entity that first places products on the French market must appoint a French authorised representative. PPWR Article 45 confirms this per Member State from 12 August 2026.
- Does our CONAI registration cover France?
- No. CONAI covers Italian packaging obligations only. France requires its own IDU per stream, issued by ADEME after registration with a French eco-organism. The Italian and French systems are independent.
- We are the brand but a factory manufactures for us, are we still the producer?
- Yes. For EPR, the producer is whoever first places the product on the French market under its own name, not the physical manufacturer. Selling your branded goods into France makes you the producer, even if a third-party factory makes 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.