French EPR compliance,
for producers in Singapore.
Singapore is a non-EU jurisdiction for French EPR purposes. A Singapore Pte Ltd, branch office or partnership shipping packaged consumer goods to French addresses must designate a France-established mandataire REP under Article L. 541-10 II of the Code de l’environnement. Our workflow is set up for ACRA-registered entities, Bizfile excerpt accepted directly, no apostille.
Why Singapore exporters end up here.
Singapore-based brands and trading houses are increasing France-bound shipments via Amazon FBA-EU, Shopify D2C, and direct B2B supply to French retailers. France is a top-3 EU expansion market after Germany and Netherlands.
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 Singapore-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
- ACRA Bizfile (Accounting and Corporate Regulatory Authority business profile excerpt). The standard Bizfile printout is sufficient, original digital PDF accepted.
- Tax identifier
- UEN (Unique Entity Number), Singapore’s unified business identifier. Optionally GST registration number for sellers above the SGD 1 million GST threshold.
- Invoicing & currency
- We invoice in EUR. Singapore Pte Ltd companies receive in SGD via international wire, we provide SGD equivalent for accounting reference. Singapore GST does not apply to our service (B2B export). No French VAT applies.
What Singapore sellers need to watch.
ASEAN-EU regulatory bridge
Many Singapore companies serve as ASEAN-EU hubs handling product flows from China, Vietnam, Indonesia, Thailand. The producer for French EPR is whichever entity places the product on the French market, usually the Singapore Pte Ltd, not the upstream manufacturer.
Singapore-EU Trade Agreement context
The EU-Singapore Free Trade Agreement (in force since 21 November 2019) reduces customs duties but does NOT affect EPR. EPR is environmental law, not trade law, the same obligation applies regardless of trade agreements.
PPWR Article 45 cross-border multiplier
From 12 August 2026, Singapore companies shipping packaging to multiple EU Member States need a representative in each. We coordinate the France leg + refer for DE, IT, ES, NL.
The streams Singapore 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 →Singapore-specific questions.
- Singapore has its own packaging EPR regime (Mandatory Packaging Reporting). Does it cover French obligations?
- No. Singapore’s Mandatory Packaging Reporting under the Resource Sustainability Act covers Singapore-sold packaging only. It has no extraterritorial effect on French EPR. Singapore companies shipping to France need independent French registration.
- I use a Singapore holding structure with a Hong Kong operating subsidiary. Who is the producer?
- Whichever entity invoices the French end customer (or its marketplace) and bears commercial title transfer. Usually the operating subsidiary. The holding company is rarely the producer for EPR unless it directly transacts.
- Can I pay in SGD?
- You can wire from a SGD account but we invoice in EUR and our books are in EUR. Your bank will convert on the wire; we receive EUR. The SGD-equivalent on our invoice is for your reference and reconciliation only.
- 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.