French EPR compliance,
for producers in Singapore.
Singapore companies often act as the regional hub for goods made elsewhere in Asia. When the Singapore company is the seller to French customers, it is the producer for French EPR, whatever the country of manufacture, and with no establishment in France it must appoint a representative established in France.
What brings producers to us
I need to be compliant in France, fast.
A written quote within one business day, a mandate signed online and your membership filed within two business days of payment. Then the identifier comes on each eco-organisation’s real timing, which we state upfront.
What happens after you sign →Nobody on my team understands French EPR.
You hand the whole obligation to a specialist established in France: 19 streams, several eco-organisations each, scales that change every year. You send your sales data; we qualify your streams, choose the eco-organisation, file the membership and the declarations, handle audits and keep the archive.
How the mandate works →I want an expert, not a form.
A team that does French EPR only, in English and French, in writing, qualifies each product before registration: the right stream, eco-organisation and category. We take charge of, and answer for, your registration and your declarations.
Who you deal with →A marketplace asks for my French EPR number, or has suspended my listings.
It wants the unique identifier (IDU) of each stream, issued after membership of an approved eco-organisation; since 10 July 2026 a seller not established in France needs a representative established in France to get it. A marketplace that takes on EPR for you covers only what it sells for you, and only until you register yourself.
The marketplace EPR number, step by step →I’m afraid of fines and of getting it wrong.
Up to €30,000, and up to €7,500 per unit or tonne for a company or €1,500 for an individual (Article L. 541-9-5), from the first unit sold: there is no threshold. A UK or German registration does not cover France, and some eco-organisations backdate membership; we tell you before you sign.
Penalties explained →I want to know the full cost upfront.
From €190/year excl. VAT per stream, then a fixed fee stated in writing in your quote. Three typical year-one budgets are published, and we take no percentage on eco-contributions.
Year-one budgets →How do companies from Singapore end up subject to French EPR?
Singapore companies sell into France as brand owners shipping D2C or through Amazon.fr, and as hubs supplying French distributors. The French producer is the entity that sells to the French customer: often the Singapore company, sometimes a French importer that buys the goods and imports them in its own name.
Is a French representative compulsory for a company based in Singapore?
Yes, for any company with no establishment in France that places products subject to EPR on the French market. A written mandate under Article L. 541-10-9-1 of the French Environmental Code, created by Law No. 2026-602 of 8 July 2026. Since 10 July 2026, any producer not established in France and subject to EPR must appoint a representative established in France, for every stream. For packaging, Article 45 of Regulation (EU) 2025/40 (PPWR) adds the same requirement at EU level.
We take charge of, and answer for, your registration, your identifier, your declarations, the exchanges with the eco-organisation and audits. You remain the producer and pay your eco-contributions directly to the eco-organisation.
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 conditions of the mandate and the regularisation path.
Does Singapore’s Mandatory Packaging Reporting cover French obligations?
No. Mandatory Packaging Reporting under Singapore’s Resource Sustainability Act concerns packaging placed on the Singapore market.
It has no effect in France, where household packaging is registered with Citeo or Léko and declared to them.
Amazon.fr, your own store or a French distributor: who is the producer for each channel?
The producer is whoever owns the goods when they enter France. On Amazon.fr and on your own store shipping to French addresses, that is the Singapore company; with a French distributor that buys the goods and imports them in its own name, it is the distributor.
Stock held for you by a 3PL or by Amazon stays yours, wherever the warehouse is. If the goods are made in Vietnam or China and sold by the Singapore company, the country of manufacture plays no part: the upstream factory that sells to the Singapore hub is not the French producer.
Does the EU-Singapore trade agreement change EPR?
No. The EU-Singapore Free Trade Agreement, in force since 21 November 2019, deals with tariffs and trade rules.
French EPR is a French environmental obligation and applies in the same way to Singapore producers.
Which documents from Singapore does the file need?
An ACRA business profile (Bizfile) less than three months old listing the officers, your UEN, the name of the officer who signs (or a written delegation) and a bank document. The documents are usually already in English, and we never ask for an identity document.
- Company register
- ACRA business profile (Bizfile), which lists the company’s officers. A recent digital copy is the usual format.
- Registration and tax numbers
- UEN (Unique Entity Number), and the GST registration number if the company has one.
- Invoicing and payment
- Our invoices are issued and paid in euros, by bank transfer. The refundable security deposit is paid by a separate bank transfer to our dedicated account. Your eco-contributions stay invoiced to you and paid by you directly to the eco-organisation. We do not handle VAT, customs or tax questions.
What a business like yours pays in year one
From €190/year excl. VAT, per stream.
Already registered with a French eco-organisation, household packaging: you prepare your declarations, we check and file them
- Setup, once
- €290
- Annual fee
- €190
- Refundable deposit
- equal to the eco-organisation’s annual minimum (€110 at Citeo or Léko in 2027)
- Eco-contribution, paid to the eco-organisation
- from €110 a year
Risk of doing nothing: A missing or inaccurate declaration: up to €30,000, and up to €7,500 per unit or tonne for a company (€1,500 for an individual), Article L. 541-9-5 of the French Environmental Code.
New brand, household packaging, small volume: we prepare and file
- Setup, once
- €290
- Annual fee
- €350
- Refundable deposit
- €110
- Eco-contribution, paid to the eco-organisation
- €110 a year at Citeo below 10,000 units in 2027
Risk of doing nothing: Selling without registration or without displaying your identifier: up to €30,000 (Article L. 541-9-5). Packaging without Info-tri: up to €15,000 per reference for a company (€3,000 for an individual), Article L. 541-9-4.
Marketplace seller, household packaging and electronics: we prepare and file
- Setup, once
- €1,050 (packaging €290 + electronics €760)
- Annual fee
- €1,150 (packaging €450 + electronics €700, electronics on annual declaration with direct debit at Ecosystem)
- Refundable deposit
- about one year of estimated eco-contributions (minimum €110 + €200)
- Eco-contribution, paid to the eco-organisation
- per the eco-organisations’ published scales
Risk of doing nothing: Listings blocked by the marketplace without an identifier for each stream, and for each stream the penalties of Article L. 541-9-5: up to €30,000, and up to €7,500 per unit or tonne for a company.
Your quote is fixed in writing within one business day. Eco-contributions are invoiced to you directly by the eco-organisation; we take no percentage on them.
What happens after you sign
- 1
Written quote within one business day
You describe your products, channels and volumes. We qualify each product (stream, eco-organisation, category) and send a fixed written quote.
- 2
Mandate signed online
You sign the written mandate required by Article L. 541-10-9-1 of the French Environmental Code. One mandate covers all your French streams.
- 3
Invoice and deposit
We invoice the setup and the declaration campaign, payable by bank transfer in euros. The refundable security deposit is paid by a separate bank transfer in euros to our dedicated account.
- 4
Membership within two business days
We file your membership or designation with each eco-organisation within two business days of receiving payment.
- 5
Your identifier
The identifier (IDU) is issued on the eco-organisation’s own timing, listed below.
Our invoices are issued and paid in euros, by bank transfer. The refundable security deposit is paid by a separate bank transfer to our dedicated account.
When your identifier is issued
- Citeo (household packaging): about seven business days after the membership is validated.
- Léko (household packaging): about five business days after the initial Léko invoice is paid; that invoice must be paid within five business days, otherwise the membership is cancelled.
- Ecosystem (electronics, batteries): the identifier is issued after the first declaration has been filed and paid.
- Refashion (textiles, footwear): after membership, the signed contract and the first declaration with its payment, then about ten business days.
- Professional packaging (EPRO: Citeo Pro, Léko Pro, Twiice): registration open now, eco-contributions from 1 January 2027.
Documents we ask for
A closed list, the same as a membership without a representative:
- Exact company name and registered address
- Registration number and tax identifier
- Company register extract less than three months old
- Name and position of the signatory, and proof of authority (the extract or a written delegation)
- Product scope
- Volumes per stream, and for the three previous years if you already sell in France
- Date of your first sale in France
- Sales channels and customers
- Who imports the goods and who owns them when they enter France
- Identifiers and memberships you already hold
- Billing contact, and phone numbers with international prefix for the contact and the signatory
- Acceptance of the deposit
- A bank document
We never ask for an identity document.
We work in English and French, in writing, and reply within one business day (Paris time).
Who handles your file, and where does your money go?
Your file is handled in writing, in English or French, by a team established in Paris that does French EPR only. Read who you deal with, starting with our founder, Leo Escourrou.
Our fee is fixed per stream in the written quote. The refundable security deposit sits on a dedicated bank account, separate from our operating account, and your eco-contributions are invoiced to you directly by the eco-organisation, with no percentage for us. See how we handle your money.
Which French EPR streams do sellers from Singapore most often trigger?
The streams below follow the products this market typically sells into France. One representative and one written mandate cover all of them, each stream with its own membership, identifier and declarations.
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 →Portable batteries and accumulators
Required for standalone portable batteries, plus rechargeable cells embedded in any device.
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 →Sports, DIY and garden articles
Required for sports equipment, hand tools, garden articles, and DIY products shipped to French consumers.
Stream details →EPR representative or EU authorised representative? Not the same role: an EU authorised representative or responsible person answers for product compliance (CE marking, product safety), while a French EPR representative answers for registration, identifiers and declarations with the eco-organisations. We act for French EPR only.
What do companies from Singapore ask before appointing a French representative?
- Does my Singapore packaging reporting cover France?
- No. Singapore’s reporting covers packaging placed on the Singapore market. France requires its own membership and identifier per stream with a French eco-organisation.
- I use a Singapore holding with a Hong Kong operating subsidiary. Who is the producer?
- The entity that sells to the French customer or marketplace and transfers title to the goods, usually the operating subsidiary. A holding company is the producer only if it sells into France itself.
- Do I need a French representative if I sell from Singapore through Amazon or another marketplace?
- If a marketplace takes on the EPR obligation for your products under Article L. 541-10-9 of the French Environmental Code, it covers only the products it sells for you, and only while you are not registered yourself. Your own website, other marketplaces and your sales to businesses stay your obligation. A producer with no establishment in France registers through a representative established in France, whatever the sales channel.
- Who is the producer if I ship from my own warehouse, from a 3PL in France or through FBA?
- The producer is whoever owns the goods when they enter France: not the brand as such, not the Incoterm, not whoever clears customs. Shipping from your own warehouse in Singapore, from a 3PL or through Amazon FBA does not move the obligation to the logistics provider, which holds your goods without buying them. If a French buyer buys the goods and imports them in its own name, that buyer is the producer.
- What documents do you need?
- For a Singapore company: an ACRA business profile less than three months old listing the officers, your UEN and a bank document. In every case, a closed list: exact company name and registered address; registration number and tax identifier; company register extract less than three months old; name and position of the signatory, and proof of authority (the extract or a written delegation); product scope; volumes per stream, and for the three previous years if you already sell in France; date of your first sale in France; sales channels and customers; who imports the goods and who owns them when they enter France; identifiers and memberships you already hold; billing contact, and phone numbers with international prefix for the contact and the signatory; acceptance of the deposit; a bank document. We never ask for an identity document. These are the same documents as a membership without a representative.
- How long until I can sell?
- The identifier timing depends on the eco-organisation. Citeo (household packaging): about seven business days after the membership is validated. Léko (household packaging): about five business days after the initial Léko invoice is paid; that invoice must be paid within five business days, otherwise the membership is cancelled. Ecosystem (electronics, batteries): the identifier is issued after the first declaration has been filed and paid. Refashion (textiles, footwear): after membership, the signed contract and the first declaration with its payment, then about ten business days. Professional packaging (EPRO: Citeo Pro, Léko Pro, Twiice): registration open now, eco-contributions from 1 January 2027. We file your membership or designation with each eco-organisation within two business days of receiving payment.
- What does it cost?
- Our fee starts from €190/year excl. VAT per stream. Your annual fee is a fixed amount per stream and per calendar year, independent of your eco-contributions. It depends on the declaration regime and frequency, the number of references and, above EUR 1,000 of eco-contribution per stream, its size. A one-time setup per stream and a refundable security deposit are stated in a written quote sent within one business day. Three typical year-one budgets are published on this page and on our pricing page. Your eco-contributions stay invoiced to you and paid by you directly to the eco-organisation; we take no percentage on them.