French EPR compliance,
for producers in Turkey.
Turkey is a non-EU jurisdiction for French EPR. A Turkish Anonim Şirketi (A.Ş.) or Limited Şirketi (Ltd. Şti.) shipping packaged consumer goods to French addresses must designate a France-established mandataire REP. Our workflow is set up for Turkish textile, ceramics, food and consumer goods exporters who are highly active in France.
Why Turkey exporters end up here.
Turkey is one of the largest non-EU suppliers to France, particularly in textile, ceramics, food, and home goods. Turkish exporters increasingly bypass French distributor middlemen and sell direct via Amazon France, Cdiscount, ManoMano. French EPR applies the moment they go direct.
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 Turkey-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
- Ticaret Sicil Gazetesi (Turkish Trade Registry Gazette) excerpt or Ticaret Sicil Belgesi (trade registry certificate). Original Turkish + English translation accepted.
- Tax identifier
- Vergi Numarası (10-digit Turkish tax identification number). Optional: KDV registration number if VAT-registered.
- Invoicing & currency
- We invoice in EUR. Turkish A.Ş. and Ltd. Şti. companies receive in TRY via international wire. Turkish KDV does not apply to our service (B2B export of services). No French VAT applies.
What Turkey sellers need to watch.
EU-Turkey Customs Union context
Turkey is in the EU Customs Union (since 1995), most industrial goods cross EU borders duty-free. This does NOT affect EPR, Turkey is still non-EU for environmental regulation purposes. French EPR fully applies.
Turkish-language document translation
Eco-organisms accept Turkish documents with English translation. We coordinate professional translation.
Refashion (textile) for Turkish apparel exporters
Turkey is the second-largest non-EU textile supplier to France after China. Turkish apparel and home textile exporters going direct to French consumers (Amazon FR, Shopify) fall under Refashion EPR for textile + Citeo/Léko/Adelphe for packaging.
The streams Turkey 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 →Turkey-specific questions.
- I export to a French wholesaler who then sells onward. Do I need EPR?
- Usually no. If the French wholesaler takes title and is the importer of record, they are the French producer. You are an exporter to a French buyer, not a producer for French EPR purposes. Confirm with the contract.
- My Turkish company supplies private-label products to French brands. Same answer?
- Same logic. The French brand owner who places the products on the market under their brand name is typically the producer, not the Turkish OEM manufacturer.
- Customs Union means no customs declaration. Does this affect EPR documentation?
- No. EPR registration is independent of customs documentation. Even without customs declarations, the producer obligation triggers on first placing on the market.
- 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.