French EPR compliance,
for US-based sellers.
A US company that sells to French customers, through Amazon.fr, Pan-European FBA, a Shopify store shipping to France or a French reseller that does not import the goods itself, is the producer for French EPR. With no establishment in France, it must appoint a representative established in France. We are that representative, for French EPR only.
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 →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 →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 →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 →When does French EPR start for a company based in the United States?
The obligation starts with your first sale that places a product on the French market: the first Amazon.fr order fulfilled from French or other EU stock, the first Shopify parcel delivered to a French address, the first shipment to a French shop that buys from you without importing the goods itself. The state where the company is incorporated plays no part, and neither does where the goods were made.
Is a French representative compulsory for a company based in the United States?
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 a Delaware LLC change anything?
No. The only test is whether the company is established in France, so a Delaware, California or Wyoming LLC or corporation with no establishment in France must appoint a representative established in France.
The state of incorporation, the corporate form and the place of manufacture play no part. What matters is who sells to French customers and who owns the goods when they enter France.
Stock at a 3PL in the Netherlands or Germany, Pan-European FBA, Shopify shipping from the US: who is the producer in each case?
In all three cases the US company is the producer, because it still owns the goods when they enter France. The exception is a French buyer that buys the goods and imports them in its own name: that buyer is then the producer for those flows.
A 3PL in the Netherlands or Germany stores and ships your stock, it never buys it, so a parcel it sends to a French customer is your sale. Pan-European FBA moves your stock between Amazon fulfilment centres, French ones included, but you remain the owner until the customer buys. A Shopify store shipping from the US sells directly to the French consumer, and you own the goods until delivery. Packaging is always in scope; the product adds its own stream (textile, electrical equipment, furniture and so on).
Which US company documents do we need?
A certificate of good standing less than three months old from the state where the company is incorporated, the name and title of the signatory, your EIN and a bank document. We never ask for an identity document.
The signatory must be an officer named in the company records or hold a written delegation. The rest of the file is the closed list below, and everything runs in writing, in English or French.
Which sales channels bring sellers from the United States into French EPR?
US brands reach France mainly through Amazon.fr (with stock in French fulfilment centres or spread across the EU through Pan-European FBA), Shopify stores shipping from the US or from an EU 3PL, TikTok Shop, and French distributors or retailers. What matters for EPR is who owns the goods when they enter France, not where the warehouse is.
Typical profiles (illustrative)
- A US audio brand selling earbuds on Amazon.fr through Pan-European FBA (packaging, electrical equipment, batteries)
- A US activewear brand shipping Shopify orders to French addresses from a Dutch 3PL (packaging, textile)
- A US outdoor brand supplying French sports shops that buy and import the goods themselves (the shops are the producers)
- A US toy brand selling on Amazon.fr and TikTok Shop (packaging, toys, batteries if the toys contain them)
What happens if a seller from the United States is not registered in France?
Marketplaces selling to French customers must check that their sellers are registered (Article L. 541-10-9 of the French Environmental Code), and they ask sellers for the French identifier of each stream concerned. Penalties under Article L. 541-9-5 of the French Environmental Code reach up to €30,000 (no registration, inaccurate data, identifier not displayed), and up to €1,500 per unit or tonne for an individual or €7,500 per unit or tonne for a company. Eco-organisations can also claim contributions for sales made before you joined: we tell you before signing whether earlier years are at stake.
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 (≈ US$324)
- Annual fee
- €190 (≈ US$212)
- 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 (≈ US$324)
- Annual fee
- €350 (≈ US$391)
- Refundable deposit
- €110 (≈ US$123)
- 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 (≈ US$1,174) (packaging €290 + electronics €760)
- Annual fee
- €1,150 (≈ US$1,285) (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.
Equivalents are indicative, at the European Central Bank reference rate of 7 October 2026; invoices are issued and paid in euros.
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 the United States 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 →Toys
Required for any toy intended for use by children under 14, shipped to French consumers.
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 the United States ask before appointing a French representative?
- Does my US state registration or recycling programme cover France?
- No. US state packaging or electronics programmes cover sales in those states only. France has its own system: one membership per stream with a French eco-organisation and a unique identifier (IDU) per stream, filed through a representative established in France.
- I already have a German LUCID number. Does that work in France?
- No. LUCID covers German packaging only. France requires its own membership and identifier per stream (packaging, electrical equipment, batteries and so on), issued by the French eco-organisation you join.
- Does French EPR registration affect my US taxes or give me a French tax number?
- No. French EPR registration is environmental compliance, not tax, and we do not handle VAT, customs or tax filings. The eco-contribution is paid to an eco-organisation, not to the tax authorities.
- Do I need a French representative if I sell from the United States 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 the United States, 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 US company: a certificate of good standing less than three months old from the state of incorporation, the name and title of the signatory, your EIN as tax identifier 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.