You received an ADEME letter.
What it means and what to do in the next 30 days.

Three distinct French authorities issue EPR-related compliance letters, and the response differs significantly depending on which one you received. ADEME (Agence de la transition écologique) handles registry and IDU matters. DGCCRF (Direction générale de la concurrence, de la consommation et de la répression des fraudes) handles consumer-facing enforcement and is the body that issues actual fines. Eco-organisms (Citeo, Refashion, Ecosystem etc.) handle their own member compliance and can write to you about declarations or contributions.

Read the letterhead carefully. The legal basis cited at the top of the page tells you which regime you are in. Articles L. 541-10 and following = ADEME. Articles L. 511-1 and following of the Code de la consommation = DGCCRF. Eco-organism letters reference their internal accreditation or the AGEC law (Loi 2020-105 of 10 February 2020) without citing a specific Code article.

Is a mise en demeure already a fine?

No. It is a formal notice to comply within a deadline, which the authority must send before it can sanction you. Answer it properly and the case usually closes there.

The most common EPR enforcement letter is a mise en demeure, a formal notice to comply within a stated deadline. For EPR breaches, the competent authority demands compliance first and, failing that, imposes the administrative fines of Article L. 541-9-5 of the Code de l’environnement.

A mise en demeure is not yet a fine. It is a legal precondition: the authority is required to give you a chance to comply before sanctioning. If you respond adequately within the deadline, the case is typically closed with no further consequence. If you ignore the letter or your response is judged insufficient, the authority can move to sanction administrative, the actual fine, which can reach €30,000 (plus €7,500 per unit or per tonne of non-compliant product) under Article L. 541-9-5.

How long do I have to respond?

Most EPR mise en demeure letters give you 30 days from receipt to bring your situation in compliance and to provide evidence. The deadline runs from receipt (réception), not from the postmark date. If the letter was sent registered mail (lettre recommandée avec accusé de réception), and they almost all are, the receipt date is the day you or your agent signed for it.

Critical point for foreign sellers: if the letter is addressed to your French authorized representative and you only learn about it second-hand, the deadline still runs from the representative’s receipt date. Confirm with them immediately.

How do I respond to an ADEME letter?

In five steps: identify the breach, put a representative in place, file the missing memberships, answer in writing before the deadline, then send the identifiers once issued. Each step is detailed below.

Step 1, Identify exactly what they say you breached

The letter will state one of three breaches: (a) failure to register with an eco-organism for one or more streams, (b) failure to declare and pay eco-contributions, or (c) failure to provide an IDU to a marketplace operator who forwarded the case to ADEME. Match the alleged breach to your actual operations, authorities sometimes flag streams that do not apply to your products.

Step 2, Engage an authorized representative if you have not already

Since 10 July 2026, a producer not established in France must appoint a representative established in France, for every stream, under a written mandate (Article L. 541-10-9-1 of the Code de l’environnement). If the breach is “failure to register”, you cannot fix it without that mandate. See our services overview for the streams we cover.

Step 3, File the missing registrations

File with each relevant eco-organism. The identifier timing depends on the eco-organisation: Citeo issues it about seven business days after the membership is validated, Léko about five business days after its initial invoice is paid (payable within five business days, otherwise the membership is cancelled), Ecosystem after your first declaration has been filed and paid. We file your membership within two business days of receiving the signed mandate, the first invoice payment and the deposit.

Step 4, Draft a written response

Reply by registered mail before the deadline. Even if you do not yet have the IDU, send a response showing the steps you have taken: representative appointed, eco-organism dossier filed, expected publication date. Authorities respond well to good-faith engagement. The response should include:

• Reference to the case number in their letter
• Acknowledgment of the alleged breach
• Concrete remediation actions taken with dates
• Supporting evidence (mandate signature, eco-organism filing receipt)
• An expected IDU publication date (request a status from the eco-organism)
• A commitment to update the authority once the IDU is published

Step 5, Update once IDUs are issued

As each IDU is published on SYDEREP, send a follow-up to the authority with the IDU number. ADEME can verify it directly. Once all streams are covered, request written confirmation that the file is closed.

What happens if I ignore the letter?

The authority can move to an administrative fine once the deadline has passed. Ignoring a formal notice from the administration opens the door to the full sanction grid:

• Up to €30,000 under Article L. 541-9-5 (failure to register on SYDEREP, missing IDU display, or erroneous data, a single ceiling, not a per-SKU multiplier).
• €7,500 per unit or per tonne of non-compliant product placed on the French market for a legal entity (€1,500 per unit/tonne for an individual), accumulated on the volume in breach.
• Astreinte journalière, a daily penalty until you comply, typically €500 to €1,500 per day per breach.

Detailed exposure analysis with examples is in our penalties guide.

What NOT to do

• Do not ignore. A non-response is treated as an admission and accelerates the sanction.
• Do not respond in English only. French administrative procedure requires the response in French. An English-only reply may be deemed inadmissible.
• Do not pause your French sales as a defense. Stopping shipments does not retroactively fix the breach. You need the IDU.
• Do not negotiate the legal basis. EPR obligations are statutory. Arguing “we did not know” or “we are not really a producer” almost never succeeds for foreign sellers shipping to France.
• Do not respond without a representative. A producer not established in France cannot legally remediate without one.

How fast can it actually go?

The sequence from receipt to file-closed:

• Letter received: send it to us in writing, with the PDF attached.
• Mandate signed (electronic), first invoice and deposit received.
• Within two business days: membership filed with each eco-organisation.
• Acknowledgment letter sent to the authority with proof of filing.
• Identifier issued: about seven business days after the membership is validated at Citeo, after the first declaration has been filed and paid at Ecosystem.
• Follow-up to the authority with the IDU and a request for written confirmation that the file is closed.

If you would like us to handle the filings, see our pricing or request a written quote with the letter PDF attached: you get a fixed quote within one business day.

Frequently asked questions