French EPR from the United States.
The full playbook for US brands selling into France.
Seven minute read. Last updated 8 October 2026.
US brands selling into France through Amazon.fr, Shopify, TikTok Shop, or any direct channel are producers under French Extended Producer Responsibility law, with no establishment in France. The state of incorporation does not change this (Delaware, California, Wyoming alike): the test is establishment in France, and the producer is whoever owns the goods when they enter France.
This guide walks through the full registration sequence: what streams to register for, why you need a French authorized representative, how the IDU number you hear about works, and what it costs.
Step 1: Which French EPR streams apply to a US brand?
France has 19 EPR streams in total; about 10 of them are relevant to typical US e-commerce brands. The streams that catch most US sellers:
- Household packaging: every product shipped in a box, polybag, or container. Eco-organism: Citeo (default) or Léko. Stream page.
- WEEE: anything with a plug, battery, sensor, or electronic. Eco-organism: Ecosystem or Ecologic. Stream page.
- Batteries: standalone batteries OR batteries embedded in another product. Eco-organism: Ecosystem, which we register battery clients with. Stream page.
- Textile: apparel, household linen, footwear, even if shipped in 1-piece D2C orders. Eco-organism: Refashion. Stream page.
- Furniture: home and office furniture, mattresses, bedding. Eco-organism: Ecomaison (household) or Valdelia (professional). Stream page.
- Toys, sports, DIY: toys with Ecomaison; sports and leisure articles with Ecologic, the only approved eco-organisation (categories 1 and 2); DIY and garden with Ecomaison, Valobat or Ecologic. Toys, sports/DIY.
Most US sellers need 2 to 4 of these streams in combination. A typical Amazon FBA electronics brand needs packaging + WEEE + batteries (3 streams). A Shopify apparel brand needs textile + packaging (2 streams). The mapping is what our onboarding form figures out.
Step 2: Why do I need a French representative?
Because French law requires one. The basis is 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.
The representative signs the adherence contracts, obtains your IDU and files declarations, all in your name and on your behalf; the eco-contributions are set by the eco-organisms on their published barèmes, with no percentage taken by us. You remain the producer. Under the written mandate required by Article L. 541-10-9-1 of the French Environmental Code, we take charge of and answer for your registration, your identifier, your declarations, the exchanges with the eco-organisation and audits, and the archiving of your files. Your eco-contributions stay invoiced to you and paid by you directly to the eco-organisation. Read the EPR foundational guide for the legal architecture.
Step 3: The application sequence
- Apply through our get-registered form. Four short steps, about three minutes.
- Receive a written quote and scope within one business day.
- Sign the mandate online.
- We file your membership with each relevant eco-organisation within two business days of receiving payment.
- Receive your IDU number(s) from each eco-organisation. 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.
- Plug the IDU into Amazon Seller Central and other marketplace dashboards.
Step 4: What does French EPR cost a US seller?
Two cost layers:
- Representative fee: a fixed annual amount per stream, from €190/year excl. VAT, confirmed in a written quote within one business day, with a one-time setup per stream and a refundable deposit stated in the quote. Excludes VAT and eco-contributions. How our pricing works.
- Eco-contributions: set by each eco-organism on its published barème, from your declared volumes, and separate from our fee (we take no percentage on them). Scale varies widely by stream and material. Three typical year-one budgets, eco-contributions included, are on our US sellers page.
Common US-specific questions
Does my LLC structure matter? No. Delaware, California, Wyoming, single-member LLCs, C-corps: the only test is whether the company is established in France. The trigger is the product placement, not the corporate structure.
Do I need a French bank account? No. 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.
What if I already have German LUCID? LUCID covers Germany only. France has its own system. No reciprocity. Read about Citeo here.
What if Amazon already suspended me? Apply with “already suspended” status. Listings can be reinstated once your identifier is in place, and the identifier timing depends on the eco-organisation (about seven business days after the membership is validated at Citeo). Detailed recovery playbook here.
Bottom line
US to France EPR is administratively simpler than most US sellers fear. The substantive work is done by your representative. What you provide is product data (categories, materials, weights, volumes) and the mandate signature. Everything else, including the IDU, runs through us. At Citeo the identifier follows about seven business days after the membership is validated.
For a deeper look at country-specific specifics, see our US sellers page. For PPWR Article 45, in force since 12 August 2026, see the PPWR guide.
Frequently asked questions
Does my state of incorporation change my French EPR obligation?
No. Delaware, California, Wyoming, single-member LLCs or C-corps are all treated identically for French EPR: the only test is whether the company is established in France. The producer is whoever owns the goods when they enter France, whatever the corporate structure or the state of incorporation.
Can a US company register directly with a French eco-organism?
No. Since 10 July 2026, any producer not established in France and subject to EPR 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, created by Law No. 2026-602 of 8 July 2026). You remain the producer; the representative takes charge of and answers for your registration, your identifier, your declarations, the exchanges with the eco-organisation and audits, and the archiving of your files.
How many EPR streams does a typical US e-commerce brand need?
Most US sellers need 2 to 4 of the 19 French EPR streams. A typical Amazon FBA electronics brand needs packaging, WEEE and batteries; a Shopify apparel brand needs textile and packaging. The exact mapping depends on materials and product categories, which our onboarding form determines.
Do I need a French bank account to pay a French representative?
No. 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. No French banking relationship is required to appoint a representative or pay the eco-organisation.
How long from signing the mandate to a working IDU for a US seller?
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 with each eco-organisation within two business days of receiving payment, all streams in parallel. A written quote arrives within one business day of applying, and the mandate is signed online.