French EPR by country of origin.
US, UK, China, Switzerland, Norway and beyond.
Quick answer. The French EPR regime treats every producer without a French establishment the same, including UK (post-Brexit), Switzerland, Norway, Iceland, Liechtenstein, US, Canada, China, Hong Kong, Australia, and EU markets such as Germany, Spain, Italy and Ireland. There is no EFTA/EEA exemption and no EU exemption. Since 10 July 2026, Article L. 541-10-9-1 of the French Environment Code (law n° 2026-602 of 8 July 2026) makes the appointment of a France-established authorized representative compulsory for each of them, by written mandate, across all 19 French EPR streams. The operational specifics that vary are: which documents your jurisdiction requires (business licence, certificate of incorporation, etc.), how marketplace enforcement hits sellers from your country, and who owns the goods when they enter France on each channel. For the statute itself, see our breakdown of law n° 2026-602; for the broader EU and global context, our complete EPR compliance guide.
Not sure which streams apply or what it costs?
The entry price is public: from €190/year excl. VAT per EPR stream. Tell us your streams, volumes and product references, and you receive a fixed written quote within one business day, before any commitment. Eco-contributions are set by the eco-organisms on their published schedules and stay separate from our fee: we take no percentage on them.
Country-specific guides
What is the same whatever my country?
The legal obligation, the streams, the identifier and the penalties. Only the paperwork and the tax set-up around EPR differ from one country to another.
- The producer concept under Article L. 541-10 II.
- The need for a France-established representative.
- The list of EPR streams applicable to your catalog.
- The IDU timing, set by each eco-organisation (about seven business days after the membership is validated at Citeo).
- The eco-contribution rate per material.
- The penalty exposure: up to €30,000, and up to €1,500 (individual) or €7,500 (company) per unit or tonne, Article L. 541-9-5.
What changes with my country of origin?
The company documents, their translation and who owns the goods when they enter France on each sales channel. None of these changes the French obligation itself.
- Documents: US certificate of good standing, UK Companies House extract, Chinese business licence (营业执照), Hong Kong Business Registration Certificate, Japanese 登記簿謄本, Korean 등기사항전부증명서, each less than three months old.
- Translation: documents in a language other than English or French need an English or French translation (Chinese, Korean, Japanese in particular).
- Sales channels: the producer is whoever owns the goods when they enter France, so a distributor that buys and imports in its own name is the producer for those flows, while your direct sales stay yours.
- PPWR Article 45: in force since 12 August 2026, it requires producers making packaging available in an EU Member State where they are not established, including EU producers, to appoint a representative there. See our PPWR Article 45 deep-dive.
Which mistakes do foreign producers make most?
Frequently asked questions
My company is in Ireland, am I considered EU or non-EU for French EPR purposes?
The EU/non-EU distinction stopped being the operative one on 10 July 2026. Article L. 541-10-9-1 of the French Environment Code, created by law n° 2026-602 of 8 July 2026, requires any producer not established in France and subject to EPR to appoint a representative established in France, for every stream, by written mandate. Irish establishment is EU establishment, but it is not French establishment, so an Irish company selling into France is covered on exactly the same terms as a US or Chinese one. Appointing a representative is not one option among several for a producer with no French establishment: it is the statutory requirement.
Does Brexit change anything for a UK company under French EPR?
Not the test. Since 1 January 2021 UK and EU rules run separately, but French law only asks whether the producer is established in France. A UK Ltd with no French establishment must designate a representative established in France, like a US LLC, a Hong Kong company or an Irish one.
I am a Swiss company. EFTA membership does not exempt me?
No. Switzerland, Norway, Iceland and Liechtenstein are EFTA and (except Switzerland) EEA, but neither status exempts from French EPR, and neither do the EU-Swiss bilateral agreements. A Swiss SA or Norwegian AS shipping to French consumers has no establishment in France and designates a representative established in France.
My Chinese factory ships under FOB terms, am I the producer?
It depends on who owns the goods when they enter France. If your French buyer buys the goods at the port of loading (Shenzhen, Shanghai) and imports them in its own name, it is the producer. If you ship D2C to French consumers via Amazon FBA or a fulfilment service, you still own the goods when they enter France and you are the producer. The Incoterm alone does not decide; ownership does.
I am a Canadian brand selling via my US Amazon entity into FR, who registers?
The entity that owns the goods when they enter France. If your US entity sells to French customers and owns the goods until then, the US entity registers, even if a Canadian parent owns the brand.
Do I need to translate my business registration certificate?
Documents in a language other than English or French need an English or French translation (Chinese, Japanese and Korean registry extracts in particular). The register extract must be less than three months old, and we never ask for an identity document.
Long-form guides
Whichever country you are based in, send your situation to our contact form for a written quote within one business day. Fixed annual fee per stream, from €190/year excl. VAT: how our pricing works.
Get your fixed quote in one business day
The entry price is public: from €190/year excl. VAT per EPR stream. Tell us your streams, volumes and product references, and you receive a fixed written quote within one business day, before any commitment. Eco-contributions are set by the eco-organisms on their published schedules and stay separate from our fee: we take no percentage on them.