US state EPR laws and French EPR.
Two separate systems, and what France asks of a US brand.
Last updated . US state facts checked on the state agencies' pages on 28 October 2026.
Several US states have passed packaging EPR laws, and many US brands discover the concept through them. If you also sell into France, through Amazon.fr, a Shopify store shipping to French addresses or TikTok Shop, French EPR applies on top, under its own rules. This page compares the two and lists what France asks of a US brand.
What the US state laws cover
Two examples, as published by the state agencies (checked on 28 October 2026):
- Oregon: the Plastic Pollution and Recycling Modernization Act (SB 582, 2021) became effective on 1 January 2022, and the recycling program changes started in July 2025. Producers of packaged items, paper products and food serviceware pay for many of the system improvements.
- California: SB 54, the Plastic Pollution Prevention and Packaging Producer Responsibility Act, was signed on 30 June 2022. Its permanent regulations were approved on 1 May 2026, and the law sets 2032 goals for single-use packaging and plastic food service ware.
Other states have adopted their own laws, each with its own scope, thresholds and calendar: check with the environmental agency of each state you sell into. We do not act in the United States.
US state EPR and French EPR, side by side
| Topic | US state packaging laws | French EPR |
|---|---|---|
| Territory | Each state law covers products sold into that state. | Covers every product placed on the French market, whatever the sales channel. |
| Products | Packaging and related materials: Oregon names packaged items, paper products and food serviceware; California covers single-use packaging and plastic food service ware. | 19 EPR streams: packaging, electrical equipment, batteries, textiles, furniture, toys and more. |
| Producer based abroad | Rules differ from state to state. | A producer not established in France appoints a representative established in France, by written mandate, for every stream (compulsory since 10 July 2026). |
| Identifier | Set by each state programme. | One unique identifier (IDU) per stream, checked by the marketplaces that sell to French customers. |
| Threshold | Varies by state. | None: the obligation starts with the first unit. |
What France asks of a US brand
- Map your streams. Packaging almost always, plus the product's own stream: electrical equipment, batteries, textiles, furniture, toys and so on. See the 19 streams.
- Appoint a representative established in France. Under the written mandate required by Article L. 541-10-9-1 of the French Environmental Code, we act as your representative established in France. 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. We also keep the archive of your files.
- Join one eco-organisation per stream and get your IDUs. 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.
- Declare. Most streams are declared once a year. Exceptions: Ecomaison declares quarterly by default (annual on option below 15 t, 1,000 pieces and EUR 2 million of turnover in the stream), Valdelia quarterly, Ecominéro monthly, and Ecosystem electrical equipment quarterly unless contributions are paid by SEPA direct debit.
Penalties in France: Up to EUR 30,000 for failing to register, inaccurate data or an identifier not displayed, and up to EUR 1,500 (individual) or EUR 7,500 (company) per unit or tonne, under Article L. 541-9-5 of the French Environmental Code. Missing Info-tri: up to EUR 3,000 (individual) or EUR 15,000 (company) per reference, under Article L. 541-9-4. The obligation starts with the first unit sold in France: there is no threshold.
More for US companies: French EPR for US sellers, the French IDU Amazon.fr asks for and the US D2C checklist.
Frequently asked questions
Does my US state EPR registration cover sales into France?
No. A US state packaging programme covers products sold into that state only. France runs its own system: one membership per EPR stream with a French eco-organisation and one unique identifier (IDU) per stream. Nothing registered in a US state carries over to France.
Can a US company register with a French eco-organisation on its own?
No. 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 and in force 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), in force since 12 August 2026, adds the same requirement at EU level.
Is there a small-business threshold in France, as in some US state laws?
No. In France the obligation starts with the first unit placed on the French market. The small-producer regimes some eco-organisations offer set how you declare and what you pay, not whether you are covered.
Which products does French EPR cover beyond packaging?
France has 19 EPR streams. Besides household and professional packaging, the ones that most often concern US brands are electrical and electronic equipment, batteries, textiles and footwear, furniture, toys, and sports, DIY and garden articles. A single product often falls under several streams, for example packaging, electrical equipment and batteries for a pair of wireless earbuds.
How long until a US brand has its French identifiers?
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 the signed mandate, the first invoice payment and the deposit.
Sources
- Oregon Department of Environmental Quality, Recycling Modernization Act (SB 582, 2021), checked on 28 October 2026
- CalRecycle, SB 54 Plastic Pollution Prevention and Packaging Producer Responsibility Act, checked on 28 October 2026
- Law No. 2026-602 of 8 July 2026 (JORF of 9 July 2026), Article L. 541-10-9-1 of the Code de l’environnement, in force 10 July 2026
- Articles L. 541-9-5 and L. 541-9-4 of the Code de l’environnement