# EPR Representative: hub pages in full France-established EPR authorized representative (mandataire REP) for producers with no establishment in France, EU or non-EU, across all 19 French EPR streams, France only. EPR Representative SASU, SIREN 108 686 874, VAT FR81108686874, 61 rue de Lyon, 75012 Paris, France. Founder: Léo Escourrou. Onboarding form: https://eprrepresentative.com/get-registered Generated from the site's data modules. Index: https://eprrepresentative.com/llms.txt. Facts last revised: 2026-10-08. --- URL: https://eprrepresentative.com/ Last updated: 2026-10-08 # Sell in France without becoming a French EPR expert We register you, obtain your identifiers and file your declarations, as your representative established in France. For companies with no French establishment, EU or non-EU, across 19 streams. From €190/year excl. VAT per stream; written quote within one business day. We work in English and French, in writing, and reply within one business day (Paris time). ## What we take charge of 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. ## Why a representative is required 1. The French legal obligation. 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. 2. Marketplace verification. Marketplaces check your unique identifier (IDU) for each stream. A marketplace that takes on EPR for your products under Article L. 541-10-9 covers only what it sells for you, and only until you register yourself: your own website, other marketplaces and sales to businesses remain your obligation. 3. PPWR Article 45, in force since 12 August 2026. In force since 12 August 2026, Article 45 of Regulation (EU) 2025/40 requires a producer that makes packaging available in a member state where it is not established, including from another EU country, to appoint an authorised representative for extended producer responsibility in that member state. ## Penalties 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. ## Eco-organisations We currently register clients with Citeo, Léko and Léko Pro, Ecosystem (electrical equipment, lamps, batteries), Twiice, Refashion, Ecomaison and Valobat. For the other approved eco-organisations, we confirm availability with your quote. ## How long registration takes We file your membership within two business days of receiving the signed mandate, the first invoice payment and the deposit. 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. Service starts once the mandate is signed and the first invoice and deposit are received. --- URL: https://eprrepresentative.com/pricing Last updated: 2026-10-08 # EPR France Pricing: from €190/year per Stream Published entry price: from €190/year excl. VAT per stream. Every other amount is set in a written quote within one business day. No percentage on eco-contributions or on eco-organisation membership fees. ## What the annual fee depends on 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. It is fixed in writing for the year and can only change for the following year, notified in writing by 15 September, or during the year if your scope changes, for example a new stream or a change of declaration regime. ## Security deposit A refundable security deposit equal to one year of your estimated eco-contributions, at least the eco-organisation's minimum billing, paid once by separate transfer to a dedicated account, never invoiced. It covers sums left unpaid under the mandate and is returned within sixty days of the end of the mandate, once the last contributions are paid. ## Calendar year Annual fees cover a calendar year without proration: signing in the second half of the year means the current year's campaign, then next year's a few months later. ## Review mode In review mode, you prepare your declaration and send it to us at least thirty days before the eco-organisation's deadline, with read access to your account; we check, validate and file it ourselves. If it has not reached us by then, we prepare it from your data and the year is billed at the full-service rate. ## Term of the mandate The mandate runs for the calendar year from 1 January and renews tacitly each year. Either party may end it by registered letter received by 30 September, effective 31 December. Annual fees cover a calendar year and are not prorated. We are bound by an obligation of means and are liable only for proven fault, capped at the higher of twelve months of fees or EUR 5,000. The signed mandate prevails over these terms. --- URL: https://eprrepresentative.com/faq Last updated: 2026-10-12 # French EPR: frequently asked questions ### How long does registration take? We file your membership within two business days of receiving the signed mandate, the first invoice payment and the deposit. 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. ### When is the identifier issued? 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. ### What are the penalties? 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. ### What do you take charge of, and what do I keep? 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. ### What is the legal basis of the mandate? 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. ### Which eco-organisations do you work with? We currently register clients with Citeo, Léko and Léko Pro, Ecosystem (electrical equipment, lamps, batteries), Twiice, Refashion, Ecomaison and Valobat. For the other approved eco-organisations, we confirm availability with your quote. ### How often do I 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. ### Can eco-organisations claim earlier years? Registration is due from your first sale in France, and eco-organisations can claim contributions for earlier years: up to five years at Refashion (the current year and four previous ones), three at Ecomaison, Ecosystem and Valobat, one at Citeo, none at Léko. Identifiers are never backdated. We tell you before signing whether earlier years are at stake. ### What does it cost? Published entry price: from €190/year excl. VAT per stream. Every other amount is set in a written quote within one business day. No percentage on eco-contributions or on eco-organisation membership fees. 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. It is fixed in writing for the year and can only change for the following year, notified in writing by 15 September, or during the year if your scope changes, for example a new stream or a change of declaration regime. ### Does the PPWR apply to EU sellers too? In force since 12 August 2026, Article 45 of Regulation (EU) 2025/40 requires a producer that makes packaging available in a member state where it is not established, including from another EU country, to appoint an authorised representative for extended producer responsibility in that member state. ### Does the Omnibus proposal change anything today? The European Commission's environmental Omnibus proposal is still in the legislative procedure and has no legal effect. The French obligation of Article L. 541-10-9-1 applies today. ### What about professional packaging? Packaging of products used only by professionals. A package also sold to households stays household packaging, even when a business buys it. Register now; contributions and identifiers start on 1 January 2027. --- URL: https://eprrepresentative.com/epr-authorized-representative Last updated: 2026-10-12 # EPR Authorized Representative France: Who Needs One ## Who needs one 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. In force since 12 August 2026, Article 45 of Regulation (EU) 2025/40 requires a producer that makes packaging available in a member state where it is not established, including from another EU country, to appoint an authorised representative for extended producer responsibility in that member state. ## What the mandate covers 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. ## Term of the mandate The mandate runs for the calendar year from 1 January and renews tacitly each year. Either party may end it by registered letter received by 30 September, effective 31 December. Annual fees cover a calendar year and are not prorated. We are bound by an obligation of means and are liable only for proven fault, capped at the higher of twelve months of fees or EUR 5,000. The signed mandate prevails over these terms. --- URL: https://eprrepresentative.com/services/packaging Last updated: 2026-10-08 # Household packaging: EPR in France Household packaging EPR in France is run by Citeo, Léko and Adelphe. A seller joins one of them, obtains its unique identifier (IDU) and declares once a year. Without a French establishment, appointing a representative established in France has been compulsory since 10 July 2026. EPR Representative fills that role, from €190 a year excl. VAT per stream. Required for any product sold to French consumers in packaging (boxes, polybags, fillers, bottles, jars). The household packaging stream is the largest EPR obligation in France. It applies to every primary, secondary and tertiary packaging shipped to a French consumer, including the outer carton, void fill, tape, labels and inserts. Citeo is the dominant eco-organism, with Léko and Adelphe as alternatives. 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. Approved eco-organisations: Citeo, Léko, Adelphe. ## Who must register Any producer or seller with no French establishment, inside the EU as well as outside it, placing packaged goods on the French market for the first time, including cross-border e-commerce and marketplace sellers. ## Products in scope (examples) - Cardboard shipper used to ship a consumer product to France - Glass jar containing cosmetics shipped from the US - Polybag holding a t-shirt sent from a UK warehouse - Tissue paper, void fill, branded inserts placed in the box ## Questions ### Who is liable for the Household packaging stream? The first company placing these products on the French market, with no revenue or volume threshold. Any producer or seller with no French establishment, inside the EU as well as outside it, placing packaged goods on the French market for the first time, including cross-border e-commerce and marketplace sellers. A producer with no French establishment must appoint a representative established in France, compulsory since 10 July 2026. ### Which products fall under the Household packaging stream? For example: cardboard shipper used to ship a consumer product to France; glass jar containing cosmetics shipped from the US; polybag holding a t-shirt sent from a UK warehouse; tissue paper, void fill, branded inserts placed in the box. Required for any product sold to French consumers in packaging (boxes, polybags, fillers, bottles, jars). ### Which eco-organism covers Household packaging? Citeo, Léko and Adelphe are state-accredited for this stream. Joining any one of them satisfies the obligation; they differ on the published schedule and the declaration format, not on the legal cover. Citeo issues the identifier 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). ### How often is the Household packaging stream declared? This stream is declared once a year. ### Is there a minimum charge for the Household packaging stream? 2026: Citeo €110 flat fee under 10,000 UVC; Léko €95 minimum, simplified declaration capped at €150 under 20,000 UVC. 2027: €110 minimum at both; Citeo €110 flat fee under 10,000 UVC; Léko simplified declaration capped at €180 under 10,000 UVC. ### What does the Household packaging stream cost? The eco-contribution follows the eco-organism's published schedule and depends on the volumes you declare, so it is specific to your catalogue. Our fee is separate: a published entry price of EUR 190 per year excluding VAT per stream, with the exact figure fixed in a written quote within one business day. --- URL: https://eprrepresentative.com/services/weee Last updated: 2026-10-08 # Electrical and electronic equipment (WEEE): EPR in France Electrical and electronic equipment (WEEE) EPR in France is run by Ecosystem, Ecologic and Soren. A seller joins one of them, obtains its unique identifier (IDU) and declares on the eco-organisation’s calendar. Typical products: bluetooth speakers, headphones, LED lamps. Without a French establishment, appointing a representative established in France has been compulsory since 10 July 2026. EPR Representative fills that role, from €190 a year excl. VAT per stream. Required for any product with a plug, battery, cable or electronic component sold to French consumers. The WEEE (waste electrical and electronic equipment) stream covers all product categories defined under French law: temperature exchange equipment, screens, lamps, large and small equipment, small IT/telecom equipment, and photovoltaic panels. Ecosystem and Ecologic share the general market, while Soren is the dedicated eco-organism for photovoltaic panels (category 7). Marketplaces are legally required to verify that third-party sellers have a valid IDU before listing products in scope. Approved eco-organisations: Ecosystem, Ecologic, Soren. ## Who must register Producers with no French establishment, EU or non-EU, selling electrical or electronic equipment to French consumers, including dropshipping and FBA sellers. ## Products in scope (examples) - Bluetooth speakers, headphones, LED lamps - Small kitchen appliances, hair dryers, electric toothbrushes - IoT devices, smart plugs, USB chargers - Anything containing a rechargeable cell ## Questions ### Who is liable for the Electrical and electronic equipment (WEEE) stream? The first company placing these products on the French market, with no revenue or volume threshold. Producers with no French establishment, EU or non-EU, selling electrical or electronic equipment to French consumers, including dropshipping and FBA sellers. A producer with no French establishment must appoint a representative established in France, compulsory since 10 July 2026. ### Which products fall under the Electrical and electronic equipment (WEEE) stream? For example: bluetooth speakers, headphones, LED lamps; small kitchen appliances, hair dryers, electric toothbrushes; ioT devices, smart plugs, USB chargers; anything containing a rechargeable cell. Required for any product with a plug, battery, cable or electronic component sold to French consumers. ### Which eco-organism covers Electrical and electronic equipment (WEEE)? Ecosystem, Ecologic and Soren are state-accredited for this stream. Joining any one of them satisfies the obligation; they differ on the published schedule and the declaration format, not on the legal cover. Ecosystem issues the identifier after your first declaration has been filed and paid. ### How often is the Electrical and electronic equipment (WEEE) stream declared? Electrical equipment is declared quarterly at Ecosystem unless contributions are paid by SEPA direct debit; the other eco-organisations of the stream set their own calendar. ### Is there a minimum charge for the Electrical and electronic equipment (WEEE) stream? ~€200/yr floor (Ecosystem). ### What does the Electrical and electronic equipment (WEEE) stream cost? The eco-contribution follows the eco-organism's published schedule and depends on the volumes you declare, so it is specific to your catalogue. Our fee is separate: a published entry price of EUR 190 per year excluding VAT per stream, with the exact figure fixed in a written quote within one business day. --- URL: https://eprrepresentative.com/services/textile Last updated: 2026-10-08 # Textile, household linen and footwear (TLC): EPR in France Textile, household linen and footwear (TLC) EPR in France is run by Refashion. A seller joins it, obtains its unique identifier (IDU) and declares once a year. Typical products: sneakers, boots, sandals. Without a French establishment, appointing a representative established in France has been compulsory since 10 July 2026. EPR Representative fills that role, from €190 a year excl. VAT per stream. Required for any apparel, linen or footwear product shipped to French consumers. France was the first EU country to enforce EPR for textile products, run by the single eco-organism Refashion (formerly Eco-TLC). The scope is broad: it covers clothing, household linen, footwear and most fashion accessories. Since 2023 the eco-modulation system penalizes ultra-fast-fashion and non-recyclable fibers with higher contributions. Approved eco-organisations: Refashion. ## Who must register Fashion brands and online apparel retailers with no French establishment, EU or non-EU, selling to French consumers. ## Products in scope (examples) - T-shirts, jeans, dresses shipped from a UK or US fashion brand - Sneakers, boots, sandals - Bed linen, towels, kitchen textiles - Bags, hats, scarves ## Questions ### Who is liable for the Textile, household linen and footwear (TLC) stream? The first company placing these products on the French market, with no revenue or volume threshold. Fashion brands and online apparel retailers with no French establishment, EU or non-EU, selling to French consumers. A producer with no French establishment must appoint a representative established in France, compulsory since 10 July 2026. ### Which products fall under the Textile, household linen and footwear (TLC) stream? For example: T-shirts, jeans, dresses shipped from a UK or US fashion brand; sneakers, boots, sandals; bed linen, towels, kitchen textiles; bags, hats, scarves. Required for any apparel, linen or footwear product shipped to French consumers. ### Which eco-organism covers Textile, household linen and footwear (TLC)? Refashion is state-accredited for this stream. Joining it satisfies the obligation; it varies on the published schedule and the declaration format, not on the legal cover. Refashion issues the identifier after membership, the signed contract and your first declaration and payment, then about ten business days. ### How often is the Textile, household linen and footwear (TLC) stream declared? This stream is declared once a year. Registration is due from your first sale in France, and eco-organisations can claim contributions for earlier years: up to five years at Refashion (the current year and four previous ones), three at Ecomaison, Ecosystem and Valobat, one at Citeo, none at Léko. Identifiers are never backdated. We tell you before signing whether earlier years are at stake. ### Is there a minimum charge for the Textile, household linen and footwear (TLC) stream? Refashion's simplified regime is billed per piece at a higher rate (about EUR 0.58 per clothing item in 2026) and is reserved for fewer than 5,000 pieces a year with no eco-modulated product; the detailed regime is usually far cheaper per piece. ### What does the Textile, household linen and footwear (TLC) stream cost? The eco-contribution follows the eco-organism's published schedule and depends on the volumes you declare, so it is specific to your catalogue. Our fee is separate: a published entry price of EUR 190 per year excluding VAT per stream, with the exact figure fixed in a written quote within one business day. --- URL: https://eprrepresentative.com/services/furniture Last updated: 2026-10-08 # Furniture (DEA): EPR in France Furniture (DEA) EPR in France is run by Ecomaison, Valdelia and Valobat. A seller joins one of them, obtains its unique identifier (IDU) and declares quarterly by default. Without a French establishment, appointing a representative established in France has been compulsory since 10 July 2026. EPR Representative fills that role, from €190 a year excl. VAT per stream. Required for any item of furniture, mattress or bedding shipped to French consumers, plus most home decor. The EA / DEA stream (éléments d ameublement) covers domestic and professional furniture, mattresses, sofas, chairs, bedding, tables, storage units, and most loose home decor with a structural function. Three eco-organisms are approved: Ecomaison (mostly domestic), Valdelia (mostly professional) and Valobat. The scope was widened in 2023 to capture additional categories. Ecomaison declares quarterly by default (annual on option below 15 t, 1,000 pieces and EUR 2 million of turnover in the stream) and Valdelia quarterly. Ecomaison charges a EUR 50 membership fee per stream, payable within five business days of signing. Approved eco-organisations: Ecomaison, Valdelia, Valobat. ## Who must register Furniture and home brands with no French establishment, EU or non-EU, shipping or fulfilling into France. ## Products in scope (examples) - Flat-pack furniture, bookcases, desks, beds - Mattresses, sofas, armchairs - Office furniture sold B2B - Garden furniture, outdoor seating ## Questions ### Who is liable for the Furniture (DEA) stream? The first company placing these products on the French market, with no revenue or volume threshold. Furniture and home brands with no French establishment, EU or non-EU, shipping or fulfilling into France. A producer with no French establishment must appoint a representative established in France, compulsory since 10 July 2026. ### Which products fall under the Furniture (DEA) stream? For example: flat-pack furniture, bookcases, desks, beds; mattresses, sofas, armchairs; office furniture sold B2B; garden furniture, outdoor seating. Required for any item of furniture, mattress or bedding shipped to French consumers, plus most home decor. ### Which eco-organism covers Furniture (DEA)? Ecomaison, Valdelia and Valobat are state-accredited for this stream. Joining any one of them satisfies the obligation; they differ on the published schedule and the declaration format, not on the legal cover. ### How often is the Furniture (DEA) stream declared? Ecomaison declares quarterly by default (annual on option below 15 t, 1,000 pieces and EUR 2 million of turnover in the stream); Valdelia declares quarterly. ### Is there a minimum charge for the Furniture (DEA) stream? Small-producer flat-rate regime below 15 t, 1,000 pieces and EUR 2 million of turnover in the stream (cumulative criteria). ### What does the Furniture (DEA) stream cost? The eco-contribution follows the eco-organism's published schedule and depends on the volumes you declare, so it is specific to your catalogue. Our fee is separate: a published entry price of EUR 190 per year excluding VAT per stream, with the exact figure fixed in a written quote within one business day. --- URL: https://eprrepresentative.com/services/batteries Last updated: 2026-10-08 # Portable batteries and accumulators: EPR in France Portable batteries and accumulators EPR in France is run by Ecosystem and Batribox. A seller joins one of them, obtains its unique identifier (IDU) and declares once a year. Typical products: loose AA, AAA, lithium button cells. Without a French establishment, appointing a representative established in France has been compulsory since 10 July 2026. EPR Representative fills that role, from €190 a year excl. VAT per stream. Required for standalone portable batteries, plus rechargeable cells embedded in any device. The battery stream (BAT) covers portable, automotive and industrial batteries. For foreign e-commerce sellers, the relevant categories are portable batteries (AA, AAA, button cells, 18650) and the cells embedded inside consumer electronics. Two eco-organisms are approved for 2026 under the arrêté of 27 March 2025: Ecosystem (ex-Corepile) and Batribox (ex-Screlec); vehicle batteries (category 5) go to Recycler Mon Véhicule. We register battery clients with Ecosystem. A battery-powered product triggers both the WEEE and the battery stream. Approved eco-organisations: Ecosystem, Batribox. ## Who must register Foreign sellers placing batteries (standalone or embedded) on the French market. ## Products in scope (examples) - Loose AA, AAA, lithium button cells - Power banks, USB rechargeable lamps - Bluetooth devices with embedded LiPo cells ## Questions ### Who is liable for the Portable batteries and accumulators stream? The first company placing these products on the French market, with no revenue or volume threshold. Foreign sellers placing batteries (standalone or embedded) on the French market. A producer with no French establishment must appoint a representative established in France, compulsory since 10 July 2026. ### Which products fall under the Portable batteries and accumulators stream? For example: loose AA, AAA, lithium button cells; power banks, USB rechargeable lamps; bluetooth devices with embedded LiPo cells. Required for standalone portable batteries, plus rechargeable cells embedded in any device. ### Which eco-organism covers Portable batteries and accumulators? Ecosystem and Batribox are state-accredited for this stream. Joining any one of them satisfies the obligation; they differ on the published schedule and the declaration format, not on the legal cover. Ecosystem issues the identifier after your first declaration has been filed and paid. ### How often is the Portable batteries and accumulators stream declared? This stream is declared once a year. ### Is there a minimum charge for the Portable batteries and accumulators stream? €200 excl. VAT per category, per year. ### What does the Portable batteries and accumulators stream cost? The eco-contribution follows the eco-organism's published schedule and depends on the volumes you declare, so it is specific to your catalogue. Our fee is separate: a published entry price of EUR 190 per year excluding VAT per stream, with the exact figure fixed in a written quote within one business day. --- URL: https://eprrepresentative.com/services/toys Last updated: 2026-10-08 # Toys: EPR in France Toys EPR in France is run by Ecomaison. A seller joins it, obtains its unique identifier (IDU) and declares quarterly by default. Without a French establishment, appointing a representative established in France has been compulsory since 10 July 2026. EPR Representative fills that role, from €190 a year excl. VAT per stream. Required for any toy intended for use by children under 14, shipped to French consumers. The toy stream is one of the more recent French EPR obligations, added in 2022. Ecomaison is the agreed eco-organism. Many toys also contain electronics or batteries, which means they may simultaneously fall under WEEE and battery streams. Approved eco-organisations: Ecomaison. ## Who must register Toy brands and importers with no French establishment, EU or non-EU, selling to French consumers. ## Products in scope (examples) - Plush toys, board games, building bricks - Electronic toys (subject to WEEE as well) - Outdoor toys, ride-on toys ## Questions ### Who is liable for the Toys stream? The first company placing these products on the French market, with no revenue or volume threshold. Toy brands and importers with no French establishment, EU or non-EU, selling to French consumers. A producer with no French establishment must appoint a representative established in France, compulsory since 10 July 2026. ### Which products fall under the Toys stream? For example: plush toys, board games, building bricks; electronic toys (subject to WEEE as well); outdoor toys, ride-on toys. Required for any toy intended for use by children under 14, shipped to French consumers. ### Which eco-organism covers Toys? Ecomaison is state-accredited for this stream. Joining it satisfies the obligation; it varies on the published schedule and the declaration format, not on the legal cover. ### How often is the Toys stream declared? Ecomaison declares quarterly by default (annual on option below 15 t, 1,000 pieces and EUR 2 million of turnover in the stream). ### Is there a minimum charge for the Toys stream? Small-producer forfait €22 per 100 pieces/yr. ### What does the Toys stream cost? The eco-contribution follows the eco-organism's published schedule and depends on the volumes you declare, so it is specific to your catalogue. Our fee is separate: a published entry price of EUR 190 per year excluding VAT per stream, with the exact figure fixed in a written quote within one business day. --- URL: https://eprrepresentative.com/services/sports-diy Last updated: 2026-10-08 # Sports, DIY and garden articles: EPR in France Sports, DIY and garden articles EPR in France is run by Ecologic, Ecomaison and Valobat. A seller joins one of them, obtains its unique identifier (IDU) and declares on the eco-organisation’s calendar. Without a French establishment, appointing a representative established in France has been compulsory since 10 July 2026. EPR Representative fills that role, from €190 a year excl. VAT per stream. Required for sports equipment, hand tools, garden articles, and DIY products shipped to French consumers. A relatively new EPR family consolidating two official streams: sports and leisure articles (ASL: rackets, bikes, fitness gear), where Ecologic is the only approved eco-organisation (categories 1 and 2), and DIY and garden articles (ABJ: hand tools, planters, hoses), where Ecologic (thermal equipment), Ecomaison and Valobat are approved. Ecomaison does not cover sports goods. Approved eco-organisations: Ecologic, Ecomaison, Valobat. ## Who must register Brands with no French establishment, EU or non-EU, in sports, DIY or garden categories selling to France. ## Products in scope (examples) - Yoga mats, dumbbells, fitness gear - Bicycles and bicycle accessories - Hand tools, screwdrivers, hammers - Garden hoses, plant pots, watering cans ## Questions ### Who is liable for the Sports, DIY and garden articles stream? The first company placing these products on the French market, with no revenue or volume threshold. Brands with no French establishment, EU or non-EU, in sports, DIY or garden categories selling to France. A producer with no French establishment must appoint a representative established in France, compulsory since 10 July 2026. ### Which products fall under the Sports, DIY and garden articles stream? For example: yoga mats, dumbbells, fitness gear; bicycles and bicycle accessories; hand tools, screwdrivers, hammers; garden hoses, plant pots, watering cans. Required for sports equipment, hand tools, garden articles, and DIY products shipped to French consumers. ### Which eco-organism covers Sports, DIY and garden articles? Ecologic, Ecomaison and Valobat are state-accredited for this stream. Joining any one of them satisfies the obligation; they differ on the published schedule and the declaration format, not on the legal cover. ### How often is the Sports, DIY and garden articles stream declared? DIY and garden articles at Ecomaison are declared quarterly by default (annual on option below 15 t, 1,000 pieces and EUR 2 million of turnover in the stream). ### Is there a minimum charge for the Sports, DIY and garden articles stream? €200/yr minimum (Ecologic). ### What does the Sports, DIY and garden articles stream cost? The eco-contribution follows the eco-organism's published schedule and depends on the volumes you declare, so it is specific to your catalogue. Our fee is separate: a published entry price of EUR 190 per year excluding VAT per stream, with the exact figure fixed in a written quote within one business day. --- URL: https://eprrepresentative.com/services/paper Last updated: 2026-10-08 # Graphic paper: EPR in France Graphic paper EPR in France is run by Citeo and Léko. A seller joins one of them, obtains its unique identifier (IDU) and declares once a year. Typical products: printed catalogs distributed in France. Without a French establishment, appointing a representative established in France has been compulsory since 10 July 2026. EPR Representative fills that role, from €190 a year excl. VAT per stream. Required for printed paper distributed in France: catalogs, magazines, books in some cases, advertising prints. The graphic paper stream covers professionally produced printed paper distributed in France, including catalogs, magazines and certain advertising mailings. Excludes packaging paper (which falls under packaging). Citeo and Léko both operate in this stream. Approved eco-organisations: Citeo, Léko. ## Who must register Publishers and printed marketing operations with no French establishment, EU or non-EU, distributing printed paper in France. ## Products in scope (examples) - Printed catalogs distributed in France - Magazines published outside the EU and distributed in France - Direct mail advertising ## Questions ### Who is liable for the Graphic paper stream? The first company placing these products on the French market, with no revenue or volume threshold. Publishers and printed marketing operations with no French establishment, EU or non-EU, distributing printed paper in France. A producer with no French establishment must appoint a representative established in France, compulsory since 10 July 2026. ### Which products fall under the Graphic paper stream? For example: printed catalogs distributed in France; magazines published outside the EU and distributed in France; direct mail advertising. Required for printed paper distributed in France: catalogs, magazines, books in some cases, advertising prints. ### Which eco-organism covers Graphic paper? Citeo and Léko are state-accredited for this stream. Joining any one of them satisfies the obligation; they differ on the published schedule and the declaration format, not on the legal cover. Citeo issues the identifier 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). ### How often is the Graphic paper stream declared? This stream is declared once a year. ### Is there a minimum charge for the Graphic paper stream? Below 5 tonnes a year, Léko charges no contribution on attestation; registration is still required. There is no exemption threshold in French EPR. ### What does the Graphic paper stream cost? The eco-contribution follows the eco-organism's published schedule and depends on the volumes you declare, so it is specific to your catalogue. Our fee is separate: a published entry price of EUR 190 per year excluding VAT per stream, with the exact figure fixed in a written quote within one business day. --- URL: https://eprrepresentative.com/services/construction Last updated: 2026-10-08 # Construction products and materials (PMCB): EPR in France Construction products and materials (PMCB) EPR in France is run by Valobat, Ecominéro, Ecomaison and Valdelia. A seller joins one of them, obtains its unique identifier (IDU) and declares on the eco-organisation’s calendar. Without a French establishment, appointing a representative established in France has been compulsory since 10 July 2026. EPR Representative fills that role, from €190 a year excl. VAT per stream. Required for construction products and building materials sold to French professionals or consumers. PMCB (produits et matériaux de construction du bâtiment) is one of the largest and most complex EPR streams, launched in 2023. It splits into category 1, inert mineral materials (concrete, tiles, bricks, ceramics) handled by Ecominéro and Valobat, and category 2, non-inert materials (wood, gypsum, insulation, metals, glass, plastics) handled by Valobat, Ecomaison and Valdelia. Approved eco-organisations: Valobat, Ecominéro, Ecomaison, Valdelia. ## Who must register Construction product brands with no French establishment, EU or non-EU, selling to the French market through any channel. ## Products in scope (examples) - Tiles, bricks, ceramics, concrete blocks (Ecominéro) - Plywood panels, insulation foam, drywall (Valobat) - Wooden flooring, decorative panels, fixtures ## Questions ### Who is liable for the Construction products and materials (PMCB) stream? The first company placing these products on the French market, with no revenue or volume threshold. Construction product brands with no French establishment, EU or non-EU, selling to the French market through any channel. A producer with no French establishment must appoint a representative established in France, compulsory since 10 July 2026. ### Which products fall under the Construction products and materials (PMCB) stream? For example: tiles, bricks, ceramics, concrete blocks (Ecominéro); plywood panels, insulation foam, drywall (Valobat); wooden flooring, decorative panels, fixtures. Required for construction products and building materials sold to French professionals or consumers. ### Which eco-organism covers Construction products and materials (PMCB)? Valobat, Ecominéro, Ecomaison and Valdelia are state-accredited for this stream. Joining any one of them satisfies the obligation; they differ on the published schedule and the declaration format, not on the legal cover. ### How often is the Construction products and materials (PMCB) stream declared? Ecominéro declares monthly, Ecomaison quarterly by default and Valdelia quarterly. ### What does the Construction products and materials (PMCB) stream cost? The eco-contribution follows the eco-organism's published schedule and depends on the volumes you declare, so it is specific to your catalogue. Our fee is separate: a published entry price of EUR 190 per year excluding VAT per stream, with the exact figure fixed in a written quote within one business day. --- URL: https://eprrepresentative.com/services/pro-packaging Last updated: 2026-10-08 # Professional packaging (EPRO): EPR in France Professional packaging (EPRO) EPR in France is run by Citeo Pro, Léko Pro and Twiice. A seller joins one of them, obtains its unique identifier (IDU) and declares once a year. Without a French establishment, appointing a representative established in France has been compulsory since 10 July 2026. EPR Representative fills that role, from €190 a year excl. VAT per stream. Packaging of products used only by professionals. A package also sold to households stays household packaging, even when a business buys it. The professional packaging (EPRO) stream covers packaging of products used only by professionals. A package also sold to households stays household packaging, even when a business buys it. The stream was created by décret n° 2025-1081 of 17 November 2025 and its cahier des charges (arrêté of 2 December 2025). Eco-contributions were scheduled to start on 1 July 2026; the launch was postponed on 26 June 2026 and is now set for 1 January 2027. Register now; contributions and identifiers start on 1 January 2027. Three eco-organisms were accredited in June 2026: Citeo Pro, Léko Pro and Twiice (the only operator 100% dedicated to professional packaging). The 2026 professional packaging scales were withdrawn when contributions moved to 2027. Citeo Pro and Léko Pro published their 2027 scales in October 2026 (both may still change; Twiice has not published yet). A producer that supplies French professionals may be subject to this stream in addition to the household packaging stream. Approved eco-organisations: Citeo Pro, Léko Pro, Twiice. ## Who must register Any producer with no French establishment, EU or non-EU, placing on the French market products used only by professionals, in their packaging. ## Products in scope (examples) - Pallet wrap and stretch film around goods sold only to businesses - Industrial cartons of products used only by professionals - Drums and intermediate bulk containers of professional products ## Questions ### Who is liable for the Professional packaging (EPRO) stream? The first company placing these products on the French market, with no revenue or volume threshold. Any producer with no French establishment, EU or non-EU, placing on the French market products used only by professionals, in their packaging. A producer with no French establishment must appoint a representative established in France, compulsory since 10 July 2026. ### Which products fall under the Professional packaging (EPRO) stream? For example: pallet wrap and stretch film around goods sold only to businesses; industrial cartons of products used only by professionals; drums and intermediate bulk containers of professional products. Packaging of products used only by professionals. A package also sold to households stays household packaging, even when a business buys it. ### Which eco-organism covers Professional packaging (EPRO)? Citeo Pro, Léko Pro and Twiice are state-accredited for this stream. Joining any one of them satisfies the obligation; they differ on the published schedule and the declaration format, not on the legal cover. Professional packaging (EPRO): registration is open now, eco-contributions from 1 January 2027. ### How often is the Professional packaging (EPRO) stream declared? This stream is declared once a year. ### What does the Professional packaging (EPRO) stream cost? The eco-contribution follows the eco-organism's published schedule and depends on the volumes you declare, so it is specific to your catalogue. Our fee is separate: a published entry price of EUR 190 per year excluding VAT per stream, with the exact figure fixed in a written quote within one business day. --- URL: https://eprrepresentative.com/services/chemicals Last updated: 2026-10-08 # Chemical products (DDS): EPR in France Chemical products (DDS) EPR in France is run by EcoDDS, Ecopae and Pyréo. A seller joins one of them, obtains its unique identifier (IDU) and declares once a year. Without a French establishment, appointing a representative established in France has been compulsory since 10 July 2026. EPR Representative fills that role, from €190 a year excl. VAT per stream. Required for diffuse-use chemical products sold to French consumers: paints, solvents, adhesives, aerosols, cleaning products, fire extinguishers. The PCHIM stream (produits chimiques, "déchets diffus spécifiques") covers household chemical products whose residues and packaging are hazardous: paints and coatings, solvents, adhesives and resins, aerosols, biocides and pool chemicals, plus specific sub-categories run by dedicated eco-organisms: portable fire extinguishers under Ecopae (category 2) and pyrotechnic articles under Pyréo (category 1). EcoDDS is the historic operator for the diffuse chemicals categories (3 to 10). Governing cahier des charges: arrêté of 1 October 2021. Approved eco-organisations: EcoDDS, Ecopae, Pyréo. ## Who must register Any producer or seller without a French establishment placing chemical products in scope on the French market, including cross-border e-commerce and marketplace sellers. ## Products in scope (examples) - Aerosol sprays and lubricant aerosols - Paints, varnishes, wood treatments, adhesives - Pool and spa chemicals, descalers, drain cleaners - Portable fire extinguishers (Ecopae) and pyrotechnic distress flares (Pyréo) ## Questions ### Who is liable for the Chemical products (DDS) stream? The first company placing these products on the French market, with no revenue or volume threshold. Any producer or seller without a French establishment placing chemical products in scope on the French market, including cross-border e-commerce and marketplace sellers. A producer with no French establishment must appoint a representative established in France, compulsory since 10 July 2026. ### Which products fall under the Chemical products (DDS) stream? For example: aerosol sprays and lubricant aerosols; paints, varnishes, wood treatments, adhesives; pool and spa chemicals, descalers, drain cleaners; portable fire extinguishers (Ecopae) and pyrotechnic distress flares (Pyréo). Required for diffuse-use chemical products sold to French consumers: paints, solvents, adhesives, aerosols, cleaning products, fire extinguishers. ### Which eco-organism covers Chemical products (DDS)? EcoDDS, Ecopae and Pyréo are state-accredited for this stream. Joining any one of them satisfies the obligation; they differ on the published schedule and the declaration format, not on the legal cover. ### How often is the Chemical products (DDS) stream declared? This stream is declared once a year. ### What does the Chemical products (DDS) stream cost? The eco-contribution follows the eco-organism's published schedule and depends on the volumes you declare, so it is specific to your catalogue. Our fee is separate: a published entry price of EUR 190 per year excluding VAT per stream, with the exact figure fixed in a written quote within one business day. --- URL: https://eprrepresentative.com/services/wipes Last updated: 2026-10-08 # Single-use sanitary textiles (TSUU): EPR in France Single-use sanitary textiles (TSUU) EPR in France is run by Citeo Soin & Hygiène. A seller joins it, obtains its unique identifier (IDU) and declares once a year. Without a French establishment, appointing a representative established in France has been compulsory since 10 July 2026. EPR Representative fills that role, from €190 a year excl. VAT per stream. Required for single-use wipes and sanitary textiles sold to French consumers: baby wipes, cleaning wipes, cosmetic pads. TSUU (textiles sanitaires à usage unique) is one of the newest French EPR streams, with a cahier des charges set by the arrêté of 20 December 2024. It covers single-use wipes (baby, cosmetic, household, disinfecting), cotton pads and similar sanitary textiles placed on the French market. The sole approved eco-organism is Citeo Soin & Hygiène. Because wipes are a very high-volume marketplace category, many foreign D2C and FBA sellers are in scope, often without realising it. Approved eco-organisations: Citeo Soin & Hygiène. ## Who must register Any producer or seller without a French establishment placing single-use wipes or sanitary textiles on the French market. ## Products in scope (examples) - Baby wipes and cleansing wipes - Household and disinfecting wipes - Cosmetic cotton pads and make-up removal wipes - Surface and screen cleaning wipes ## Questions ### Who is liable for the Single-use sanitary textiles (TSUU) stream? The first company placing these products on the French market, with no revenue or volume threshold. Any producer or seller without a French establishment placing single-use wipes or sanitary textiles on the French market. A producer with no French establishment must appoint a representative established in France, compulsory since 10 July 2026. ### Which products fall under the Single-use sanitary textiles (TSUU) stream? For example: baby wipes and cleansing wipes; household and disinfecting wipes; cosmetic cotton pads and make-up removal wipes; surface and screen cleaning wipes. Required for single-use wipes and sanitary textiles sold to French consumers: baby wipes, cleaning wipes, cosmetic pads. ### Which eco-organism covers Single-use sanitary textiles (TSUU)? Citeo Soin & Hygiène is state-accredited for this stream. Joining it satisfies the obligation; it varies on the published schedule and the declaration format, not on the legal cover. ### How often is the Single-use sanitary textiles (TSUU) stream declared? This stream is declared once a year. ### Is there a minimum charge for the Single-use sanitary textiles (TSUU) stream? €232 excl. VAT/yr minimum (equivalent to 1 tonne). ### What does the Single-use sanitary textiles (TSUU) stream cost? The eco-contribution follows the eco-organism's published schedule and depends on the volumes you declare, so it is specific to your catalogue. Our fee is separate: a published entry price of EUR 190 per year excluding VAT per stream, with the exact figure fixed in a written quote within one business day. --- URL: https://eprrepresentative.com/services/tyres Last updated: 2026-10-08 # Tyres (PNEU): EPR in France Tyres (PNEU) EPR in France is run by Aliapur, France Recyclage Pneumatiques and Tyval. A seller joins one of them, obtains its unique identifier (IDU) and declares once a year. Without a French establishment, appointing a representative established in France has been compulsory since 10 July 2026. EPR Representative fills that role, from €190 a year excl. VAT per stream. Required for tyres placed on the French market: car, van, truck, agricultural, two-wheeler and more. The PNEU stream covers pneumatic tyres of every category (light vehicles, trucks, agricultural and civil-engineering machinery, two-wheelers, aircraft and solid tyres) placed on the French market, whether sold standalone or fitted to a vehicle. Since 2024 the eco-contribution is eco-modulated on the presence of SVHC substances (penalty) and recycled-material content (bonus). Three eco-organisms are approved: Aliapur (the historic market leader), France Recyclage Pneumatiques and Tyval. Cahier des charges: arrêté of 27 June 2023. Approved eco-organisations: Aliapur, France Recyclage Pneumatiques, Tyval. ## Who must register Any producer, importer or seller without a French establishment placing tyres on the French market, including aftermarket e-commerce sellers. ## Products in scope (examples) - Replacement car and van tyres sold online - Motorcycle and scooter tyres - Agricultural and civil-engineering tyres - Bicycle and trailer tyres ## Questions ### Who is liable for the Tyres (PNEU) stream? The first company placing these products on the French market, with no revenue or volume threshold. Any producer, importer or seller without a French establishment placing tyres on the French market, including aftermarket e-commerce sellers. A producer with no French establishment must appoint a representative established in France, compulsory since 10 July 2026. ### Which products fall under the Tyres (PNEU) stream? For example: replacement car and van tyres sold online; motorcycle and scooter tyres; agricultural and civil-engineering tyres; bicycle and trailer tyres. Required for tyres placed on the French market: car, van, truck, agricultural, two-wheeler and more. ### Which eco-organism covers Tyres (PNEU)? Aliapur, France Recyclage Pneumatiques and Tyval are state-accredited for this stream. Joining any one of them satisfies the obligation; they differ on the published schedule and the declaration format, not on the legal cover. ### How often is the Tyres (PNEU) stream declared? This stream is declared once a year. ### What does the Tyres (PNEU) stream cost? The eco-contribution follows the eco-organism's published schedule and depends on the volumes you declare, so it is specific to your catalogue. Our fee is separate: a published entry price of EUR 190 per year excluding VAT per stream, with the exact figure fixed in a written quote within one business day. --- URL: https://eprrepresentative.com/services/lubricants Last updated: 2026-10-08 # Lubricating and industrial oils (LUB): EPR in France Lubricating and industrial oils (LUB) EPR in France is run by Cyclevia. A seller joins it, obtains its unique identifier (IDU) and declares once a year. Without a French establishment, appointing a representative established in France has been compulsory since 10 July 2026. EPR Representative fills that role, from €190 a year excl. VAT per stream. Required for lubricating and industrial oils placed on the French market: motor oils, greases, hydraulic and industrial fluids. The LUB stream covers lubricating, industrial and similar oils placed on the French market. Cyclevia is the sole approved eco-organism, financing the collection and regeneration of used oils. Producers contribute per tonne placed on the market. Cahier des charges: arrêté of 27 October 2021. E-commerce sellers of motor oils, chain lubricants and maintenance fluids are in scope. Approved eco-organisations: Cyclevia. ## Who must register Any producer or seller without a French establishment placing lubricating or industrial oils on the French market. ## Products in scope (examples) - Engine and motor oils sold to consumers - Chain lubricants, greases, gear oils - Hydraulic and industrial fluids - 2-stroke and specialty lubricants ## Questions ### Who is liable for the Lubricating and industrial oils (LUB) stream? The first company placing these products on the French market, with no revenue or volume threshold. Any producer or seller without a French establishment placing lubricating or industrial oils on the French market. A producer with no French establishment must appoint a representative established in France, compulsory since 10 July 2026. ### Which products fall under the Lubricating and industrial oils (LUB) stream? For example: engine and motor oils sold to consumers; chain lubricants, greases, gear oils; hydraulic and industrial fluids; 2-stroke and specialty lubricants. Required for lubricating and industrial oils placed on the French market: motor oils, greases, hydraulic and industrial fluids. ### Which eco-organism covers Lubricating and industrial oils (LUB)? Cyclevia is state-accredited for this stream. Joining it satisfies the obligation; it varies on the published schedule and the declaration format, not on the legal cover. ### How often is the Lubricating and industrial oils (LUB) stream declared? This stream is declared once a year. ### What does the Lubricating and industrial oils (LUB) stream cost? The eco-contribution follows the eco-organism's published schedule and depends on the volumes you declare, so it is specific to your catalogue. Our fee is separate: a published entry price of EUR 190 per year excluding VAT per stream, with the exact figure fixed in a written quote within one business day. --- URL: https://eprrepresentative.com/services/medical-sharps Last updated: 2026-10-08 # Self-care medical sharps (DASRI): EPR in France Self-care medical sharps (DASRI) EPR in France is run by DASTRI. A seller joins it, obtains its unique identifier (IDU) and declares once a year. Without a French establishment, appointing a representative established in France has been compulsory since 10 July 2026. EPR Representative fills that role, from €190 a year excl. VAT per stream. Required for perforating self-care medical devices used by patients at home: pen needles, lancets, syringes. The DISP-MED stream covers perforating self-care medical devices (DASRI perforants) used by patients treating themselves at home: insulin pen needles, lancets, syringes and similar sharps. DASTRI is the sole approved eco-organism, operating the pharmacy take-back network for used sharps containers. Cahier des charges: arrêté of 2 November 2022. Producers of self-care devices and the associated medications are in scope. Approved eco-organisations: DASTRI. ## Who must register Any producer without a French establishment placing perforating self-care medical devices (or medicines using them) on the French market. ## Products in scope (examples) - Insulin pen needles and lancets - Pre-filled syringes for self-injection - Blood-glucose lancing devices - Auto-injectors for self-administration ## Questions ### Who is liable for the Self-care medical sharps (DASRI) stream? The first company placing these products on the French market, with no revenue or volume threshold. Any producer without a French establishment placing perforating self-care medical devices (or medicines using them) on the French market. A producer with no French establishment must appoint a representative established in France, compulsory since 10 July 2026. ### Which products fall under the Self-care medical sharps (DASRI) stream? For example: insulin pen needles and lancets; pre-filled syringes for self-injection; blood-glucose lancing devices; auto-injectors for self-administration. Required for perforating self-care medical devices used by patients at home: pen needles, lancets, syringes. ### Which eco-organism covers Self-care medical sharps (DASRI)? DASTRI is state-accredited for this stream. Joining it satisfies the obligation; it varies on the published schedule and the declaration format, not on the legal cover. ### How often is the Self-care medical sharps (DASRI) stream declared? This stream is declared once a year. ### Is there a minimum charge for the Self-care medical sharps (DASRI) stream? Fixed part €5,000/yr. ### What does the Self-care medical sharps (DASRI) stream cost? The eco-contribution follows the eco-organism's published schedule and depends on the volumes you declare, so it is specific to your catalogue. Our fee is separate: a published entry price of EUR 190 per year excluding VAT per stream, with the exact figure fixed in a written quote within one business day. --- URL: https://eprrepresentative.com/services/medicines Last updated: 2026-10-08 # Unused medicines (MNU): EPR in France Unused medicines (MNU) EPR in France is run by Cyclamed. A seller joins it, obtains its unique identifier (IDU) and declares once a year. Without a French establishment, appointing a representative established in France has been compulsory since 10 July 2026. EPR Representative fills that role, from €190 a year excl. VAT per stream. Required for medicines for human use placed on the French market, financing the Cyclamed pharmacy take-back scheme. The MNU stream (médicaments non utilisés) covers medicines for human use placed on the French market. Cyclamed is the sole approved eco-organism, running the long-established pharmacy take-back scheme for unused and expired medicines. The 2026 contribution is a very low per-box amount (about €0.0045 per box). Cahier des charges: arrêté of 29 October 2021. Pharmaceutical laboratories and importers are in scope. Approved eco-organisations: Cyclamed. ## Who must register Any pharmaceutical producer or importer without a French establishment placing medicines for human use on the French market. ## Products in scope (examples) - Prescription and OTC medicines in boxes - Human-use pharmaceutical specialities - Imported branded and generic drugs ## Questions ### Who is liable for the Unused medicines (MNU) stream? The first company placing these products on the French market, with no revenue or volume threshold. Any pharmaceutical producer or importer without a French establishment placing medicines for human use on the French market. A producer with no French establishment must appoint a representative established in France, compulsory since 10 July 2026. ### Which products fall under the Unused medicines (MNU) stream? For example: prescription and OTC medicines in boxes; human-use pharmaceutical specialities; imported branded and generic drugs. Required for medicines for human use placed on the French market, financing the Cyclamed pharmacy take-back scheme. ### Which eco-organism covers Unused medicines (MNU)? Cyclamed is state-accredited for this stream. Joining it satisfies the obligation; it varies on the published schedule and the declaration format, not on the legal cover. ### How often is the Unused medicines (MNU) stream declared? This stream is declared once a year. ### What does the Unused medicines (MNU) stream cost? The eco-contribution follows the eco-organism's published schedule and depends on the volumes you declare, so it is specific to your catalogue. Our fee is separate: a published entry price of EUR 190 per year excluding VAT per stream, with the exact figure fixed in a written quote within one business day. --- URL: https://eprrepresentative.com/services/tobacco Last updated: 2026-10-08 # Tobacco products (mégots): EPR in France Tobacco products (mégots) EPR in France is run by Alcome. A seller joins it, obtains its unique identifier (IDU) and declares once a year. Without a French establishment, appointing a representative established in France has been compulsory since 10 July 2026. EPR Representative fills that role, from €190 a year excl. VAT per stream. Required for tobacco products with plastic-containing filters placed on the French market (cigarette-butt litter stream). The TABAC stream addresses the litter from tobacco product filters containing plastic. Alcome is the sole approved eco-organism, funding street-cleaning, public ashtrays and awareness campaigns for local authorities. Producers contribute based on quantities placed on the market. Cahier des charges: arrêté of 23 November 2022. Tobacco manufacturers and importers placing product on the French market are in scope. Approved eco-organisations: Alcome. ## Who must register Any tobacco producer or importer without a French establishment placing filtered tobacco products on the French market. ## Products in scope (examples) - Cigarettes with cellulose-acetate (plastic) filters - Roll-your-own tobacco with filter tips - Other filtered tobacco products ## Questions ### Who is liable for the Tobacco products (mégots) stream? The first company placing these products on the French market, with no revenue or volume threshold. Any tobacco producer or importer without a French establishment placing filtered tobacco products on the French market. A producer with no French establishment must appoint a representative established in France, compulsory since 10 July 2026. ### Which products fall under the Tobacco products (mégots) stream? For example: cigarettes with cellulose-acetate (plastic) filters; roll-your-own tobacco with filter tips; other filtered tobacco products. Required for tobacco products with plastic-containing filters placed on the French market (cigarette-butt litter stream). ### Which eco-organism covers Tobacco products (mégots)? Alcome is state-accredited for this stream. Joining it satisfies the obligation; it varies on the published schedule and the declaration format, not on the legal cover. ### How often is the Tobacco products (mégots) stream declared? This stream is declared once a year. ### What does the Tobacco products (mégots) stream cost? The eco-contribution follows the eco-organism's published schedule and depends on the volumes you declare, so it is specific to your catalogue. Our fee is separate: a published entry price of EUR 190 per year excluding VAT per stream, with the exact figure fixed in a written quote within one business day. --- URL: https://eprrepresentative.com/services/boats Last updated: 2026-10-08 # Pleasure and sport boats (BPS): EPR in France Pleasure and sport boats (BPS) EPR in France is run by APER. A seller joins it, obtains its unique identifier (IDU) and declares once a year. Without a French establishment, appointing a representative established in France has been compulsory since 10 July 2026. EPR Representative fills that role, from €190 a year excl. VAT per stream. Required for pleasure and sport boats placed on the French market, financing the end-of-life boat deconstruction scheme. The BPS stream (bateaux de plaisance ou de sport) covers recreational and sport boats placed on the French market. APER is the sole approved eco-organism, organising the deconstruction and recycling of end-of-life pleasure craft. Cahier des charges: arrêté of 6 December 2023. Boat builders and importers placing craft on the French market are in scope. Approved eco-organisations: APER. ## Who must register Any boat builder or importer without a French establishment placing pleasure or sport boats on the French market. ## Products in scope (examples) - Sailing and motor pleasure boats - Rigid-hull and inflatable sport boats - Personal watercraft (jet skis) ## Questions ### Who is liable for the Pleasure and sport boats (BPS) stream? The first company placing these products on the French market, with no revenue or volume threshold. Any boat builder or importer without a French establishment placing pleasure or sport boats on the French market. A producer with no French establishment must appoint a representative established in France, compulsory since 10 July 2026. ### Which products fall under the Pleasure and sport boats (BPS) stream? For example: sailing and motor pleasure boats; rigid-hull and inflatable sport boats; personal watercraft (jet skis). Required for pleasure and sport boats placed on the French market, financing the end-of-life boat deconstruction scheme. ### Which eco-organism covers Pleasure and sport boats (BPS)? APER is state-accredited for this stream. Joining it satisfies the obligation; it varies on the published schedule and the declaration format, not on the legal cover. ### How often is the Pleasure and sport boats (BPS) stream declared? This stream is declared once a year. ### What does the Pleasure and sport boats (BPS) stream cost? The eco-contribution follows the eco-organism's published schedule and depends on the volumes you declare, so it is specific to your catalogue. Our fee is separate: a published entry price of EUR 190 per year excluding VAT per stream, with the exact figure fixed in a written quote within one business day. --- URL: https://eprrepresentative.com/services/vehicles Last updated: 2026-10-08 # End-of-life vehicles (VHU): EPR in France End-of-life vehicles (VHU) EPR in France is run by Recycler Mon Véhicule. A seller joins it, obtains its unique identifier (IDU) and declares once a year. Without a French establishment, appointing a representative established in France has been compulsory since 10 July 2026. EPR Representative fills that role, from €190 a year excl. VAT per stream. Required for cars and light vehicles placed on the French market, financing the end-of-life vehicle treatment network. The VEHICULE stream covers end-of-life vehicles (VHU): passenger cars and light commercial vehicles placed on the French market. Recycler Mon Véhicule is an approved eco-organism operating the authorised treatment and depollution network. Cahier des charges: arrêté of 20 November 2023. Vehicle manufacturers and importers are in scope. Approved eco-organisations: Recycler Mon Véhicule. ## Who must register Any vehicle manufacturer or importer without a French establishment placing cars or light vehicles on the French market. ## Products in scope (examples) - Passenger cars (category M1) - Light commercial vehicles (category N1) - Three-wheeled motor vehicles ## Questions ### Who is liable for the End-of-life vehicles (VHU) stream? The first company placing these products on the French market, with no revenue or volume threshold. Any vehicle manufacturer or importer without a French establishment placing cars or light vehicles on the French market. A producer with no French establishment must appoint a representative established in France, compulsory since 10 July 2026. ### Which products fall under the End-of-life vehicles (VHU) stream? For example: passenger cars (category M1); light commercial vehicles (category N1); three-wheeled motor vehicles. Required for cars and light vehicles placed on the French market, financing the end-of-life vehicle treatment network. ### Which eco-organism covers End-of-life vehicles (VHU)? Recycler Mon Véhicule is state-accredited for this stream. Joining it satisfies the obligation; it varies on the published schedule and the declaration format, not on the legal cover. ### How often is the End-of-life vehicles (VHU) stream declared? This stream is declared once a year. ### What does the End-of-life vehicles (VHU) stream cost? The eco-contribution follows the eco-organism's published schedule and depends on the volumes you declare, so it is specific to your catalogue. Our fee is separate: a published entry price of EUR 190 per year excluding VAT per stream, with the exact figure fixed in a written quote within one business day. --- URL: https://eprrepresentative.com/from/us Last updated: 2026-10-12 # French EPR for companies based in United States A US company with no establishment in France that sells into France, through Amazon.fr, Pan-European FBA, a Shopify store shipping to French addresses or a French reseller that does not take title, is the producer and must appoint a representative established in France, compulsory since 10 July 2026. Delaware or any other state of incorporation changes nothing. One written mandate covers all its French streams. 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. ## 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. ## When the obligation starts 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. ## Why it matters 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. ## Sales channels 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. ## Questions ### 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. --- URL: https://eprrepresentative.com/from/uk Last updated: 2026-10-12 # French EPR for companies based in United Kingdom A UK company with no French establishment selling into France must appoint a representative established in France, compulsory since 10 July 2026. UK packaging EPR, UK WEEE and UK batteries registrations cover the UK only, and selling on Amazon.co.uk says nothing about Amazon.fr. For packaging, PPWR Article 45 adds a representative in each EU country where the UK seller makes packaging available. A UK company selling into France is a producer outside France and outside the EU. Its UK packaging EPR, WEEE and batteries registrations cover the UK only, so French sales need French memberships, French identifiers and, since 10 July 2026, a representative established in France. We are that representative, for French EPR only. ## You already report under UK packaging EPR: what carries over to France, and what does not? Your UK packaging EPR registration does not cover France, which works stream by stream, with one approved eco-organisation and one identifier per stream. The weight-by-material data you prepare for the UK is often a good basis, but the French declaration also asks for units sold, and Info-tri labelling is specific to France. Your UK WEEE compliance scheme, your UK batteries registration and the Packaging Recovery Notes you buy cover the UK market only, and the UK Plastic Packaging Tax is a tax, not an EPR scheme. None of these numbers is accepted in place of a French identifier. ## Amazon.co.uk orders to France, Pan-European stock, delivered duty paid: who is the producer? The producer is whoever owns the goods when they enter France: not the brand as such, not the Incoterm, not whoever clears customs. A UK company that sells to French customers and still owns the goods when they cross into France is the producer, whatever the warehouse or the delivery terms. Orders on Amazon.co.uk delivered to UK addresses are UK sales. Orders delivered to French addresses, from Amazon.co.uk, Amazon.fr or stock that Amazon moves into French fulfilment centres, are French sales, and you remain the owner of the goods until the customer buys them. Delivered duty paid only decides who bears the import costs. Where a French buyer buys the goods and imports them in its own name, that buyer is the producer for those flows. ## What changed for UK sellers when the July 2026 law came in? Law n° 2026-602 made establishment in France the test, so a UK company with no French establishment must appoint a representative established in France. Brexit matters less than many UK sellers think: an Irish or Dutch company with no French establishment needs one too. What Brexit did change is that UK and EU rules now run separately, so nothing registered in the UK carries over to France. ## Does PPWR Article 45 mean one representative for the whole EU? No. The PPWR, in force since 12 August 2026, applies member state by member state: a UK producer needs an authorised representative for packaging in each EU country where it makes packaging available and is not established. We cover France only, for all French streams. ## Which UK company documents do we need? A Companies House extract less than three months old, the name of the director who signs (or a written delegation if the signatory is not a director), your UK VAT number and a bank document. We never ask for an identity document. The rest of the file is the same closed list for every producer, set out below. The mandate is in English or French and signed online. ## When the obligation starts The obligation starts with the first product a UK company places on the French market: an Amazon.fr order, a parcel from a UK or EU warehouse to a French customer, a delivery to a French shop that does not import the goods itself. Since the end of the Brexit transition period on 31 December 2020, those goods enter France from a third country, but the French test is simpler still: no establishment in France means a French representative. ## Why it matters Marketplaces selling to French customers must check their sellers' French registration (Article L. 541-10-9 of the French Environmental Code). A UK registration number is not a French identifier, so Amazon.fr, ManoMano or Cdiscount ask a UK seller for the French IDU 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. ## Sales channels UK brands reach France through Amazon.fr, their own Shopify stores shipping from the UK or from an EU 3PL, eBay and ManoMano for home and garden goods. Amazon.co.uk and Amazon.fr are separate stores: a UK seller account active on Amazon.fr is checked against French requirements, whatever it has registered in the UK. ## Questions ### Does my UK packaging EPR or WEEE registration cover France? No. UK packaging EPR, UK WEEE and UK batteries registrations cover the UK market only. France requires its own membership and identifier per stream with a French eco-organisation, filed through a representative established in France. ### I am still a member of a UK compliance scheme and buy PRNs. Does that count? No. Packaging Recovery Notes evidence UK recycling obligations. They have no effect in France, where packaging is registered with Citeo or Léko and declared to them. ### My fulfilment is in Belgium or the Netherlands, not the UK. Does it matter? Not for France. The trigger is the French customer, not the dispatch country. If your UK company sells products delivered to French customers, it is the producer for France, wherever the warehouse is. ### Does a French VAT number make my UK company established in France? No. A French VAT registration, or a fiscal representative for VAT, does not create an establishment in France for EPR. You still need a representative established in France. We do not handle VAT. --- URL: https://eprrepresentative.com/from/china Last updated: 2026-10-12 # French EPR for companies based in China A Chinese company selling to French customers through Amazon.fr, AliExpress, Temu, TikTok Shop or its own store has no establishment in France, so it must appoint a representative established in France, compulsory since 10 July 2026. Electrical equipment, batteries, textile, toys and packaging are the streams most often triggered. The file is built from the business licence (营业执照) and runs in English or French. Chinese manufacturers and trading companies selling to French customers, on Amazon.fr, AliExpress, Temu, TikTok Shop, Cdiscount or their own stores, are producers for French EPR. With no establishment in France, they must appoint a representative established in France. We are that representative, working in writing in English and French. ## Which entity signs: the factory, the trading company or the Hong Kong company? The entity that sells to the French customer, which is the seller of record on the marketplace. If a Hong Kong or mainland trading company holds the Amazon.fr account, that company signs the mandate; if the factory sells directly, the factory signs. The business licence (营业执照) shows the legal representative (法定代表人) who signs, or who delegates in writing. ## Who is the producer on Temu, Shein, AliExpress or TikTok Shop? Whoever owns the goods when they enter France. If the platform buys your goods before they enter France and resells them, it is the producer for those goods; if it sells in your name while you still own the goods, you are the producer, whether the stock ships from China or from a warehouse in Europe. Each platform runs several selling models and they change, so we do not assume which one applies to you: we read your seller agreement and your shipping flows before the quote. Where a platform takes on EPR for the products it sells for you (Article L. 541-10-9), that covers only those products and only while you are not registered yourself; your own store, other marketplaces and sales to businesses stay yours. ## Which streams do Chinese electronics and small-goods sellers usually trigger? Electrical and electronic equipment plus batteries for chargers, earbuds, lamps and power banks; textile for clothing, shoes and home linen; toys; and household packaging for almost everything sold to consumers. One mandate covers all of them, with one membership and one identifier per stream. ## Which Chinese company documents do we need? Your business licence (营业执照) with an English or French translation, the name of the legal representative (法定代表人) who signs or delegates in writing, and a bank document. We never ask for an identity document. The rest of the file is the same closed list for every producer, set out below. ## Do you work in Chinese? No. We work in writing, in English and French. Our guides in Chinese on /zh explain the rules, but the file, the mandate and our replies are in English or French. ## When the obligation starts The obligation starts with the first product placed on the French market: an Amazon.fr order, an AliExpress or Temu parcel to a French address, a TikTok Shop sale, a delivery to a French buyer that does not import the goods itself. Where the goods are made and where the company is incorporated, mainland China or elsewhere, play no part. ## Why it matters Marketplaces selling to French customers must check that their sellers are registered (Article L. 541-10-9 of the French Environmental Code), and a missing French identifier blocks the listing whatever the account's history on other Amazon stores. 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 claim contributions for sales made before you joined: we tell you before signing whether earlier years are at stake. ## Sales channels Chinese sellers reach French customers through Amazon.fr, AliExpress, Temu, TikTok Shop, Cdiscount and their own Shopify stores. The producer for France is whoever owns the goods when they enter France, which is the entity that signs the mandate. ## Questions ### Does a Chinese registration or certification cover France? No. Nothing registered in China counts for French EPR. France requires its own membership and identifier per stream with a French eco-organisation, filed through a representative established in France. ### Can my Chinese trading company sign the mandate, or does it have to be the manufacturing entity? Whichever entity is the producer for the French market signs the mandate. If your trading company is the seller of record on Amazon.fr, that entity signs. If your manufacturing entity ships directly, that one signs. ### I already have a German LUCID number. Does that cover France? No. LUCID covers German packaging only. France has its own system, an identifier per stream, separate from Germany. --- URL: https://eprrepresentative.com/from/canada Last updated: 2026-10-12 # French EPR for companies based in Canada A Canadian company selling into France through Amazon.fr, a Shopify store or a French reseller that does not take title has no French establishment, so it must appoint a representative established in France, compulsory since 10 July 2026. Provincial EPR memberships, such as Éco Entreprises Québec, cover Canada only. Quebec companies can run the whole file, mandate included, in French. A Canadian company selling to French customers through Amazon.fr, a Shopify store or a French reseller that does not import the goods itself is the producer for French EPR. Provincial EPR memberships cover Canada only. With no establishment in France, the company must appoint a representative established in France. We are that representative, in French or in English. ## Can a Quebec company run the whole file in French? Yes. The mandate exists in French and in English, our written replies are in either language, and the French eco-organisations work in French. A Quebec company can therefore read its contracts with Citeo, Léko or Refashion in their original language. ## Does CETA change anything for French EPR? No. The EU-Canada agreement (CETA) deals with tariffs and trade rules. French EPR is a French environmental obligation that applies to any producer selling into France, Canadian or not. ## Amazon.fr, a Shopify store or a French distributor: who is the producer for each channel? The producer is whoever owns the goods when they enter France. On Amazon.fr and on a Shopify store shipping to French addresses that is the Canadian company; with a French distributor that buys and imports the goods in its own name, it is the distributor. Stock held for you by a 3PL or by Amazon stays yours, wherever the warehouse is. If you sell through a US entity, the entity that owns the goods when they enter France is the producer and signs the mandate. ## Which Canadian company documents do we need? A certificate or corporate profile less than three months old from Corporations Canada or your provincial registry (for Quebec, the Registraire des entreprises, with your NEQ), your CRA business number and a bank document. The signatory must appear as a director or officer, or hold a written delegation. We never ask for an identity document. The rest of the file is the same closed list for every producer, set out below. ## When the obligation starts The obligation starts with the first product a Canadian company places on the French market: an Amazon.fr order, a parcel from Canada or from an EU 3PL to a French address, a delivery to a French shop that does not import the goods itself. Whether the company is incorporated federally or in a province plays no part. ## Why it matters Marketplaces selling to French customers must check that their sellers are registered (Article L. 541-10-9 of the French Environmental Code), and a Canadian registration number is not a French identifier. 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. ## Sales channels Canadian brands reach France mainly through Amazon.fr, Shopify stores shipping from Canada or from an EU 3PL, and French distributors. Where a French distributor buys and imports the goods, the distributor is the producer for those flows; direct sales stay yours. ## Questions ### I am Quebec-based and already report to Éco Entreprises Québec. Does that count in France? No. Éco Entreprises Québec covers packaging and printed paper supplied in Quebec. France requires its own membership with Citeo or Léko and its own identifier, even for the same products. ### Can the mandate be signed in French? Yes. The mandate exists in French and in English, signed electronically. --- URL: https://eprrepresentative.com/from/germany Last updated: 2026-10-12 # French EPR for companies based in Germany A company based in Germany selling into France has no French establishment, so it must appoint a representative established in France, compulsory since 10 July 2026. In practice: one eco-organism membership per stream, a unique identifier (IDU) shown on its sales channels (Amazon France FBA, Cdiscount and ManoMano) and declarations, most of them once a year. EPR Representative takes charge of that registration and those declarations, from €190 a year excl. VAT per stream. A German GmbH, UG or AG selling into France is a French EPR producer whenever it is the first to place goods on the French market. EU membership makes no difference: what triggers the French mandataire obligation is not being established in France, not being outside the EU. Your German LUCID / ZSVR registration covers Germany, not France. ## When the obligation starts The trigger is the first placement on the French market, not your country of establishment. A German company shipping to French consumers (Amazon.fr, your own shop, Cdiscount) or selling to French buyers who do not take title as importer is the producer under Article L. 541-10 II. In force since 12 August 2026, Article 45 of Regulation (EU) 2025/40 requires a producer that makes packaging available in a member state where it is not established, including from another EU country, to appoint an authorised representative for extended producer responsibility in that member state. ## Why it matters The legal basis: 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. Marketplaces must check the French IDU of their sellers, whatever your German registration (Article L. 541-10-9). 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. ## Sales channels German brands typically reach French buyers via Amazon.fr (often Pan-European FBA from a German or Polish hub), Cdiscount, ManoMano for home and DIY, and D2C Shopify. Fulfilment from a German warehouse does not change the destination-market rule: goods reaching a French consumer trigger French EPR. A German LUCID number is not accepted by Amazon.fr for French sales. ## Questions ### We are an EU company, does the single market not exempt us from a French representative? No. The obligation turns on establishment in France, not on EU membership. A German company with no French entity that first places products on the French market must appoint a French authorised representative. PPWR Article 45, in force since 12 August 2026, confirms this per Member State. ### Does my LUCID number cover France? No. LUCID covers German packaging obligations only. France has its own system: an IDU per stream issued after registration with a French eco-organisation (Citeo, Léko, Refashion…). The two systems do not share data. ### We sell to a French distributor, not directly to consumers. Who is the producer? It depends on the chain of title. If the French distributor takes title to the goods (imports them) before they reach the consumer, that French entity is the producer and you may not need a mandataire. If you still own the goods when they enter France (drop-ship, consignment, D2C), you are the producer. The test is who owns the goods when they enter France, not the Incoterm, and we settle it channel by channel before the quote. --- URL: https://eprrepresentative.com/from/netherlands Last updated: 2026-10-12 # French EPR for companies based in Netherlands A company based in the Netherlands selling into France has no French establishment, so it must appoint a representative established in France, compulsory since 10 July 2026. In practice: one eco-organism membership per stream, a unique identifier (IDU) shown on its sales channels (Amazon France FBA, Bol and Shopify) and declarations, most of them once a year. EPR Representative takes charge of that registration and those declarations, from €190 a year excl. VAT per stream. A Dutch BV or NV selling into France is a French EPR producer whenever it is the first to place goods on the French market. Being in the EU changes nothing: the French mandataire obligation is triggered by not being established in France, not by being outside the EU. Your Afvalfonds Verpakkingen participation covers the Netherlands, not France. ## When the obligation starts The trigger is the first placement on the French market, not your country of establishment. A Dutch company shipping to French consumers (Amazon.fr, your own shop) or selling to French buyers who do not take title as importer is the producer under Article L. 541-10 II. In force since 12 August 2026, Article 45 of Regulation (EU) 2025/40 requires a producer that makes packaging available in a member state where it is not established, including from another EU country, to appoint an authorised representative for extended producer responsibility in that member state. ## Why it matters The legal basis: 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. Marketplaces must check the French IDU of their sellers, whatever your Dutch registration (Article L. 541-10-9). 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. ## Sales channels Dutch brands reach French buyers via Amazon.fr, their own Shopify D2C stores, ManoMano for home and garden, and increasingly via cross-border fulfilment from a Dutch or Belgian hub. Dispatch from the Netherlands does not avoid the obligation: goods reaching a French consumer trigger French EPR, on top of any Dutch Afvalfonds participation. ## Questions ### We are an EU company, does the single market not exempt us from a French representative? No. The obligation turns on establishment in France, not on EU membership. A Dutch company with no French entity that first places products on the French market must appoint a French authorised representative. PPWR Article 45, in force since 12 August 2026, confirms this per Member State. ### Does our Afvalfonds Verpakkingen registration cover France? No. Afvalfonds covers Dutch packaging obligations only. France requires its own IDU per stream, issued after registration with a French eco-organisation. The Dutch and French systems are independent. ### We sell clothing and it ships in our own packaging. Which streams apply? Typically two: textile (TLC, via Refashion) for the garments themselves, and household packaging (Citeo or Léko) for the polybags, boxes and mailers. A single mandate can cover both, each stream priced as a fixed annual fee in the same written quote. --- URL: https://eprrepresentative.com/from/spain Last updated: 2026-10-12 # French EPR for companies based in Spain A company based in Spain selling into France has no French establishment, so it must appoint a representative established in France, compulsory since 10 July 2026. In practice: one eco-organism membership per stream, a unique identifier (IDU) shown on its sales channels (Amazon France FBA, Cdiscount and ManoMano) and declarations, most of them once a year. EPR Representative takes charge of that registration and those declarations, from €190 a year excl. VAT per stream. A Spanish SL or SA selling into France is a French EPR producer whenever it is the first to place goods on the French market. EU membership makes no difference: the French mandataire obligation is triggered by not being established in France, not by being outside the EU. Your Spanish packaging registration covers Spain, not France. ## When the obligation starts The trigger is the first placement on the French market, not your country of establishment. A Spanish company shipping to French consumers (Amazon.fr, your own shop, Cdiscount) or selling to French buyers who do not take title as importer is the producer under Article L. 541-10 II. In force since 12 August 2026, Article 45 of Regulation (EU) 2025/40 requires a producer that makes packaging available in a member state where it is not established, including from another EU country, to appoint an authorised representative for extended producer responsibility in that member state. ## Why it matters The legal basis: 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. Marketplaces must check the French IDU of their sellers, whatever your Spanish registration (Article L. 541-10-9). 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. ## Sales channels Spanish brands reach French buyers via Amazon.fr (often the same catalogue as Amazon.es), Cdiscount, ManoMano for home and DIY, and D2C Shopify. Proximity and shared logistics with France do not remove the obligation: goods reaching a French consumer trigger French EPR, separate from any Spanish scheme. ## Questions ### We are an EU company, does the single market not exempt us from a French representative? No. The obligation turns on establishment in France, not on EU membership. A Spanish company with no French entity that first places products on the French market must appoint a French authorised representative. PPWR Article 45, in force since 12 August 2026, confirms this per Member State. ### Does our Spanish packaging registration cover France? No. The Spanish scheme covers Spanish obligations only. France requires its own IDU per stream, issued after registration with a French eco-organisation. The Spanish and French systems are independent. ### Your annual fee, is that your service or the recycling cost? Two separate things. Our fee is our service (registration, IDU, declarations, mandate): a fixed annual fee per stream, confirmed in a written quote within one business day. The eco-contribution is set by the French eco-organisation on its published schedule and on your declared volumes, and it stays separate from our fee: we take no percentage and no markup on it. Your eco-contributions stay invoiced to you and paid by you directly to the eco-organisation. --- URL: https://eprrepresentative.com/from/italy Last updated: 2026-10-12 # French EPR for companies based in Italy A company based in Italy selling into France has no French establishment, so it must appoint a representative established in France, compulsory since 10 July 2026. In practice: one eco-organism membership per stream, a unique identifier (IDU) shown on its sales channels (Amazon France FBA, Cdiscount and ManoMano) and declarations, most of them once a year. EPR Representative takes charge of that registration and those declarations, from €190 a year excl. VAT per stream. An Italian Srl or SpA selling into France is a French EPR producer whenever it is the first to place goods on the French market. EU membership makes no difference: the French mandataire obligation is triggered by not being established in France, not by being outside the EU. Your CONAI participation covers Italy, not France. ## When the obligation starts The trigger is the first placement on the French market, not your country of establishment. An Italian company shipping to French consumers (Amazon.fr, your own shop, Cdiscount) or selling to French buyers who do not take title as importer is the producer under Article L. 541-10 II. In force since 12 August 2026, Article 45 of Regulation (EU) 2025/40 requires a producer that makes packaging available in a member state where it is not established, including from another EU country, to appoint an authorised representative for extended producer responsibility in that member state. ## Why it matters The legal basis: 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. Marketplaces must check the French IDU of their sellers, whatever your Italian registration (Article L. 541-10-9). 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. ## Sales channels Italian brands reach French buyers via Amazon.fr, Cdiscount, ManoMano, and D2C Shopify, often with fashion, furniture, food and homeware catalogues. Shared EU logistics with France do not remove the obligation: goods reaching a French consumer trigger French EPR, separate from CONAI. ## Questions ### We are an EU company, does the single market not exempt us from a French representative? No. The obligation turns on establishment in France, not on EU membership. An Italian company with no French entity that first places products on the French market must appoint a French authorised representative. PPWR Article 45, in force since 12 August 2026, confirms this per Member State. ### Does our CONAI registration cover France? No. CONAI covers Italian packaging obligations only. France requires its own IDU per stream, issued after registration with a French eco-organisation. The Italian and French systems are independent. ### We are the brand but a factory manufactures for us, are we still the producer? Yes. For EPR, the producer is whoever first places the product on the French market under its own name, not the physical manufacturer. Selling your branded goods into France makes you the producer, even if a third-party factory makes them. --- URL: https://eprrepresentative.com/from/poland Last updated: 2026-10-12 # French EPR for companies based in Poland A company based in Poland selling into France has no French establishment, so it must appoint a representative established in France, compulsory since 10 July 2026. In practice: one eco-organism membership per stream, a unique identifier (IDU) shown on its sales channels (Amazon France FBA, Cdiscount and Shopify) and declarations, most of them once a year. EPR Representative takes charge of that registration and those declarations, from €190 a year excl. VAT per stream. A Polish company (sp. z o.o., S.A.) selling into France is a French EPR producer whenever it is the first to place goods on the French market. EU membership makes no difference: what triggers the French mandataire obligation is not being established in France. Your BDO registration covers Poland, not France. ## When the obligation starts The trigger is the first placement on the French market, not your country of establishment. A Polish company shipping to French consumers (Amazon.fr, your own shop, Cdiscount) or selling to French buyers who do not take title as importer is the producer under Article L. 541-10 II. In force since 12 August 2026, Article 45 of Regulation (EU) 2025/40 requires a producer that makes packaging available in a member state where it is not established, including from another EU country, to appoint an authorised representative for extended producer responsibility in that member state. ## Why it matters The legal basis: 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. Marketplaces must check the French IDU of their sellers, whatever your Polish registration (Article L. 541-10-9). 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. ## Sales channels Polish brands reach French buyers via Amazon.fr (including Pan-European FBA from Polish fulfilment centres), Cdiscount, ManoMano and D2C stores. Shipping from a warehouse in Poland does not change the rule: goods reaching a French customer fall under French EPR. ## Questions ### Does my BDO number cover France? No. BDO covers Polish obligations only. France requires its own membership and IDU per stream, with a French eco-organisation. The Polish and French systems are independent. ### We are an EU company, does the single market not exempt us from a French representative? No. The obligation turns on establishment in France, not on EU membership. A Polish company with no French entity that first places products on the French market must appoint a French authorised representative. --- URL: https://eprrepresentative.com/from/belgium Last updated: 2026-10-12 # French EPR for companies based in Belgium A company based in Belgium selling into France has no French establishment, so it must appoint a representative established in France, compulsory since 10 July 2026. In practice: one eco-organism membership per stream, a unique identifier (IDU) shown on its sales channels (Amazon France FBA, Cdiscount and Shopify) and declarations, most of them once a year. EPR Representative takes charge of that registration and those declarations, from €190 a year excl. VAT per stream. A Belgian company (SRL / BV, SA / NV) selling into France is a French EPR producer whenever it is the first to place goods on the French market. A shared border and a shared language change nothing: what triggers the French mandataire obligation is not being established in France. Your Belgian registration covers Belgium, not France. ## When the obligation starts The trigger is the first placement on the French market, not your country of establishment. A Belgian company shipping to French consumers (Amazon.fr, your own shop, Cdiscount) or selling to French buyers who do not take title as importer is the producer under Article L. 541-10 II. In force since 12 August 2026, Article 45 of Regulation (EU) 2025/40 requires a producer that makes packaging available in a member state where it is not established, including from another EU country, to appoint an authorised representative for extended producer responsibility in that member state. ## Why it matters The legal basis: 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. Marketplaces must check the French IDU of their sellers, whatever your Belgian registration (Article L. 541-10-9). 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. ## Sales channels Belgian brands reach French buyers via Amazon.fr, Cdiscount, ManoMano and their own D2C stores, often from a Belgian warehouse. Dispatch from Belgium does not change the rule: goods reaching a French customer fall under French EPR. ## Questions ### Does my Belgian registration cover France? No. Your national register covers Belgian obligations only. France requires its own membership and IDU per stream, with a French eco-organisation. ### We are an EU company, does the single market not exempt us from a French representative? No. The obligation turns on establishment in France, not on EU membership. A Belgian company with no French entity that first places products on the French market must appoint a French authorised representative. --- URL: https://eprrepresentative.com/from/austria Last updated: 2026-10-12 # French EPR for companies based in Austria A company based in Austria selling into France has no French establishment, so it must appoint a representative established in France, compulsory since 10 July 2026. In practice: one eco-organism membership per stream, a unique identifier (IDU) shown on its sales channels (Amazon France FBA, Cdiscount and Shopify) and declarations, most of them once a year. EPR Representative takes charge of that registration and those declarations, from €190 a year excl. VAT per stream. An Austrian company (GmbH, AG) selling into France is a French EPR producer whenever it is the first to place goods on the French market. EU membership makes no difference: what triggers the French mandataire obligation is not being established in France. Your Austrian registration covers Austria, not France. ## When the obligation starts The trigger is the first placement on the French market, not your country of establishment. An Austrian company shipping to French consumers (Amazon.fr, your own shop, Cdiscount) or selling to French buyers who do not take title as importer is the producer under Article L. 541-10 II. In force since 12 August 2026, Article 45 of Regulation (EU) 2025/40 requires a producer that makes packaging available in a member state where it is not established, including from another EU country, to appoint an authorised representative for extended producer responsibility in that member state. ## Why it matters The legal basis: 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. Marketplaces must check the French IDU of their sellers, whatever your Austrian registration (Article L. 541-10-9). 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. ## Sales channels Austrian brands reach French buyers via Amazon.fr, Cdiscount, ManoMano and their own D2C stores. Shipping from Austria or from a German hub does not change the rule: goods reaching a French customer fall under French EPR. ## Questions ### Does my Austrian registration cover France? No. Your national register covers Austrian obligations only. France requires its own membership and IDU per stream, with a French eco-organisation. ### We are an EU company, does the single market not exempt us from a French representative? No. The obligation turns on establishment in France, not on EU membership. An Austrian company with no French entity that first places products on the French market must appoint a French authorised representative. --- URL: https://eprrepresentative.com/from/switzerland Last updated: 2026-10-12 # French EPR for companies based in Switzerland A Swiss company selling to French consumers from a Swiss website or warehouse is the producer for France, even though the goods leave from outside the EU. With no establishment in France, it must appoint a representative established in France, compulsory since 10 July 2026. Swiss recycling-fee memberships cover Switzerland only. One French representative and one written mandate cover all its French streams. A Swiss company (AG / SA, GmbH / Sàrl) selling to French customers is a French EPR producer, even when the order is placed on a Swiss website and the parcel leaves a Swiss warehouse. Switzerland is not in the EU, and the test is establishment in France: with no French entity, the company must appoint a representative established in France. ## Is a Swiss company selling from a Swiss site or warehouse the producer for France? Yes. When a French consumer buys on your Swiss website and receives the parcel in France, your company owns the goods when they enter France and is the producer. Shipping from Switzerland and clearing customs at the border change nothing. The exception is a French buyer that buys the goods and imports them in its own name: it is then the producer for those flows. ## Do the EU-Swiss bilateral agreements exempt a Swiss producer? No. The bilateral agreements do not create an establishment in France, and French law asks one question: is the producer established in France? Switzerland is outside the EU and the EEA, but the answer would be the same for a company established in another EU country: with no French establishment, it must appoint a representative established in France. ## Selling to French businesses: which packaging stream applies to a Swiss producer? Packaging that reaches French businesses falls under the professional packaging stream (EPRO), in force since 1 January 2026, eco-contributions from 1 January 2027, with Citeo Pro, Léko Pro or Twiice. Packaging also sold to consumers counts as household packaging, declared to Citeo or Léko. Registration with a professional packaging eco-organisation is open now. We qualify each reference before the quote: sold to businesses only, or also to consumers. ## Does a Swiss producer need a French representative per stream? No. One representative established in France and one written mandate cover all your French streams, from household packaging to electrical equipment or textile. Each stream keeps its own membership, identifier and declarations, all handled under the same mandate. ## Which Swiss company documents do we need? A commercial register extract (Handelsregister, registre du commerce) less than three months old, your company identification number (IDE / UID, CHE-...) and a bank document. The signatory must hold signing authority on the extract or a written delegation. We never ask for an identity document. The file runs in French or English. ## When the obligation starts The obligation starts with the first product a Swiss company places on the French market: a parcel from a Swiss webshop to a French address, an Amazon.fr order, a delivery to a French retailer that does not import the goods itself. Customs clearance at the border does not move the obligation: if the Swiss company is the seller to the French customer, it is the producer. ## Why it matters Marketplaces selling to French customers must check that their sellers are registered (Article L. 541-10-9 of the French Environmental Code), and a Swiss registration number is not a French identifier. 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. ## Sales channels Swiss brands reach French buyers through their own websites shipping from Switzerland, Amazon.fr, Cdiscount and B2B distribution. Where a French distributor buys the goods and imports them in its own name, the distributor is the producer for those flows; where the Swiss company sells directly, it is. ## Questions ### Switzerland is not in the EU. Does French EPR still apply to us? Yes. French EPR applies to whoever first places the product on the French market, inside or outside the EU. A Swiss company with no establishment in France must appoint a representative established in France. ### Does a Swiss recycling-fee membership cover France? No. Swiss systems cover products sold in Switzerland. France requires its own membership and identifier per stream with a French eco-organisation. ### Does the PPWR authorised representative rule apply to Swiss companies? In force since 12 August 2026, Article 45 of Regulation (EU) 2025/40 requires a producer that makes packaging available in a member state where it is not established, including from another EU country, to appoint an authorised representative for extended producer responsibility in that member state. A Swiss producer is not established in France, so the rule applies for France, and again in each other EU country where it makes packaging available. --- URL: https://eprrepresentative.com/from/hong-kong Last updated: 2026-10-12 # French EPR for companies based in Hong Kong A Hong Kong company, often a trading company selling Chinese-made electronics, toys or gifts, is the producer for France when it sells to French customers or to French buyers that do not import the goods themselves. With no establishment in France, it must appoint a representative established in France, compulsory since 10 July 2026. Its Hong Kong registration documents are usually already in English. Hong Kong companies often sit between Chinese factories and European customers. When the Hong Kong company is the seller to French customers, on Amazon.fr or to French buyers that do not import the goods themselves, it is the producer for French EPR and, with no establishment in France, must appoint a representative established in France. ## Why France Hong Kong trading companies reach France in two ways: as sellers of record on Amazon.fr, Cdiscount or their own stores, and as suppliers to French importers and retailers. Only the first makes the Hong Kong company the producer. Where a French importer buys the goods and imports them in its own name, the importer is the producer for those flows. ## Points specific to Hong Kong ### Is the Hong Kong trading company or the mainland factory the producer? The producer is whoever owns the goods when they enter France. If the Hong Kong company sells to the French customer or holds the Amazon.fr seller account, it is the producer and signs the mandate, even when the goods ship straight from a mainland factory. The factory becomes the producer only if it sells to the French customer itself. Where a French importer buys the goods and imports them in its own name, the importer is the producer for those flows. ### Temu, Shein, AliExpress, TikTok Shop: who is the producer for a Hong Kong seller? It depends on who owns the goods when they enter France. If the platform buys your goods before they enter France, it is the producer for them; if it sells in your name while the goods are still yours, the Hong Kong company is the producer, whether the stock leaves from China, Hong Kong or a warehouse in Europe. Platforms run several selling models, so we do not assume which one is yours: we read your seller agreement and your shipping flows before the quote. A platform that takes on EPR for the products it sells for you (Article L. 541-10-9) covers only those products and only while you are not registered; your own store, other marketplaces and sales to businesses stay yours. ### Can a Hong Kong agent act as the French representative? No. The representative must be established in France (Article L. 541-10-9-1 of the French Environmental Code). A Hong Kong sourcing agent or trading company can introduce the brand owner to a French representative, but cannot hold that role itself. ### Which streams do Hong Kong trading companies usually trigger? Electrical and electronic equipment and batteries for gadgets, chargers and lighting; toys; and household packaging for nearly everything sold to consumers. Gift and seasonal ranges often mix several streams in one shipment, so we map them reference by reference before the quote. ## Questions ### Does any Hong Kong registration cover France? No. Nothing registered in Hong Kong counts for French EPR. France requires its own membership and identifier per stream with a French eco-organisation, filed through a representative established in France. ### My Hong Kong business is a partnership, not a limited company. Same regime? Yes. Any business placing products on the French market is a producer for French EPR, whatever its legal form. Only the documents change: the partnership records replace the Companies Registry record. ### Do I need a French bank account? No. You pay our fee by international transfer from any bank. Eco-contributions are a separate cost, set by the eco-organisation on its published schedule and invoiced to you by it directly; we take no percentage on them. --- URL: https://eprrepresentative.com/from/singapore Last updated: 2026-10-12 # French EPR for companies based in Singapore A Singapore company selling into France, often as a regional hub for goods made elsewhere in Asia, is the producer when it is the seller to the French customer. With no establishment in France, it must appoint a representative established in France, compulsory since 10 July 2026. Singapore’s Mandatory Packaging Reporting covers Singapore only. An ACRA business profile in English supports the file. Singapore companies often act as the regional hub for goods made elsewhere in Asia. When the Singapore company is the seller to French customers, it is the producer for French EPR, whatever the country of manufacture, and with no establishment in France it must appoint a representative established in France. ## Why France Singapore companies sell into France as brand owners shipping D2C or through Amazon.fr, and as hubs supplying French distributors. The French producer is the entity that sells to the French customer: often the Singapore company, sometimes a French importer that buys the goods and imports them in its own name. ## Points specific to Singapore ### Does Singapore’s Mandatory Packaging Reporting cover French obligations? No. Mandatory Packaging Reporting under Singapore’s Resource Sustainability Act concerns packaging placed on the Singapore market. It has no effect in France, where household packaging is registered with Citeo or Léko and declared to them. ### Amazon.fr, your own store or a French distributor: who is the producer for each channel? The producer is whoever owns the goods when they enter France. On Amazon.fr and on your own store shipping to French addresses, that is the Singapore company; with a French distributor that buys the goods and imports them in its own name, it is the distributor. Stock held for you by a 3PL or by Amazon stays yours, wherever the warehouse is. If the goods are made in Vietnam or China and sold by the Singapore company, the country of manufacture plays no part: the upstream factory that sells to the Singapore hub is not the French producer. ### Does the EU-Singapore trade agreement change EPR? No. The EU-Singapore Free Trade Agreement, in force since 21 November 2019, deals with tariffs and trade rules. French EPR is a French environmental obligation and applies in the same way to Singapore producers. ## Questions ### Does my Singapore packaging reporting cover France? No. Singapore’s reporting covers packaging placed on the Singapore market. France requires its own membership and identifier per stream with a French eco-organisation. ### I use a Singapore holding with a Hong Kong operating subsidiary. Who is the producer? The entity that sells to the French customer or marketplace and transfers title to the goods, usually the operating subsidiary. A holding company is the producer only if it sells into France itself. --- URL: https://eprrepresentative.com/from/australia Last updated: 2026-10-12 # French EPR for companies based in Australia An Australian company selling into France, typically a beauty, wellness, fashion or outdoor brand shipping D2C or through Amazon.fr, has no French establishment, so it must appoint a representative established in France, compulsory since 10 July 2026. APCO membership covers Australia only. An ASIC extract and the ABN support the file, and everything runs in writing, which suits the time difference with Paris. Australian brands in beauty, wellness, fashion, swimwear and outdoor gear often reach France through their own stores and Amazon.fr. With no establishment in France, an Australian company selling to French customers must appoint a representative established in France. The work runs in writing, which suits the time difference with Paris. ## Why France Australian brands sell into France mostly direct: their own Shopify stores shipping from Australia or from an EU 3PL, and Amazon.fr. Some also supply French retailers. A brand that ships from Australia to a French consumer is the producer for France even though the goods never pass through a French warehouse. ## Points specific to Australia ### Does APCO membership cover French obligations? No. Membership of the Australian Packaging Covenant Organisation concerns packaging placed on the Australian market. France requires its own household packaging membership, with Citeo or Léko, and its own identifier. ### Your own store, Amazon.fr or a French retailer: who is the producer for each channel? The producer is whoever owns the goods when they enter France. A brand shipping from Australia or from an EU 3PL to a French consumer, or selling on Amazon.fr, is the producer; a French retailer that buys the goods and imports them in its own name is the producer for those flows. The goods never need to pass through a French warehouse: a parcel from Australia to a French address places them on the French market. Orders on Amazon UK delivered to UK customers are not French sales. ### Which streams do Australian D2C brands usually trigger? Household packaging for almost every consumer product, textile for clothing, swimwear and shoes, and sports and leisure goods for outdoor and fitness equipment. Skincare and supplements usually trigger packaging alone. One mandate covers all of them. ### How does the file work across the time difference? In writing. Questions, the scope review and the written quote go by email, and the mandate is signed online, so nothing waits for overlapping office hours. Our written replies come within one business day, in English or French. ## Questions ### Does my APCO membership cover France? No. APCO covers the Australian market. France requires its own membership and identifier per stream with a French eco-organisation, filed through a representative established in France. --- URL: https://eprrepresentative.com/from/india Last updated: 2026-10-12 # French EPR for companies based in India An Indian exporter selling directly into France, most often apparel, home linen, handicrafts, furniture or cosmetics, is the producer when it sells to French customers or to buyers that do not import the goods themselves. With no establishment in France, it must appoint a representative established in France, compulsory since 10 July 2026. Indian EPR registrations under the plastic or e-waste rules do not cover France. Indian exporters of apparel, home linen, handicrafts, furniture and cosmetics usually sell to French importers, and increasingly to French consumers through Amazon.fr and their own stores. When the Indian company is the seller to the French customer, it is the producer for French EPR and must appoint a representative established in France. ## Why France Most Indian exporters reach France through French importers and brands, which buy the goods and are the producers for them. The position changes when the Indian company sells directly: Amazon.fr, its own store shipping to French addresses, or consignment stock that it still owns when a French customer buys. ## Points specific to India ### Do Indian EPR registrations cover French obligations? No. Registrations under India’s Plastic Waste Management Rules or E-Waste (Management) Rules 2022 concern products placed on the Indian market. France has its own system, with one membership and one identifier per stream. ### Selling to a French brand, on Amazon.fr or on consignment: who is the producer for each channel? The producer is whoever owns the goods when they enter France. When a French brand or importer buys the garments and imports them in its own name, it is the producer; when the Indian company sells on Amazon.fr, from its own store or keeps ownership of consignment stock until a French customer buys, the Indian company is. Most Indian textile exporters selling to French brands therefore need no French EPR for those flows: the French brand declares them to Refashion. French EPR applies only to what the Indian company sells to French customers itself. ### Which streams do Indian exporters usually trigger when they sell direct? Textile (Refashion) for clothing, shoes and home linen; furniture for wooden and metal furniture and some decorative items; household packaging for everything sold to consumers. One mandate covers all of them, each stream with its own membership and identifier. ## Questions ### Does my Indian EPR registration cover France? No. Indian plastic packaging and e-waste registrations cover the Indian market. France requires its own membership and identifier per stream with a French eco-organisation. ### I only sell within India or to markets other than France. Do I need French EPR? No. French EPR applies only to products placed on the French market. It starts with your first sale to a French customer, for example on Amazon.fr. --- URL: https://eprrepresentative.com/from/japan Last updated: 2026-10-12 # French EPR for companies based in Japan A Japanese company selling into France through Amazon.fr, Rakuten France or its own store, often cosmetics, electronics, kitchenware or character goods, has no French establishment, so it must appoint a representative established in France, compulsory since 10 July 2026. Japan’s Containers and Packaging Recycling Law covers Japan only. The registry extract needs an English or French translation. Japanese companies selling cosmetics, electronics, cameras, kitchenware, stationery or character goods to French customers, through Amazon.fr, Rakuten France or their own stores, are producers for French EPR. With no establishment in France, they must appoint a representative established in France. We work in writing, in English and French. ## Why France Japanese brands reach France through Amazon.fr, Rakuten France, their own stores shipping from Japan or from an EU 3PL, and French distributors and department stores. Where a French distributor buys and imports the goods, it is the producer for them; direct sales stay with the Japanese company. ## Points specific to Japan ### Your French distributor may be the producer, not you: how do you tell? If your French distributor buys the goods and imports them in its own name, it is the producer and declares them. If you sell directly to French consumers, or keep ownership of the goods until they are in France, you are the producer and need a representative established in France. Many Japanese brands have both flows at once: a distributor or department store for part of the range, Amazon.fr, Rakuten France or their own store for the rest. We map each channel before the quote, so you register only what is yours. ### Does Japan’s Containers and Packaging Recycling Law cover France? No. The Japanese law concerns packaging used for products sold in Japan. Packaging on products sold to French consumers is registered in France, with Citeo or Léko, and declared there. ### Which streams do Japanese electronics and cosmetics sellers usually trigger? Electrical and electronic equipment plus batteries for cameras, audio and small appliances; household packaging for cosmetics and almost everything else sold to consumers; toys for figures and games that are toys within the French scope. One mandate covers them all. ### Does the EU-Japan Economic Partnership Agreement change EPR? No. The agreement, in force since 1 February 2019, deals with tariffs and trade rules. French EPR is a French environmental obligation and applies to Japanese producers in the same way. ## Questions ### Does my Japanese packaging recycling compliance cover France? No. Compliance under the Japanese Containers and Packaging Recycling Law covers Japan only. France requires its own membership and identifier per stream with a French eco-organisation. ### Can we correspond in Japanese? No. We work in writing, in English and French only. The mandate, our replies and the eco-organisation files are in one of these two languages. --- URL: https://eprrepresentative.com/from/south-korea Last updated: 2026-10-12 # French EPR for companies based in South Korea A South Korean company selling K-beauty, K-fashion or electronics into France, through Amazon.fr, its own store or a French retailer that does not import the goods itself, must appoint a representative established in France, compulsory since 10 July 2026. Korean EPR covers Korea only. For cosmetics, household packaging is the usual stream; electronics and batteries add their own. Korean brands, from K-beauty and K-fashion to electronics and small appliances, sell to French customers through Amazon.fr, their own stores and French retailers. When the Korean company is the seller to the French customer, it is the producer for French EPR and must appoint a representative established in France. ## Why France Korean beauty and fashion brands reach France through Amazon.fr, their own stores shipping from Korea or from an EU 3PL, and French beauty retailers and distributors. Where a French distributor buys and imports the goods, it is the producer for them; direct sales stay with the Korean company. ## Points specific to South Korea ### Your French distributor may be the producer, not you: how do you tell? If your French distributor or retailer buys the goods and imports them in its own name, it is the producer and declares them. If you sell directly to French consumers, or keep ownership of the goods until they are in France, for example on consignment, you are the producer and need a representative established in France. K-beauty and K-fashion brands often run both flows: a French retailer for part of the range, Amazon.fr or their own store for the rest. We map each channel before the quote, so you register only what is yours. ### Which stream does a K-beauty brand trigger in France? Household packaging: jars, tubes, pumps, boxes and mailers, registered with Citeo or Léko. The cosmetic product itself has no EPR stream. Cosmetics rules (notification, responsible person) are a separate regime that we do not handle. ### Does Korean EPR cover French obligations? No. Korea’s EPR system concerns products placed on the Korean market. France requires its own membership and identifier per stream, filed through a representative established in France. ## Questions ### Does my Korean EPR registration cover France? No. The Korean system covers the Korean market. France requires its own membership and identifier per stream with a French eco-organisation. ### Do you handle the cosmetics responsible person and notification as well? No. We act for French EPR only. Cosmetics product compliance is a separate role that a different provider takes on. --- URL: https://eprrepresentative.com/from/turkey Last updated: 2026-10-12 # French EPR for companies based in Turkey A Turkish company selling apparel, home textile, appliances or ceramics directly to French customers, or to French buyers that do not import the goods themselves, must appoint a representative established in France, compulsory since 10 July 2026. The EU-Turkey Customs Union removes duties on many goods but does not make a Turkish company established in France. The trade registry documents need a translation. Turkish exporters of apparel, home textile, appliances, ceramics and furniture usually supply French importers and brands. When the Turkish company sells directly, on Amazon.fr, Cdiscount, ManoMano or its own store, it becomes the producer for French EPR and must appoint a representative established in France. ## Why France Most Turkish exports to France go through French importers, brands and retailers, which buy the goods and are the producers for them. Turkish companies that sell directly, through Amazon.fr, Cdiscount, ManoMano or their own stores, take on French EPR for those sales. ## Points specific to Turkey ### Does the EU-Turkey Customs Union exempt a Turkish producer? No. The Customs Union, set up in 1995, removes customs duties on industrial goods, but it does not make a Turkish company established in France. French EPR asks only that question: is the producer established in France? ### Private label, a French wholesaler or direct sales: who is the producer for each channel? The producer is whoever owns the goods when they enter France. When a French brand or wholesaler buys the goods and imports them in its own name, it is the producer; when the Turkish company sells on Amazon.fr, Cdiscount, ManoMano or its own store, the Turkish company is. A Turkish private-label manufacturer therefore needs French EPR only for what it sells to French customers itself. Confirm in each contract who owns the goods when they enter France. ### Which streams do Turkish apparel and appliance exporters trigger when they sell direct? Textile (Refashion) for clothing, shoes and home linen; electrical and electronic equipment for household appliances; furniture; and household packaging for products sold to consumers. One mandate covers all of them. ## Questions ### Does any Turkish registration cover France? No. Nothing registered in Turkey counts for French EPR. France requires its own membership and identifier per stream with a French eco-organisation. --- URL: https://eprrepresentative.com/blog/french-epr-representative-mandatory-law-2026-602 Last updated: 2026-10-12 # Appointing a French EPR Representative Is Now Compulsory: Law n° 2026-602 and Article L. 541-10-9-1 Since 10 July 2026, any producer with no establishment in France, whether based elsewhere in the EU or outside it, must appoint a France-established representative by written mandate. The rule covers all 19 French streams, reaches online marketplaces that are not established in France, and does not depend on PPWR. The text, its scope, and how to regularise an existing membership that has no representative on file. On 10 July 2026, France changed the nature of the question "do I need a French EPR representative?". Until that date, appointing a *mandataire REP* was an **option** opened to foreign producers by the AGEC framework: practical, usually the only workable route, but not a written obligation. Since then it is a **statutory obligation**. This article covers the text, its exact scope, what the representative takes charge of and what stays with you, the marketplace case, and the regularisation path for producers whose eco-organism file carries no representative. ## What does the text say? **Law n° 2026-602 of 8 July 2026** on reducing the environmental impact of the textile industry, known as the **"Fast Fashion" law**, was published in the **Journal officiel n° 0159 of 9 July 2026** (NOR TECX2407166L). Its article 5, 2° created **Article L. 541-10-9-1 of the *Code de l'environnement***, in force on **10 July 2026**. The title of the law is misleading. The measure is **horizontal**: it does not concern textiles alone, it applies to **every French EPR stream**, nineteen of them today, from household packaging to professional packaging, from WEEE to tyres. What the article says, in substance: any person **not established on French territory** who is subject to Extended Producer Responsibility under Article L. 541-10 or L. 541-10-9 shall appoint, **by written mandate**, a natural or legal person **established in France** to ensure compliance with its EPR obligations; and the appointment obligation is treated as satisfied for products in respect of which a person covered by Article L. 541-10-9 and established in France ensures that compliance. ## Who is covered, and who is not? The test is **establishment in France**. Not nationality, not EU membership, not where you ship from. **Covered:** - Producers established **outside the European Union**: United States, United Kingdom, China, Switzerland, Turkey and everywhere else. - Producers established **in another EU Member State** with no French establishment. A German GmbH, a Spanish SL or an Italian Srl selling into France from home is in exactly the same position as a US seller. This is the most frequently missed point, because the topic circulated for years labelled "an obligation for non-EU sellers". - **Online intermediation platforms** not established in France that fall within Article L. 541-10-9 (see below). **Not covered:** producers **established in France**. A French company declares in its own name, has no representative to appoint, and stays under the earlier regime. If it outsources the preparation and filing of its declarations, that is a contractual arrangement, not a statutory mandate, and the obligations stay its own. The trigger remains **making products available on the French market**, not the channel. Marketplace sales, your own store, shipping from abroad, stock held in France, B2B sales: the analysis is the same, stream by stream. ## What are the three conditions of the mandate? The text sets three cumulative requirements, and each of them can be checked before you sign. **A representative established in France.** The text refers to a **natural or legal person** established on French territory. A pan-EU provider running the French leg through an undisclosed sub-provider does not meet that condition in any verifiable way: ask who the France-established person is, and under which SIREN number it appears on the file. **A written mandate.** The appointment is not presumed and does not follow from a purchase order or an email exchange. It is a written mandate under Article L. 541-10-9-1 of the *Code de l'environnement*, signed, dated, with an identified scope. Electronic signature is fine, no notary is needed. **An accepted, delimited scope.** The representative ensures compliance with the obligations it accepts in the mandate. The accepted scope is therefore a **contract clause**, not a general formula: which streams, which tasks, effective date, duration. A mandate that stays vague on this is one whose scope you will discover during an inspection. ## What does the representative take charge of, and what stays with you? 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. Three limits frame the mandate. **It is bounded by the accepted scope.** Streams you did not entrust stay yours. A packaging mandate does not cover your batteries or your textiles. **It runs from its effective date.** Earlier years are a separate question. Registration is due from your first sale in France, and eco-organisations can claim contributions for earlier years: up to five years at Refashion (the current year and four previous ones), three at Ecomaison, Ecosystem and Valobat, one at Citeo, none at Léko. Identifiers are never backdated. We tell you before signing whether earlier years are at stake. A representative promising to erase the past is promising something the statute does not allow. **You keep producer status.** You remain the producer within the meaning of Article L. 541-10, and you answer for the **accuracy of the data** you provide. The representative declares what you give it; if the tonnages are wrong, responsibility for the data has not moved. ## Why did Parliament have to legislate? On **10 November 2023**, in case n° 449213, known as the **EcoDDS** ruling, the Conseil d'État annulled Article R. 541-174 of the *Code de l'environnement* insofar as it transferred the producer's EPR obligations to the representative. The objection was that **modifying obligations between operators belongs to statute** under Article 34 of the French Constitution, not to a decree. The annulment took immediate effect, with no deferral. The legislator picked the file back up at the level the court had identified, for producers not established in France: since 10 July 2026, Article L. 541-10-9-1 sets their regime in a statute. The EcoDDS ruling now only concerns producers established in France. Our [analysis of the EcoDDS ruling](/blog/ecodds-conseil-detat-ruling-civil-mandate) sets out the reasoning. **The purpose of the measure** is easy to state: to give the authorities a **jurisdictional grip** on any operator making EPR products available on the French market. Without a French establishment, a foreign producer is hard to inspect and harder still to prosecute. With a France-established representative, the administration has a counterpart on French territory, under French law. That also explains the twin requirements of establishment and writing, and why a serious mandate provides a security deposit. ## How does it apply to marketplaces? Article L. 541-10-9-1 covers persons subject to EPR under Article L. 541-10 **or Article L. 541-10-9**. That second reference is the one for online intermediation platforms that facilitate distance sales or the delivery of products on behalf of third-party sellers and are required, on that basis, to provide for or contribute to the management of the resulting waste. **First direction: a platform not established in France is itself obligated.** A marketplace falling within Article L. 541-10-9 and not established in France must appoint its own France-established representative. The obligation therefore does not stop at brands and manufacturers: it reaches intermediaries too. **Second direction: a France-established platform can cover your products.** The text provides that the appointment obligation is treated as satisfied for products in respect of which a person covered by Article L. 541-10-9 and **established in France** ensures compliance with the EPR obligations. In practice, where a France-established platform genuinely takes on compliance for the products it sells for you, that perimeter is covered. Two common-sense caveats on that second point. The cover is **per product and per stream**, not global: a platform handling the packaging of your shipments is not handling the WEEE stream for your devices. And it only holds **for that channel**: the moment you sell elsewhere, your own store, another marketplace, a French distributor, the uncovered perimeter is yours again. Confirm it in writing with the platform rather than treating it as a working assumption. ## Your file carries no representative: how do you regularise? A frequent case, and rarely addressed. Eco-organisms have long required a French counterpart to open a membership, which is why a producer with no establishment in France generally cannot complete a registration alone. Even so, some reached a membership and an IDU before 10 July 2026 without a representative being recorded on the file. That position no longer satisfies the statute: the membership exists, but appointing a representative is now required by law. Regularisation runs in five steps, and the **IDU does not have to be lost**: it is a file update, not a re-registration. 1. **Identify a France-established representative** for the streams concerned, and check it covers your whole perimeter rather than a single stream. 2. **Conclude the written mandate**, with an identified scope, an effective date and a duration. 3. **Send the mandate to the eco-organism** so it updates your membership: that transmission is what makes the representative exist on the file. 4. **Have the representative sign or take over the membership contract**, stream by stream, with each eco-organism concerned. 5. **Let the eco-organism update the membership data in SYDEREP**, the ADEME register, so the published IDU reflects the new arrangement. Starting from scratch follows the same path without the takeover step. It depends on the eco-organisation. Citeo issues the identifier about seven business days after the membership is validated. Léko issues it about five business days after its initial invoice is paid; that invoice must be paid within five business days, otherwise the membership is cancelled. Refashion issues it after membership, the signed contract and your first declaration and payment, then about ten business days. Ecosystem issues it after your first declaration has been filed and paid. Professional packaging (EPRO): registration is open now, eco-contributions from 1 January 2027. We file your membership within two business days of receiving the signed mandate, the first invoice payment and the deposit. Changing representative is a neighbouring but distinct question, covered in our guide on [switching French EPR representative without losing your IDU](/blog/switch-french-epr-representative-without-losing-idu). ## How does it interact with PPWR and the Omnibus proposal? Two texts overlap, and they do not cover the same ground. Latest state of play on the EU procedure: [EU Omnibus and the EPR authorised representative, what changes and what does not](/blog/eu-omnibus-epr-authorised-representative-france). | | Article L. 541-10-9-1 | PPWR Article 45 | |---|---|---| | Nature | French statute | Regulation (EU) 2025/40 | | Date | In force since 10 July 2026 | Applicable since 12 August 2026 | | Scope | All 19 French EPR streams | Packaging only | | Geography | France | Each Member State where the producer is not established | Since 12 August 2026, Article 45 of Regulation (EU) 2025/40 requires a producer that makes packaging available in a member state where it is not established, including from another EU country, to appoint an authorised representative for extended producer responsibility in that member state. The European Commission's environmental Omnibus proposal is still in the legislative procedure and has no legal effect. The French obligation of Article L. 541-10-9-1 applies today. Our [PPWR timeline 2026-2040](/blog/ppwr-timeline-2026-2040-deadlines-producers) tracks where the proposal stands. ## What does it mean for your mandate contract? If you already have a representative, there is a simple test: **reread the template**. A contract drafted before July 2026 and left unchanged almost certainly rests on the pre-2026 regime and does not cite Article L. 541-10-9-1. For a producer not established in France, that drafting is out of date. Four points belong in an up-to-date mandate: - The **scope of the mandate** under Article L. 541-10-9-1: which streams, which tasks. - Its **effective date**, with the pre-mandate period addressed explicitly. - The **duration** of the mandate and how it ends, including what happens to the IDU. - The **security deposit** attached. On our side that last point takes this form: a refundable security deposit equal to one year of your estimated eco-contributions, at least the eco-organisation's minimum billing, paid once by separate transfer to a dedicated account, never invoiced. It covers sums left unpaid under the mandate and is returned within sixty days of the end of the mandate, once the last contributions are paid. Our fee is a fixed annual amount per stream, **from €190 excl. VAT per year** for a stream under an eco-organism flat-rate regime, confirmed by written quote within one business day, with a one-time setup 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. We take **no percentage and no margin** on eco-contributions, and none on eco-organism membership fees either. The detail is on [our pricing page](/pricing). ## What should you do now? 1. **Settle the establishment question.** Do you have a legal entity in France, or only sales into France? The answer drives everything else. 2. **Map your streams.** A consumer catalogue typically touches two to four: packaging, often WEEE or batteries, sometimes textile or furniture. The [eco-contribution simulator](/tools/eco-contribution-simulator) gives an order of magnitude stream by stream. 3. **Check your existing memberships.** Direct membership with no representative, or a representative on file? If it is the former, plan the five-step regularisation above. 4. **Audit your mandate contract**, if you have one, against the four points listed above. 5. **Confirm in writing what each platform actually covers**, product by product and stream by stream, before relying on the exemption clause. If you want the position on your own facts, [tell us your streams and channels](/get-registered) and you will get a fixed written quote within one business day. ## Sources & references The wording of the obligation is that of law n° 2026-602 of 8 July 2026 as published in the Journal officiel n° 0159 of 9 July 2026. This is not legal advice. Verified 4 August 2026. - [LOI n° 2026-602 du 8 juillet 2026 visant à réduire l'impact environnemental de l'industrie textile, Légifrance](https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000054399113), article 5, 2°, creating Article L. 541-10-9-1 du Code de l'environnement (NOR TECX2407166L), in force 10 July 2026 - [JORF n° 0159 of 9 July 2026, Légifrance](https://www.legifrance.gouv.fr/jorf/jo/2026/07/09/0159) - [Article L. 541-10 du Code de l'environnement (general EPR framework), Légifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000049464284) - [Article L. 541-10-9 du Code de l'environnement (marketplace obligations), Légifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000041599049/2022-01-01) - [Cabinet Gossement, analysis of law n° 2026-602 of 8 July 2026](https://www.gossement-avocats.com/blog/fast-fashion-mode-ultra-express-decryptage-de-la-loi-n2026-602-du-8-juillet-2026-visant-a-reduire-limpact-environnemental-de-lindustrie-textile/) - [Ministry for Ecological Transition, FAQ on applying the EPR reform to marketplaces (Article L. 541-10-9)](https://www.ecologie.gouv.fr/sites/default/files/documents/FAQ%20place%20de%20marché%20L541-10-9%20.pdf) - [Regulation (EU) 2025/40 (PPWR), EUR-Lex](https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng), Article 45, applicable since 12 August 2026 - [SYDEREP, public producer register (ADEME)](https://www.syderep.ademe.fr/) --- URL: https://eprrepresentative.com/blog/french-epr-idu-number-foreign-companies-guide Last updated: 2026-10-12 # The French EPR IDU Number Explained: A Complete Guide for Foreign Companies The IDU is the identifier that proves your French EPR registration, one per stream. What it is, how it is issued, where it must appear, what changes it and how marketplaces check it. The IDU is the French EPR registration number: one per producer and per stream, recorded in ADEME's register once an approved eco-organisation accepts your membership. A foreign company without a French establishment obtains it through a France-established representative ([Article L. 541-10-9-1](https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000054399113), since 10 July 2026) and must show it in its French terms of sale. Sooner or later a marketplace, a business customer or an inspector asks for it. This guide covers what the IDU is, where it comes from, where it must appear, what changes it, and how marketplaces check it. ## What does IDU stand for, and what is it? *Identifiant unique*, or unique identifier: the number that proves a producer is registered for a given EPR stream. Every producer of products covered by a French EPR stream needs one per stream it operates in. It is an alphanumeric code issued for one producer in one stream. It does not need renewing each year: it stays valid while your eco-organisation membership is active, and lapses if that membership ends. The IDU is **attached to the producer**, not to the representative. If you change French representative, your IDU stays with you. If you later set up a French subsidiary that becomes the seller of record, that subsidiary is a different legal entity and registers with its own IDU. ## Where does the IDU come from? From the national register of producers created by Article L. 541-10-13 of the *Code de l'environnement* (AGEC law of 10 February 2020) and run by ADEME through its [SYDEREP](https://www.syderep.ademe.fr/) service. The eco-organisation you join triggers the registration. The path runs as follows: 1. You sign a written mandate with a France-established representative (required since 10 July 2026 for any producer not established in France, EU or not). 2. Your representative files your membership with the relevant eco-organisation (Citeo or Léko for household packaging, Ecosystem for WEEE, and so on; for textile, you sign the Refashion membership and we act as your declaring facilitator under your power of attorney). 3. The eco-organisation accepts the membership and issues a membership certificate (*attestation d'adhésion*). 4. The registration reaches ADEME's register and the IDU is issued. 5. The IDU becomes searchable on SYDEREP. How long does it take? It depends on the eco-organisation. Citeo issues the identifier about seven business days after the membership is validated. Léko issues it about five business days after its initial invoice is paid; that invoice must be paid within five business days, otherwise the membership is cancelled. Refashion issues it after membership, the signed contract and your first declaration and payment, then about ten business days. Ecosystem issues it after your first declaration has been filed and paid. Professional packaging (EPRO): registration is open now, eco-contributions from 1 January 2027. We file your membership within two business days of receiving the signed mandate, the first invoice payment and the deposit. ## Does one IDU cover every stream? No. IDUs are assigned per stream, not per company, and this is the most common confusion among foreign sellers. A seller of electronic devices in retail packaging needs **at least three**: - WEEE (through Ecosystem or Ecologic) - Batteries (through Ecosystem, which we recommend, or Batribox) - Household packaging (through Citeo, Léko or Adelphe) Each IDU has its own eco-organisation, declaration calendar and marketplace field. A seller registered for packaging only can still be blocked for a missing WEEE identifier. Map your products against the 19 French EPR streams before registering; most foreign e-commerce sellers need two to four IDUs, all handled under one mandate. ## Where must you display the IDU? In your French terms of sale, which the law requires, and on every marketplace that asks for it. Invoices and storefront footers are good practice. **Your terms of sale (CGV).** Article R. 541-173 of the *Code de l'environnement* requires producers to state their IDU in their terms of sale or, failing those, in any other contractual document given to the buyer, and on their website if they have one. List each IDU with its stream. **Amazon Seller Central.** The EPR section of the compliance settings asks for the identifier and the eco-organisation for each French stream. Amazon checks it; Seller Central states its current policy. **ManoMano, Cdiscount, Fnac Marketplace, TikTok Shop France.** Each has its own compliance portal and asks for the same thing: the IDU per stream, with the eco-organisation named. **Invoices and B2B documentation.** Showing the IDU on invoices and order confirmations helps business customers, who often ask for it in supplier compliance files. **Not on the product.** The IDU does not go on the product. Household packaging carries the Triman logo and *Info-tri* instead. ## What happens when something changes? Most changes are routine if handled in order. The IDU only changes when the producer or the eco-organisation changes. **You change French representative.** Your IDU stays. The eco-organisation file changes contact; the membership continues and marketplaces keep checking the same number. See [switching representative without losing your IDU](/blog/switch-french-epr-representative-without-losing-idu). **You switch eco-organisation within a stream** (Citeo to Léko for household packaging, for example). Permitted, since both are approved for the stream. Terminate one membership, sign the other, then update the marketplaces with the new eco-organisation and, if one is issued, the new IDU. **You add a product category.** If it falls under a new stream, you register for that stream and receive an additional IDU. Add it to your terms of sale and to the marketplaces. **A marketplace rejects a valid IDU.** Usually a name mismatch or a membership in transition. Send the membership certificate as backup and ask your representative to raise it with the eco-organisation. See [IDU not recognised on Amazon France](/guides/idu-not-on-amazon-france). **The eco-organisation ends your membership.** Rare, and usually linked to unpaid contributions or serious declaration failures. Without an active membership the IDU no longer proves registration, and marketplaces suspend listings. ## How do you verify your IDU? Search for it on [SYDEREP](https://www.syderep.ademe.fr/) by legal name or by number. The record shows the producer name as registered, the IDU, the stream and the eco-organisation. The registered name is what marketplaces compare against, character for character. Check that the name on SYDEREP matches the legal name on your marketplace account exactly before any upload; a mismatch is a common cause of failed checks. ## Why does a new IDU show as "not found"? Because publication lags approval. The eco-organisation accepts the membership, the registration reaches ADEME, then the IDU becomes searchable on SYDEREP; a marketplace can return "not found" in between. Do not upload during that gap: repeated failed checks can flag your account. The timing depends on the eco-organisation: about seven business days after the membership is validated at Citeo; about five business days after the initial invoice is paid at Léko (payable within five business days, otherwise the membership is cancelled); after the signed contract, the first declaration and its payment, then about ten business days, at Refashion; after the first declaration has been filed and paid at Ecosystem. ## What do marketplaces actually check? That the IDU exists, belongs to your company, and covers the stream of each product you list. A WEEE identifier does not unlock packaging-only listings, and a battery identifier does not unlock furniture. When a check fails, the marketplace sends a compliance notice through Seller Central or its equivalent, with a deadline to fix it before listings are removed. Answer the first notice promptly: prevention is faster than recovery. ## Is an IDU the same as an EU product-safety or VAT number? No. The IDU proves EPR registration in France only. An EU Responsible Person or Authorised Representative covers product safety, and a VAT number or fiscal representative covers tax; neither produces an IDU. See [EPR representative vs EU authorised representative](/epr-representative-vs-eu-authorised-representative). ## How do you obtain your IDU as a foreign seller? Through a representative established in France; registering alone from outside France is no longer an option. 1. **Appoint a representative.** 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. 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. 2. **Eco-organisation membership.** We file your membership within two business days of receiving the signed mandate, the first invoice payment and the deposit. 3. **IDU issuance.** On each eco-organisation's timing: about seven business days after the membership is validated at Citeo, about five business days after the initial invoice is paid at Léko (that invoice is due within five business days, otherwise the membership is cancelled), after the first declaration has been filed and paid at Ecosystem. 4. **Publication.** Add the IDUs to your terms of sale, then to every French marketplace where you sell. For Amazon.fr, the eight steps from stream to Seller Central are in [how to get a French IDU for Amazon France](/guides/how-to-get-french-idu-amazon-france). ## Frequently asked questions ### What is a French EPR IDU and how does a foreign company get one? The IDU (identifiant unique) is the registration number recorded in ADEME's producer register for each producer and each EPR stream, once an approved eco-organisation accepts the membership. A company with no French establishment obtains it through a France-established representative, compulsory since 10 July 2026. It must appear in your French terms of sale, and marketplaces check it against SYDEREP. ### Does one IDU cover every EPR stream a company sells into? No. IDUs are assigned per stream, not per company. A foreign seller of electronic devices in retail packaging typically needs three: WEEE, batteries and household packaging, each with its own eco-organisation and declaration calendar. One representative and one mandate still cover all three. ### How long does it take to get an IDU after signing with a French representative? It depends on the eco-organisation. Citeo issues the identifier 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), Refashion after membership, the signed contract and your first declaration and payment, then about ten business days, and Ecosystem after your first declaration has been filed and paid. ### Does the IDU stay with a company if it switches French representative? Yes. The IDU is attached to the producer, not to the representative. Changing representative changes the contact on the eco-organisation file; the membership and the IDU continue, and marketplaces keep verifying the same number. ### Why does a marketplace show my IDU as "not found" right after the eco-organisation approved it? There can be a gap between the eco-organisation's approval and the public SYDEREP record. Uploading during that gap can produce repeated failed checks, so wait until the IDU can be found on SYDEREP under your exact registered name. ### Does the IDU need to be printed on the product or its packaging? No. The IDU is an administrative identifier for terms of sale, invoices and marketplace compliance portals. What goes on household packaging is the Triman logo and the Info-tri sorting instructions, a separate obligation. ### Can two related companies in the same group share a single French IDU? No. Each legal entity that places products on the French market needs its own IDU per stream, even within a group. A parent company and a separate sales subsidiary both selling to France each need their own registration. ## Next step If you do not yet have your French IDUs, our [wizard](/get-registered) scopes your streams in about three minutes and a written quote follows within one business day. The IDU timing then depends on the eco-organisation (about seven business days after the membership is validated at Citeo). ## Sources & references All legal and regulatory claims in this article trace back to the following primary sources (Légifrance, EUR-Lex, ADEME and equivalents). Verified 31 July 2026. - [LOI n° 2026-602 du 8 juillet 2026, Légifrance](https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000054399113), article 5, 2°, creating Article L. 541-10-9-1 du Code de l’environnement (JO of 9 July 2026, NOR TECX2407166L), in force 10 July 2026. Mandatory representative for producers not established in France. - [Article L. 541-10 du Code de l’environnement (cadre général REP), Légifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000049464284) - [Loi n° 2020-105 du 10 février 2020 (AGEC), Légifrance](https://www.legifrance.gouv.fr/loda/id/JORFTEXT000041553759/) - [SYDEREP, registre public des producteurs (ADEME)](https://www.syderep.ademe.fr/) - [Citeo, éco-organisme emballages ménagers](https://www.citeo.com/) - [Léko, éco-organisme emballages](https://www.leko-organisme.fr/) - [Adelphe, éco-organisme emballages (filiale Citeo)](https://www.adelphe.fr/) - [Ecosystem, éco-organisme DEEE](https://www.ecosystem.eco/) - [Ecologic, éco-organisme DEEE](https://www.ecologic-france.com/) - [Refashion, éco-organisme textile, linge, chaussures (TLC)](https://refashion.fr/) - [Batribox (ex-Screlec), éco-organisme piles et accumulateurs](https://www.batribox.fr/) - [ADEME, Agence de la transition écologique](https://www.ademe.fr/) - [Amazon EU Seller Central, EPR France requirements](https://sellercentral-europe.amazon.com/help/hub/reference/external/GAZUTQC8RXT769H7) - [Cadre général des filières REP, Ministère de la Transition écologique](https://www.ecologie.gouv.fr/politiques-publiques/cadre-general-filieres-responsabilite-elargie-producteurs) --- URL: https://eprrepresentative.com/blog/french-epr-declaration-deadlines-eco-organisms-2026 Last updated: 2026-10-12 # French EPR Declaration Deadlines 2026 and 2027: The Filing Calendar for Every Eco-Organism Every French eco-organism sets its own declaration deadline and frequency, and they are not all 28 February. This is the filing calendar for all 19 EPR streams: the 2026 dates for 2025 volumes, the first 2027 dates for household packaging, the firm dates, the ones to confirm on the portal, and what a missed declaration costs. Most guides to French EPR treat the annual declaration as a single date: 28 February. That is convenient and wrong. The declaration is the filing in which a producer reports the volumes it placed on the French market, and on which each eco-organism computes the eco-contribution. There are around 28 approved eco-organisms across the 19 French EPR streams, and they do not share one calendar. Some close at the end of February, some at the end of March, one runs into late May, several declare quarterly or monthly, and professional packaging has no 2025 declaration at all. This is the hub for French EPR deadlines: the 2026 filing calendar for 2025 volumes, eco-organism by eco-organism, plus the first published dates for 2027 placements. > **In this topic** > > - [EPR deadlines timeline (tool)](/tools/epr-deadlines-2026): the year at a glance > - [EPRO 2027 calendar](/blog/epro-2027-calendar-adhesion-declarations): professional packaging, from adhesion to the first declaration > - [Professional packaging rates 2026 and 2027](/blog/professional-packaging-epr-baremes-2026): where the scales stand > - [Calculating French eco-contributions](/blog/calculate-french-eco-contributions-guide): how declared volumes become a contribution > - [Packaging weight vs unit sales](/blog/packaging-weight-vs-unit-sales-epr-data-france): the data your declaration needs > - [EPR penalties](/guides/epr-penalties): what a missed declaration exposes you to > - [Version française : échéances de déclaration REP](/blog/echeances-declaration-rep-eco-organismes-2026) ## Which two deadlines do people confuse? **The declaration is not the payment.** You declare your volumes first; the eco-organism then invoices the eco-contribution, usually weeks later. Refashion, for example, closed its declaration on 28 February 2026 and set payment at 31 March 2026. Citeo closes its declaration at the end of February and invoices toward the end of April. When someone gives you one date, ask whether it is the declaration or the payment. **The declaration to the eco-organism is not the SYDEREP declaration to ADEME.** You (or your representative) declare placed-on-market volumes to each eco-organism you belong to. Separately, the eco-organism files an aggregated annual report of its members' data into ADEME's national SYDEREP register, anchored by the arrêté of 12 December 2022 at end of Q1 to 30 April. That 31 March or 30 April figure is the eco-organism's regulatory filing, generally handled for you, not your own deadline. ## How often do you 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. The shape of a year: - **January**: annual declaration windows open on most streams. Data preparation should already be done. - **Late January to end of March**: the bulk of annual declarations close. The household streams cluster at the end of February; furniture and several others sit at the end of March or later. - **March to May**: eco-contribution invoices issue. - **Throughout the year**: quarterly and monthly filers declare on a rolling basis. ## What is the 2026 declaration calendar, stream by stream? Dates below are for 2025 volumes, read from each eco-organism's official pages in July 2026. Firm means published in the eco-organism's own declaration guide, FAQ or calendar. Confirm on portal means the eco-organism does not publish a fixed public date and you should read it in your member space. In all cases the eco-organism's own current calendar prevails over any summary, including this one. | Stream | Eco-organism(s) | Frequency | 2026 declaration window / deadline (for 2025) | | --- | --- | --- | --- | | Household packaging + graphic paper | Citeo, Adelphe | Annual (large producers also file a provisional estimate) | **1 January to 28 February 2026**; eco-contribution payment by 30 April. Firm | | Household packaging + graphic paper | Léko | Annual (detailed declaration mandatory above 500,000 UVC) | Early 2026, ahead of the invoice issued no later than 31 March; confirm the window on MyLéko | | Professional packaging (EPRO) | Citeo Pro, Léko Pro, Twiice | Annual once running | No 2025 or 2026 contribution. Provisional declaration at adhesion; first real declaration in early 2028 on 2027 volumes. See the note below | | WEEE (electrical and electronic) | Ecosystem | Quarterly unless contributions are paid by SEPA direct debit | Confirm the exact 2026 dates on the producer portal | | WEEE + sports/leisure + DIY/garden | Ecologic | Semi-annual campaigns (about six weeks each) | No single fixed date; each campaign's deadline is emailed to members | | WEEE, photovoltaic panels (cat. 7) | Soren | Quarterly, ten-day windows | 2025 Q4: **1 to 10 January 2026**; then 1 to 10 April, July and October 2026. Firm | | Batteries (portable) | Batribox | Annual | Closed **28 February 2026**. Firm | | Batteries | Ecosystem | Per Ecosystem's calendar | Confirm on the producer portal | | Textile, household linen, footwear | Refashion | Annual | **14 January to 28 February 2026**; payment by 31 March. Firm | | Furniture, toys, DIY/garden | Ecomaison | Quarterly by default; annual on option (below 15 t, 1,000 pieces and EUR 2 million of turnover in the stream) | Annual declarants: **1 January to 31 March 2026**. Firm | | Professional furniture + construction (cat. 2) | Valdelia | Quarterly | Published closing for 2025: **before 31 March 2026**; confirm each quarter in the member space | | Construction (PMCB), furniture, DIY | Valobat | Annual | Campaign **1 March to 31 May 2026**. Firm | | Construction (PMCB, inert cat. 1) | Ecominéro | Monthly by default; annual regime for eligible small producers | Monthly (1st to 15th of the following month); annual regime **1 to 31 January 2026** | | Single-use wipes (TSUU) | Citeo Soin & Hygiène | Annual (offset first cycle) | For 2025 volumes the declaration **opens 1 July 2026**; closing date to confirm | | Chemicals (household DDS) | EcoDDS | Annual | **1 January to 1 March 2026**; attestation of accuracy before 30 June. Firm | | Chemicals (fire extinguishers) | Ecopae | Annual | Not published; confirm | | Chemicals (pyrotechnics) | Pyréo | Annual | Not published; confirm | | Tyres | Aliapur | Annual (occasional importers declare per shipment) | **Before 31 January 2026** on Aliabase. Confirm on portal | | Tyres | France Recyclage Pneumatiques, Tyval | Annual | Portal deadline not separately published (SYDEREP anchor 31 March); confirm | | Lubricants | Cyclevia | Quarterly plus annual | Dates not published (LUBREC platform); confirm | | Medical sharps | DASTRI | Annual | Deadline not published; confirm in the member space | | Unused medicines | Cyclamed | Annual | Deadline not published; confirm | | Tobacco (cigarette filters) | Alcome | Annual (flat-fee regime for small producers) | Deadline not published; confirm | | Recreational boats | APER | Contribution per new-boat sale | Deadline not published; confirm | | End-of-life vehicles + EV batteries | Recycler Mon Véhicule | Annual | Portal date not published (SYDEREP anchor 30 April); confirm | If your catalogue triggers several streams (a boxed electrical product is packaging plus WEEE, often plus batteries), you are managing three or four deadlines on different dates, not one. ## What are the first dates for 2027 placements? The 2027 household packaging grids, published on 30 September 2026 and revised on 8 October 2026, also set the next declaration windows: | Eco-organism | Declaration of 2027 placements | Invoice and payment | | --- | --- | --- | | **Citeo** | **From January to the end of February 2028** | Per Citeo's invoicing calendar | | **Léko** | **Before 1 March 2028** | Invoice by 31 March 2028, payable within 30 days | For professional packaging, the first declaration of actual 2027 volumes is expected in early 2028 (before 1 March under Citeo Pro's standard contract). Other eco-organisms publish their 2027 calendars on their own timing; check each one in its member space. ## Which special cases are worth flagging? **Professional packaging (EPRO) has no 2025 or 2026 contribution.** The stream was created by décret n° 2025-1081 and contributions start on 1 January 2027. Producers file a provisional declaration on estimates when they join; the first real declaration covers 2027 volumes, in early 2028. Details in the [EPRO 2027 calendar](/blog/epro-2027-calendar-adhesion-declarations). **Wipes (TSUU) run on an offset cycle.** Because the single-use wipes stream started on 1 July 2025, the declaration for 2025 volumes opened on 1 July 2026, not in the first quarter. It is mandatory even for small volumes. **Some eco-organisms have no annual date.** Soren declares in four ten-day quarterly windows, Ecominéro monthly by default, Ecologic in semi-annual campaigns with each deadline emailed. For these there is a rhythm to keep, not a date to circle. **Multi-stream eco-organisms carry one calendar across their streams.** Furniture, toys and DIY declared through Ecomaison share one cadence. Valobat covers construction, furniture and DIY on its 1 March to 31 May campaign. This is a quiet argument for consolidating streams under one representative and one cadence. ## What goes into a declaration? Each declaration covers the volumes placed on the French market over the period, in the unit of the eco-organism's scale: - **Household packaging**: units and weight by material, per reference or packaging family. - **WEEE**: units by product category. - **Batteries**: weight by battery type. - **Textile (Refashion)**: pieces by category (clothing, linen, footwear). - **Furniture, toys, DIY**: units or weight, depending on the eco-organism's scale. - **Professional packaging**: tonnage by material. Each stream is declared separately with its own eco-organism: a producer with three streams files three declarations. ## What happens if you miss a declaration? The escalation is predictable, and the order matters because the expensive part is not the fine: 1. A reminder from the eco-organism. 2. A formal notice if the declaration is still missing. 3. Suspension of the identifier on SYDEREP. 4. Revocation of the identifier if there is no remediation. 5. Back-payment of eco-contributions plus late penalties, and possible referral to the authorities. The operational consequence arrives between steps 3 and 4: once SYDEREP shows your identifier as suspended, marketplace checks fail and listings deactivate. The administrative sanction sits behind that under Article L. 541-9-5 (up to EUR 7,500 per unit or per tonne for a legal entity, and up to EUR 30,000 for a registry or identifier failure, after a formal notice from the administration; checked on Légifrance on 6 October 2026). For most sellers the lost sales are the larger cost. See our [EPR penalties guide](/guides/epr-penalties). ## How do you prepare for year 1 and every year after? **Your first declaration is a partial year**, from your registration date to 31 December: a producer registered in October 2025 declares October to December 2025 in the 2026 windows. Reasonable estimates are acceptable and correctable later; a non-declaration is not. Five habits prevent declaration problems: - **Prepare data continuously, not at year-end.** A running tally of French shipments by reference is far easier than reconstructing twelve months in January. - **Reconcile your channels.** Amazon FBA, Shopify, other marketplaces and direct B2B each track units separately; build one France-units view monthly or quarterly. - **Know each eco-organism's cadence.** Quarterly and monthly filers do not wait for January. - **Send the data to your representative early**, a few weeks before the first deadline of the year. - **File even when uncertain.** A declaration filed on reasonable estimates can be corrected; a missing one escalates. ## Who files, and what stays with you? 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. We hold the calendar, prepare the declarations and file each one in its own window. [Request a written quote](/get-registered) and get your fee per stream within one business day, or see the year at a glance on the [deadlines timeline](/tools/epr-deadlines-2026). ## Frequently asked questions ### When are French EPR declarations due? Each eco-organism sets its own date. Most streams are declared once a year, mostly between January and the end of March for the previous year: Citeo closes at the end of February, Ecomaison annual declarants on 31 March, Valobat on 31 May. For 2027 household packaging, Citeo opens January to the end of February 2028 and Léko closes before 1 March 2028. ### Is the French EPR declaration deadline always 28 February? No. 28 February 2026 is firm for several household streams (Citeo and Adelphe for packaging and graphic paper, Refashion for textile, Batribox for portable batteries), but Ecomaison annual declarants close on 31 March, Valobat runs 1 March to 31 May, EcoDDS closes on 1 March, Aliapur on 31 January, Soren declares in quarterly ten-day windows and Ecominéro monthly. The eco-organism's own published calendar prevails. ### How often do I 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. ### What happens if I miss an eco-organism declaration deadline? A cascade, and the commercial part hits first. The eco-organism sends a reminder, then a formal notice. If the declaration is still missing, it can suspend or revoke your identifier. Once the identifier is suspended on the ADEME SYDEREP register, marketplace checks start failing and listings deactivate. The administrative sanctions of Article L. 541-9-5 sit behind that: up to EUR 7,500 per unit or per tonne for a legal entity. ### Is the declaration to the eco-organism the same as the SYDEREP declaration to ADEME? No. The producer declares placed-on-market volumes to each eco-organism it belongs to; that computes the eco-contribution, and its deadline varies by eco-organism. Separately, the eco-organism files an aggregated annual report of its members' data to ADEME's SYDEREP register, anchored by the arrêté of 12 December 2022 around 31 March to 30 April. That date is the eco-organism's filing, usually done for you, not your own deadline. ### I registered partway through 2025. Do I still declare in 2026? Yes. Your first declaration covers the period from your registration date to 31 December of the registration year, filed in the 2026 window of each relevant eco-organism. Partial-year declarations are normal; filing with reasonable estimates is far better than not filing. ### Who files the declaration for a producer with no French establishment? Your authorized representative files it in each eco-organism portal, using the volume data you provide, before each eco-organism's deadline. 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 declarations, your registration and identifier, the exchanges with the eco-organisation and audits, and the archiving of your files. ## Sources & references The 2026 dates were read from each eco-organism's official pages in July 2026; the 2027 household packaging dates come from the Léko 2027 grid (version of 8 October 2026) and the Citeo 2027 guide (updated 8 October 2026). Declaration calendars are republished every year: confirm the exact date on your eco-organism's producer portal before relying on it. - [Citeo, déclarer vos emballages et papiers](https://www.citeo.com/declarer) - [Léko, éco-organisme emballages](https://www.leko-organisme.fr/) - [Refashion, filing your declaration (pro space)](https://pro.refashion.fr/en/marketer/file-your-declaration) - [Batribox, déclarez vos mises sur le marché](https://www.batribox.fr/declarez-vos-mises-sur-le-marche) - [Ecosystem](https://www.ecosystem.eco/) - [Ecomaison, déclarer l'éco-participation](https://ecomaison.com/) - [Valdelia, foire aux questions déclaration](https://batiment.valdelia.org/foire-aux-questions) - [Valobat, adhésion, déclaration, facturation](https://www.valobat.fr/) - [Soren, déclarations (support Moebius)](https://soren.eco/) - [EcoDDS, déclaration des produits contribuants](https://www.ecodds.com/) - [Aliapur, metteurs en marché](https://www.aliapur.fr/) - [Ecominéro, déclarer ses mises en marché](https://www.ecominero.fr/) - [Arrêté du 12 décembre 2022 relatif aux déclarations REP (registre SYDEREP), Légifrance](https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000046756020) - [Article L. 541-9-5 du Code de l'environnement (sanctions), Légifrance](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000043979280) - [SYDEREP, registre public des producteurs (ADEME)](https://www.syderep.ademe.fr/) - [Liste des filières REP et éco-organismes agréés, ADEME](https://filieres-rep.ademe.fr/) --- URL: https://eprrepresentative.com/blog/triman-logo-french-labeling-non-eu-brands Last updated: 2026-10-12 # Info-tri and the Triman Logo: the 2026 Guide for Sellers Outside France Household packaging and graphic papers sold in France carry the Info-tri, with the Triman logo, whatever their origin. Who must mark, the four blocks, sizes and colours, stickers, small packaging, export versions, where the official files come from, a checklist for brands designing their packaging and what changes with the PPWR. Household packaging and graphic papers sold in France must carry the Info-tri, the French sorting information that includes the Triman logo, whatever the country they come from, EU or non-EU. The obligation applies since 1 January 2022. The official files come with membership of Citeo or Léko, which we open for you; the artwork stays with you and your designer. This guide covers packaging and graphic papers, the case almost every seller meets. Electrical equipment, batteries, textiles, furniture, toys, sports, DIY and household chemicals have their own markings: see [French sorting info across every EPR scheme](/blog/sorting-info-france-triman-info-tri-every-epr-scheme). ## Who must mark? The producer that places household packaging or graphic papers on the French market: whoever owns the goods when they enter France (the transfer of ownership decides, not the brand or the Incoterm), including when the goods then ship from Amazon FBA or a third-party warehouse. Origin does not matter. A German, Spanish, US or Chinese brand selling to French households marks its packaging exactly like a French one, and a registration in another country (a German LUCID number, a Polish BDO number) does not cover France. What is in scope and what is not: - **In scope:** household packaging (boxes, bottles, jars, pouches, films, the shipping box delivered to a consumer) and graphic papers. - **Out of scope:** packaging of products used only by professionals. A package also sold to households stays household packaging, even when a business buys it. - **Exempt:** glass beverage bottles. Voluntary marking is recommended. **Dates.** The marking is mandatory since 1 January 2022. Packaging made or imported before then could be sold off until 9 March 2023; that period is over, so every unit now on the French market must be marked. ## The four blocks, and what is forbidden A compliant marking has four blocks, read from left to right or top to bottom: 1. **The Triman**, the common sorting logo. It is not a recyclability claim: it only tells the consumer that a sorting rule applies. 2. **The banner**, the header strip of the Info-tri. 3. **The elements**: each separable element the consumer handles (box, bottle, cap, film, sleeve), shown as text, pictogram or both. 4. **The destination** of each element (the sorting bin, or the glass bank for glass). List what the consumer actually separates. A bottle with its cap is one gesture when the cap stays on; a lid in a different material from the jar is a separate element. A pouch that cannot be separated is one element. **What is forbidden in the Info-tri:** - the **name of the material** (the element is "box", not "cardboard"); - the words **"à recycler"**; - a **household waste pictogram** (the bin for residual waste). Remove old sorting mentions while you are at it, and the Green Dot: it is not mandatory and does not mean recyclable. ## Sizes and colours - **Triman:** at least **10 mm** in the standard format, **6 mm** in the compact format. The compact format is only for tight spaces and is never shrunk further. - **Text:** at least **5 pt**. - **Colours:** your eco-organisation's guide sets them. Léko does not allow a white Triman. Citeo accepts a reversed Triman if it stays legible. Follow the guide of the eco-organisation you belong to rather than a generic rule. Never redraw or distort the logo: use the official files (see below). ## Where to place it On the packaging, on a surface the consumer sees without opening or dismantling it. **Never inside** the packaging. A side panel or the back of the box is fine. **Stickers.** Léko accepts a sticker on the packaging, including to relabel stock already produced. That is the usual route for a seller whose packaging is printed for several markets, or who discovers the obligation with goods already in a French warehouse. If you are a Citeo member, follow the Citeo guide. For the shipping box of an online order, see [E-commerce parcels and stickers](/blog/ecommerce-parcels-stickers-triman-france). ## Three or more elements, and leaflets Packaging with many separable elements (a gift box with an insert, a jar, a lid, a sleeve) still lists every element the consumer separates, each with its destination. When space runs short, use the layouts of your eco-organisation's guide rather than dropping elements. When a leaflet or instruction sheet accompanies the product and the packaging is too small to carry the Info-tri, the Info-tri goes on the leaflet (see the next section). ## Small packaging and dematerialisation Small packaging can move part or all of the marking online, but the obligation remains: | Packaging | Rule | |---|---| | Largest face under 10 cm² | Triman and Info-tri can both be dematerialised | | Largest face 10 to 20 cm² | Triman on the packaging; Info-tri can be dematerialised | | Round packaging under 20 cm² | Triman and Info-tri can both be dematerialised | | Round packaging 20 to 40 cm² | The banner can be dematerialised | | A leaflet accompanies the product | The Info-tri goes on the leaflet | ## Products sold in France and abroad The Info-tri is a French marking. When one artwork serves several countries: - place the **FR tab first**, so the consumer sees the rule applies in France; - **do not translate** the Info-tri; - **export versions:** Léko requires a monochrome export version; Citeo only for multi-country versions. If the packaging carries other national markings, keep each one complete rather than merging them. ## Getting the official files The official files are not public downloads. They come with membership: - **Citeo:** the Easy Info-tri generator, in the Citeo client area. - **Léko:** licensed files in the member document area, which you compose yourself. Both are available **only after membership**, and **neither eco-organisation validates your artwork**: the responsibility for the final marking stays with the producer. That is where we come in. As a French authorised representative, we open your Citeo or Léko membership in your name, which gives you access to the files. The artwork stays with you and your designer: we do not design, generate or validate markings. ## Penalties Under Article L. 541-9-4 of the French Environmental Code, a missing or wrong marking can be fined up to **EUR 3,000 for an individual** and **EUR 15,000 for a company**, **per non-compliant reference**. Checks are carried out by the DGCCRF, the French consumer protection authority. Two points worth knowing. On a catalogue of many references the exposure adds up, one reference at a time. And the marking has no effect on your eco-contribution: the 2027 Citeo and Léko scales carry no bonus or malus linked to Info-tri; the marking is a legal requirement. The only related premium (4%) rewards off-pack media awareness campaigns. ## What comes with the PPWR Regulation (EU) 2025/40 (PPWR) creates a harmonised EU sorting label for packaging, which will replace national packaging labels such as the Triman. Citeo has announced the following timeline: application in 2028, a stock sell-off period from 2028 to 2031, and the EU marking on all packaging in 2032. Until then the Triman and the Info-tri stay mandatory in France. The state of play is in [EU sorting-label harmonisation: PPWR and the Triman](/blog/eu-sorting-label-harmonisation-ppwr-triman-state-of-play). ## FAQ ### Is the Info-tri mandatory for a foreign seller? Yes. Household packaging and graphic papers placed on the French market carry the Info-tri, with the Triman logo, whatever their origin, EU or non-EU. The obligation applies since 1 January 2022; the sell-off period for older stock ended on 9 March 2023. Packaging of products used only by professionals is out of scope. ### Where do I get the official Info-tri and Triman files? From your eco-organisation, once you are a member. Citeo provides the Easy Info-tri generator in its client area; Léko provides licensed files in its member document area, which you compose yourself. Neither eco-organisation validates your artwork. We open the membership for you; the artwork stays with you and your designer. ### Is a sticker enough? Léko accepts a sticker on the packaging, including to relabel stock already produced. The marking must sit on the packaging, never inside it. If you are a Citeo member, follow the Citeo guide. ### What about the shipping box? Citeo treats the shipping box delivered to a consumer as packaging to be marked, and its 2027 guide counts a parcel made of a box, tape and void fill as three units. Packaging sold only to professionals is out of scope, but a package also sold to households stays household packaging. ### Does the Info-tri change my eco-contribution? No. The 2027 Citeo and Léko scales carry no bonus or malus linked to Info-tri; the marking is a legal requirement. The only related premium (4%) rewards off-pack media awareness campaigns. ### Do glass bottles need the Info-tri? Glass beverage bottles are exempt from the obligation; voluntary marking is recommended. The exemption covers glass beverage packaging only: other household packaging keeps the Info-tri and the Triman. ### What is the penalty for a missing Info-tri? Up to €3,000 for an individual or €15,000 for a company, per non-compliant reference, under Article L. 541-9-4 of the French Environmental Code. Checks are carried out by the DGCCRF, the French consumer protection authority. ## Info-tri for foreign brands designing their packaging Before your packaging artwork goes to print for France, run through these points. They summarise the published rules of Citeo and Léko; your eco-organisation’s guide prevails on the detail. 1. Check the scope: household packaging and graphic papers sold in France carry the Info-tri, whatever their origin. Packaging of products used only by professionals is out of scope; a package also sold to households stays household packaging. 2. Plan the membership before the artwork: the official files come only with membership (the Easy Info-tri generator at Citeo, licensed files to compose yourself at Léko). 3. List every separable element the consumer handles (box, bottle, cap, film, sleeve), each with its destination. 4. Leave out the name of the material, the words “à recycler” and any household waste pictogram; remove the Green Dot. 5. Respect the sizes: Triman at least 10 mm, or 6 mm in the compact format, text at least 5 pt; colours follow your eco-organisation’s guide. 6. Place the marking on the packaging, on a surface seen without opening it, never inside. 7. Small packaging: check the 10 and 20 cm² thresholds (20 and 40 cm² for round packaging) before moving part of the marking online; if a leaflet accompanies the product and the packaging is too small, the Info-tri goes on the leaflet. 8. Artwork shared with other countries: FR tab first, Info-tri not translated, export version as your eco-organisation requires (Léko: monochrome export version; Citeo: only for multi-country versions). 9. Stock already printed: Léko accepts a sticker on the packaging, including to relabel existing stock; Citeo members follow the Citeo guide. 10. Online orders: Citeo treats the shipping box delivered to a consumer as packaging to be marked. 11. Glass beverage bottles are exempt (voluntary marking recommended); other household packaging is not. 12. Nobody validates your artwork, neither Citeo nor Léko: the final marking stays the producer’s responsibility. A missing Info-tri can cost up to €3,000 (individual) or €15,000 (company) per reference, Article L. 541-9-4. We open your Citeo or Léko membership, which gives you the official files, obtain your identifier and file your declarations. The artwork stays with you and your designer: we do not design, generate or validate markings. ## Open the membership that gives you the files If you sell household packaging into France without a French establishment, we join Citeo or Léko in your name, obtain your identifier and file your declarations. You then download the official files and your designer applies them. [Request a written quote](/get-registered): it arrives within one business day. Stream details: [household packaging](/services/packaging), [Citeo](/eco-organisms/citeo), [Léko](/eco-organisms/leko). ## Sources - Article L. 541-9-3 of the French Environmental Code (sorting information obligation) and Article L. 541-9-4 (penalties), [Légifrance](https://www.legifrance.gouv.fr/codes/texte_lc/LEGITEXT000006074220) - Léko, Info-tri user guide (2024) - Citeo, simplified Info-tri guide (2025) - Citeo and Léko, 2027 household packaging scales (published 30 September 2026, both revised 8 October 2026) - [Regulation (EU) 2025/40 (PPWR), EUR-Lex](https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng) --- URL: https://eprrepresentative.com/blog/french-household-packaging-rates-2027-citeo-vs-leko Last updated: 2026-10-12 # French Household Packaging Rates 2027: Citeo vs Léko, What Changes and What It Costs Producers Citeo and Léko both replaced their 30 September 2026 household packaging grids for 2027 on 8 October 2026: Citeo with a downward revision, Léko with a version that caps the simplified declaration at €180 below 10,000 units. Most Citeo weight rates now move by 0.5 to 1.2%, PVC rises 18% at Citeo and 39% at Léko, both cut their per-unit fee, and Léko raises its minimum to €110, matching the Citeo flat fee. A material-by-material comparison, worked examples and what foreign sellers should do now. On 30 September 2026, Citeo and Léko, the two eco-organisms most foreign sellers join for French household packaging, published their 2027 rates. On 8 October 2026 both replaced them. Citeo's revised guide is lower on every weight rate, on its per-unit fee and on its simplified tariffs (the €110 flat fee is unchanged). Léko's revised grid caps the simplified declaration at €180 excluding VAT below 10,000 units, raises two weight rates against its 30 September version (compostable bags from 77.00 to 80.40 ct€/kg, PLA from 105.00 to 140.00 ct€/kg) and grants its reduction bonus only when the product quantity stays constant, with evidence. This article uses both 8 October versions. The rates apply to packaging made available on the French market in 2027 and declared in early 2028. We read the documents in full (each organisation's 2026 grid and both of its 2027 versions) and compared them line by line. The short version: most Citeo weight rates now barely move, most Léko plastics rise 4.5%, PVC rises much more at both, both cut their per-unit fee, and small sellers are the ones whose bill can move most. ## Weight rates, material by material The weight component is the main part of the eco-contribution for producers declaring per unit (compulsory above 500,000 consumer sales units, UVC, a year). Euro cents per kg, excluding VAT: | Material | Citeo 2026 | Citeo 2027 | Change | Léko 2026 | Léko 2027 | Change | |---|---|---|---|---|---|---| | Steel | 6.49 | 6.52 | +0.5% | 6.45 | 6.50 | +0.8% | | Aluminium | 24.34 | 24.63 | +1.2% | 24.30 | 25.40 | +4.5% | | Paper-cardboard | 25.81 | 25.94 | +0.5% | 25.50 | 25.80 | +1.2% | | Liquid cartons | 46.79 | 47.03 | +0.5% | 46.75 | 47.00 | +0.5% | | Glass | 2.01 | 2.02 | +0.5% | 2.00 | 2.00 | 0% | | Clear PET bottles | 70.00 | 70.87 | +1.2% | 67.00 | 70.00 | +4.5% | | PE / PP bottles | 77.01 | 77.96 | +1.2% | 73.70 | 77.00 | +4.5% | | Rigid PET (non-bottle) | 84.01 | 81.50 | -3.0% | 80.40 | 80.50 | +0.1% | | Flexible PE | 77.01 | 77.96 | +1.2% | 73.70 | 77.00 | +4.5% | | Flexible PP | 84.01 | 81.50 | -3.0% | 80.40 | 80.50 | +0.1% | | Complex or other resins (excl. PVC) | 140.01 | 141.74 | +1.2% | 134.00 | 140.00 | +4.5% | | PVC-containing packaging | 210.01 | 248.03 | +18.1% | 201.00 | 280.00 | +39.3% | | Textile, other materials | 105.01 | 77.96 | -25.8% | 105.00 | 76.00 | -27.6% | **Common materials barely move.** Cardboard, glass and steel rise 0 to 1.2% at both. A brand shipping mostly in cardboard sees its weight component stay almost flat. **Plastics: +1.2% at Citeo, +4.5% at Léko**, except rigid PET and flexible PP, down 3% at Citeo and almost flat at Léko. Citeo now splits rigid PS (77.96 ct€/kg) from PSE and XPS (81.50). Léko stays below Citeo on plastics, but the gap is now about 1% (77.00 against 77.96 on PE and PP). **PVC becomes a real cost line.** PVC goes to 248.03 ct€/kg at Citeo (+18%) and 280.00 at Léko (+39%): Léko is dearer than Citeo on PVC, and also on aluminium (25.40 against 24.63). Citeo adds a 212.60 ct€/kg line for PVC blisters of medicines under marketing authorisation, following the PPWR recyclability exemptions. Complex packaging rises only 1.2% at Citeo after the revision (the 30 September version had +15%). Textile and "other materials" fall sharply at both, and ceramic at Citeo, on the same exemption logic. The full grid, including PS, PSE, XPS, compostable plastics, PLA, wood and ceramic, is on our [French EPR rates 2026 page](/baremes-rep-2026). ## The per-unit fee: down at both On top of weight comes a fee per UVC, set by the number of separable packaging components (cap, seal, sleeve…) and the business sector. It is counted in fractions of a cent, but it applies to every unit sold. - **Léko** cuts its full per-unit rate everywhere. For a one-component unit: household goods 0.155 to 0.1396 euro cents (-9.9%), beverages 0.180 to 0.1677 (-6.8%), health and beauty 0.135 to 0.1179 (-12.7%). - **Citeo**, after its 8 October revision, cuts its littering component too: household goods 0.1482 to 0.1291 euro cents for a one-component unit (-13%), -31% at ten components and -35% at twenty. New in 2027: from the 17th component, each extra one carries a 5% surcharge. Its separate reuse component falls from 0.0140 to 0.0131 euro cents per unit. ## Simplified declarations and the small-seller floors Most small and mid-sized foreign sellers use the simplified declaration: a fixed amount per unit by product family, no technical data. Léko keeps its 2027 simplified grid almost identical to 2026, with a handful of cuts for shipped products (still water shipped in a parcel from €0.0577 to €0.0248 per unit, audio and hi-fi from €0.1941 to €0.13). Citeo's revised general grid sits 1.6% below 2026 at the median (59 of its 84 families are lower, by our count), with outliers: radios, headphones and earphones from €0.0370 to €0.0642 (+74%), smartphones and connected devices from €0.0212 to €0.0248 (+17%). Its "products shipped in a parcel" grid, designed for marketplaces and their sellers, sits 3.3% below 2026 at the median (60 of 68 families lower). The floors matter more: - **Citeo** keeps its **€110 flat fee** under 10,000 units. - **Léko** raises its minimum from **€95 to €110**, and the **€150 cap under 20,000 units** of its 2026 grid becomes, in the 2027 grid of 8 October 2026, a **€180 cap under 10,000 units**. Below 10,000 units a Léko simplified declaration therefore costs between €110 and €180 (our formula: max(110, min(units × family rate, 180))); between 10,000 and 20,000 units, no cap applies any more. **Worked example: an online cosmetics brand shipping 15,000 units a year in parcels.** At Léko (simplified, with shipping packaging, €0.0388 per unit) the bill goes from €150 (capped) in 2026 to €582 in 2027, since at 15,000 units the 2027 cap no longer applies. At Citeo (products shipped in a parcel) it goes from €640.50 to €600.00 (15,000 × €0.0400). At 8,000 units the Léko cap applies: 8,000 × €0.0388 = €310.40, capped at €180, against the Citeo flat fee of €110. Below 10,000 units the Citeo flat fee is never dearer than Léko, and the gap is at most €70. ## Worked example: a beverage brand declaring per unit 100,000 clear PET bottles of 30 g (3 tonnes, cap weight included for simplicity), two packaging components, beverage sector, before eco-modulation: | | Citeo 2026 | Citeo 2027 | Léko 2026 | Léko 2027 | |---|---|---|---|---| | Weight component | €2,100.00 | €2,126.10 | €2,010.00 | €2,100.00 | | Per-unit component (2 components) | €306.80 | €273.00 | €299.00 | €281.90 | | **Total** | **€2,406.80** | **€2,399.10** | **€2,309.00** | **€2,381.90** | | Change | | **-0.3%** | | **+3.2%** | Our calculation: weight = 3,000 kg × the clear PET rate; per unit = 100,000 × the two-component rate of the sector. For Citeo, the per-unit line adds the littering component (0.2599 euro cents in 2027) and the separately published reuse component (0.0131). Léko stays €17.20 cheaper on this example, against €126.80 with the 30 September version of the Citeo guide. ## What PPWR changes in the 2027 Citeo guide The Citeo 2027 guide applies the first consequences of Regulation (EU) 2025/40 (PPWR): - **brand owners** that set packaging specifications or put their brand on it, including private labels, become responsible under EPR; - **service and transport packaging** may fall on its manufacturer; - **tea bags and coffee capsules** become packaging and carry eco-contributions; - a **parcel** made of a box, tape and void fill counts as **3 units**, subject to validation by the coordinating body. For a cross-border e-commerce seller, that last point can change the base of the declaration. > **Info-tri and the 2027 scales.** The 2027 Citeo and Léko scales carry no bonus or malus linked to Info-tri; the marking is a legal requirement. The only related premium (4%) rewards off-pack media awareness campaigns. Marking rules, sizes and where the official files come from: [the Info-tri and Triman guide](/blog/triman-logo-french-labeling-non-eu-brands). ## What foreign sellers should do now 1. **Re-run your 2027 estimate on your own volumes,** on the Citeo version of 8 October 2026, not the 30 September one. Depending on your mix, the change ranges from a cut to almost a fourfold increase for Léko members between 10,000 and 20,000 units, who lose the 2026 cap. 2. **Check your declaration regime** (flat fee, simplified, per unit) against the new grids. 3. **Compare Citeo and Léko on your case**, reading the switching terms of your membership contract before deciding. 4. **Treat PVC and complex packaging first**: they are where redesign pays back fastest. 5. **Map your shipping packaging** under the PPWR rules if you sell online. If you sell into France without a French establishment, you need a French authorised representative to join the eco-organism, obtain the IDU and file these declarations: that is our core service, from a public entry price with the exact fee fixed in a written quote within one business day. We take no percentage on your eco-contributions. Our [eco-contribution simulator](/tools/eco-contribution-simulator) now shows the Léko to Citeo range on every household packaging material. ## Sources - Citeo, 2027 household packaging tariff guide, version updated 8 October 2026 (replaces the version published 30 September 2026). - Citeo, 2026 household packaging tariff guide. - Léko, 2027 tariff, version of 8 October 2026 (replaces the version of 30 September 2026). - Léko, 2026 household packaging and paper tariff, version of 14 November 2025. - Regulation (EU) 2025/40 on packaging and packaging waste (PPWR). Amounts excluding VAT and before eco-modulation, for guidance: the eco-organisms' official grids prevail. --- URL: https://eprrepresentative.com/blog/epr-france-cost-non-eu-seller-complete-budget Last updated: 2026-10-12 # How Much Does EPR Compliance in France Really Cost a Foreign Seller? The line-by-line cost of French EPR compliance for a seller with no French establishment: the representative fee, eco-contributions by stream, the security deposit, the hidden costs to check in any quote, and a worked budget for an Amazon seller. French EPR pricing has long been opaque. Much of the traditional French environmental consultancy market relies on quote-only sales processes, where the cost depends on perceived ability to pay rather than on a stable cost structure. The result is that the same registration, for the same eco-organism, can cost a UK seller €1,200 and a US seller €8,000 in the same calendar quarter, with no operational difference. This article walks through the real cost structure, what each line pays for, and where the spread comes from. By the end, you should be able to estimate your total annual French EPR cost before talking to any provider. ## What are the two layers of French EPR cost? Every foreign seller pays for French EPR through two distinct layers. Confusing them is the single biggest reason sellers feel overcharged. **Layer 1: the authorized representative's fee.** This is what your French *mandataire* charges for the work under the mandate: eco-organism membership, the identifier (IDU), the declarations, the exchanges with the eco-organisation and audits, and the archiving of your files. It is a service fee paid to a private French company, under a written mandate required by Article L. 541-10-9-1 of the French Environmental Code. **Layer 2: eco-contributions.** This is what the eco-organisation charges on the volumes you place on the French market, per unit or per kilogram, on a published scale. It funds collection and recycling. Your eco-contributions stay invoiced to you and paid by you directly to the eco-organisation; we take no percentage and no margin on them. The crucial point: **layer 1 varies by provider; layer 2 is set by the eco-organisation and does not**. If a provider quotes a single bundled figure without separating the two, ask harder questions. ## What do representative fees look like in 2026? The French market for representative services has three recognisable pricing models. ### Model A: traditional consultancy, quote-only Large or medium environmental consultancies handling EPR alongside other regulatory work (REACH, CE marking, waste audits, sustainability reporting). They quote case by case on stream count, perceived complexity, perceived client size and negotiation. Typical 2026 quotes for a foreign seller with three streams (packaging + WEEE + batteries): - Setup fees: €3,000 to €8,000 - Annual fees: €10,000 to €30,000 for the three streams (€3,500 to €10,000 or more per stream per year) - Sometimes volume-based escalators on top Pros: deep regulatory expertise, adjacent compliance topics in one place. Cons: pricing opacity, slow turnaround, commercial pressure to bundle services you may not need. ### Model B: sector specialist Smaller firms focused on one vertical (electronics, fashion, food, B2B) or one client type. Pricing varies widely. Typical 2026 fees: €2,000 to €6,000 setup, €3,500 to €10,000 or more per stream per year, sometimes on a retainer. Pros: sector expertise that saves time on scoping and declaration formatting. Cons: harder to find, may not scale if your catalogue expands into adjacent streams. ### Model C: fixed-fee specialist Providers with a fixed per-stream fee committed in a written quote before signature and a standardised onboarding. EPR Representative is in this category. Our model: a fixed annual amount per EPR stream, from €190/year excl. VAT for streams under the eco-organism flat-fee regime, confirmed in a written quote within one business day. 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. It is fixed in writing for the year and can only change for the following year, notified in writing by 15 September, or during the year if your scope changes, for example a new stream or a change of declaration regime. A one-time setup per stream and the security deposit are stated in the quote. Pros: predictable cost, written quote before any commitment, designed for producers with no French establishment. Cons: less flexibility for highly bespoke arrangements; not built for very large industrial clients with adjacent compliance needs. ### How do the three compare for a three-stream seller? Take a non-EU e-commerce seller with three streams (packaging + WEEE + batteries), shipping to French customers via Amazon FBA, with annual French revenue of €500,000. **Model A (traditional consultancy):** - Year 1: €5,000 setup + €8,000 annual = **€13,000** - Year 2 and beyond: €8,000 a year **Model B (sector specialist):** - Year 1: €3,500 setup + €5,000 annual = **€8,500** - Year 2 and beyond: €5,000 a year **Model C (fixed-fee specialist):** - Year 1: one written quote covering the three streams: a fixed annual fee per stream, a one-time setup per stream and the security deposit, confirmed within one business day - Year 2 and beyond: the annual fee per stream only, no setup repeat, fixed in writing for each calendar year The differentiator is not always pure cost; it is predictability, contract quality and speed of onboarding. ## What is the security deposit? A refundable security deposit equal to one year of your estimated eco-contributions, at least the eco-organisation's minimum billing, paid once by separate transfer to a dedicated account, never invoiced. It covers sums left unpaid under the mandate and is returned within sixty days of the end of the mandate, once the last contributions are paid. Annual fees cover a calendar year without proration: signing in the second half of the year means the current year's campaign, then next year's a few months later. ## How much are eco-contributions, stream by stream? For larger sellers, this is where the money is. Eco-contributions are calculated per unit or per kilogram on each eco-organisation's published scale, set annually for the following year. ### Household packaging (Citeo, Léko, Adelphe) The broadest stream: almost every foreign seller has packaging exposure. Weight rates run from **€0.02 to €2.80/kg depending on material** in the 2027 household grids (glass at the bottom, PVC at Léko at the top), with eco-modulation bonuses and penalties on top. Small producers pay a flat fee or a minimum instead: Citeo €110 under 10,000 consumer units; Léko €110 minimum in 2027. For a foreign seller shipping 1,000 orders a month in a standard cardboard box with a paper label, packaging eco-contributions land in the order of €600 to €1,500 a year. For 10,000 orders a month in rigid plastic outer packaging, expect €8,000 to €25,000 a year. The material-by-material grids are in our [2027 rates comparison](/blog/french-household-packaging-rates-2027-citeo-vs-leko). ### WEEE / DEEE (Ecosystem, Ecologic) WEEE eco-contributions are charged per device, by category. Indicative 2026 rates: - Small consumer electronics (under 250 g, e.g. earbuds): around €0.30 to €0.60 per unit - Mid-size electronics (smartphones, small speakers): around €0.80 to €1.50 per unit - Larger consumer electronics (laptops, tablets, monitors): around €2 to €5 per unit - Major appliances: around €5 to €25 per unit A non-EU electronics seller shipping 5,000 small-device orders a month to France pays in the order of €25,000 to €40,000 a year in WEEE eco-contributions. ### Batteries (Ecosystem) Batteries are charged by weight. Indicative 2026 rate: around €0.50 per kilogram placed on the French market. For a device seller shipping products with embedded batteries (~50 g average), 10,000 orders a month is ~6 tonnes a year, or around €3,000. ### Textile (Refashion) Charged per piece, with eco-modulation for durability, recycled content and repairability. Indicative 2026 rate: around €0.06 to €0.10 per garment under the detailed regime. Refashion's simplified regime is billed per piece at a higher rate (about EUR 0.58 per clothing item in 2026) and is reserved for fewer than 5,000 pieces a year with no eco-modulated product; the detailed regime is usually far cheaper per piece. ### Furniture (Ecomaison, Valdelia) Charged per unit, with wide variation by furniture type: - Small items (chairs, side tables): around €1 to €3 per unit - Mid-size (sofas, beds): around €10 to €25 per unit - Large items (storage, modular kitchens): can exceed €50 per unit ### Toys, sports and leisure, paper, construction Lower unit rates (a few cents per unit for most consumer items) that add up for high-volume sellers. Sports and leisure goods go to Ecologic, the only approved eco-organisation for that stream. Construction products (PMCB) are the most complex stream and need disproportionate setup time. ### Professional packaging (Citeo Pro, Léko Pro, Twiice; from 1 January 2027) The 2026 professional packaging scales were withdrawn when contributions moved to 2027. Citeo Pro and Léko Pro published their 2027 scales in October 2026 (both may still change; Twiice has not published yet). Compare them on our [comparator](/tools/epro-rates-comparator). Register now; contributions and identifiers start on 1 January 2027. Professional packaging means packaging of products used only by professionals; a package also sold to households stays household packaging, even when a business buys it. ## What does a full budget look like for an Amazon electronics seller? A representative profile: - Chinese-incorporated seller, no EU subsidiary - Sells bluetooth speakers and headphones on Amazon France via Pan-European FBA - Annual French revenue: €1.2 million (~50,000 devices shipped to French customers) - Streams: household packaging + WEEE + batteries - Representative: fixed-fee model (per-stream written quote) **Year 1:** Layer 1 (representative): a fixed annual fee per stream + a one-time setup per stream, all three streams in one written quote confirmed within one business day. The security deposit is paid once by separate transfer and returned at the end of the mandate. Layer 2 (eco-contributions, indicative): - Household packaging (50,000 small parcels in cardboard + paper labels): ~€2,500 - WEEE (50,000 small electronics, mid-tier): ~€30,000 - Batteries (50,000 devices × 1 battery × 30 g = 1.5 tonnes): ~€750 - Subtotal: **€33,250** **At this volume, eco-contributions alone run ~2.8% of French revenue; with the fixed representative fee added, the total typically lands between 3% and 4%.** **Year 2:** the annual fee per stream only (no setup repeat), fixed in writing for the calendar year, plus ~€33,250 of eco-contributions at flat volumes. ## Which hidden costs should you check before signing? Most surprise charges fit into one of these categories. Ask about each, in writing, before signing. **Per-SKU surcharges.** A "base fee" plus a charge per SKU above a threshold. A 200-SKU catalogue can pay €5,000 to €10,000 in surcharges that were not disclosed at the quote stage. **Volume tiers.** Pricing that jumps at revenue or tonnage thresholds; growth into the next tier triggers a re-negotiation. **A percentage of the eco-contribution.** Some providers add a percentage (often 10 to 15%) on top of what the eco-organisation charges. A producer paying €5,000 in eco-contributions then pays €500 to €750 more on top of the base fee. Ask for the eco-organisation's published scale and check what you are asked for against it, line by line. On our side there is nothing to check: your eco-contributions stay invoiced to you and paid by you directly to the eco-organisation. **Per-stream setup multiplied after signing.** Setup quoted once, then applied per stream. **Undisclosed renewal increases.** A year-1 teaser followed by new line items in year 2. A revision for the following year is legitimate when it is notified in writing in advance; discovering it on the invoice is not. **Per-declaration and per-update fees.** Filing the annual declaration, adding a SKU or updating volumes mid-year should be normal account maintenance, not extra lines. **Audit support.** Who answers the eco-organisation's requests and audits, and at what cost? A clean contract includes answers to the eco-organisation's requests and audits in the base fee. **Termination terms.** Our mandate runs for the calendar year from 1 January and renews tacitly each year. Either party may end it by registered letter received by 30 September, effective 31 December. Check that any other contract states its notice and exit terms as clearly. ### What does a quote with hidden costs add up to? A typical opaque quote for packaging + WEEE + batteries: - "Base fee, year 1: €4,500." - Disclosed only after signing: €30 per SKU above 100 SKUs. - Disclosed only at the first invoice: 12% on the eco-contribution. - Disclosed at year 2: a "standard tariff" of €5,200 a year. Actual year-1 cost for a 200-SKU producer with €4,000 of eco-contribution: €4,500 + (100 × €30) + (€4,000 × 12%) = **€7,980**, against the €4,500 disclosed. ### How do you compare quotes like for like? Ask every provider for written disclosure of: 1. Setup fee per stream. 2. Recurring fee per stream. 3. Per-SKU surcharges, if any, and the threshold. 4. Volume tiers, if any, and the threshold. 5. Any percentage on the eco-contribution, and the rate. 6. The year-2 recurring fee and how it can change. 7. Termination terms and any exit fee. A provider that cannot or will not put these in writing is signalling that its hidden cost structure is significant. ## What rules of thumb help calibrate a budget? For non-EU e-commerce sellers: - Total annual EPR cost (layer 1 + layer 2) as % of French revenue: typically **1% to 5%** - Of that, layer 1 typically represents **20% to 50%** for sellers under €500K French revenue, **5% to 20%** for sellers over €1M - Above €5M French revenue, layer 2 dominates; layer 1 becomes a rounding error A total above 10% of expected French revenue is unusual and worth challenging. A quote below 1% of French revenue including eco-contributions probably excludes the eco-contributions entirely. ## Frequently asked questions ### How much does French EPR compliance cost a foreign seller? Two separate layers. The representative fee is a fixed amount per stream and per calendar year, set in a written quote within one business day. Eco-contributions are set by each eco-organisation on its published scale, invoiced to you and paid by you directly to it. For most e-commerce sellers the total runs at 1% to 5% of French revenue. ### Is the entry-level representative fee really EUR 190 a year? Yes, as a starting point. EUR 190 per year excluding VAT per stream is the public entry price for streams under the eco-organism flat-fee regime. The actual fee depends on the declaration regime and frequency, the number of references and, above EUR 1,000 of eco-contribution per stream, its size, and is confirmed in a written quote within one business day. ### Can a representative charge a percentage of my eco-contributions? Some providers add a silent margin on top of the eco-organism's published rate. A clean fixed-fee model takes no percentage and no margin on eco-contributions or on eco-organism membership fees. Your eco-contributions stay invoiced to you and paid by you directly to the eco-organisation, so the amount you pay is the published scale. ### What is the security deposit for? A refundable security deposit equal to one year of your estimated eco-contributions, at least the eco-organisation's minimum billing, paid once by separate transfer to a dedicated account, never invoiced. It covers sums left unpaid under the mandate and is returned within sixty days of the end of the mandate, once the last contributions are paid. ### Do I owe eco-contributions on units that customers return? Yes. Eco-contributions are owed on the first placing on the French market, not on net sales after returns, so gross declared volumes are the regulatory basis rather than a return-adjusted figure. ### What happens if I open an EU subsidiary? If the EU subsidiary becomes the entity placing products on the French market without being established in France, it still needs a representative established in France. If it is established in France, it registers directly with the eco-organism. The eco-contributions apply either way, since they are tied to the products placed on the market. ### Can lighter packaging lower my eco-contributions? Yes, partially. Citeo and Léko apply eco-modulation bonuses for recyclable design, recycled content and weight reduction, and lighter packaging lowers the weight you declare. ### Can my representative get me a better Citeo or Refashion rate? No. The scales are public and uniform across members. What a good representative can do is help you capture eco-modulation bonuses and choose the eco-organisation whose scale fits your mix. ### Is there a minimum revenue below which registration is not required? No. There is no exemption threshold in French EPR: registration is due from your first sale in France. For most sellers active on Amazon France, a suspended listing costs more in lost sales per month than a year of compliance. ## What is the next step? [Request a written quote](/get-registered): you get the representative fee per stream and an estimated eco-contribution range for your catalogue within one business day. See [how our pricing works](/pricing). ## Sources & references All legal and regulatory claims in this article trace back to the following primary sources. Household packaging rates from the Léko 2027 grid (version of 8 October 2026) and the Citeo 2027 guide (updated 8 October 2026, replacing the 30 September version). - [Law No. 2026-602 of 8 July 2026, creating Article L. 541-10-9-1 of the French Environmental Code, Légifrance](https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000054399113) - [Citeo, éco-organisme emballages ménagers](https://www.citeo.com/) - [Léko, éco-organisme emballages](https://www.leko-organisme.fr/) - [Adelphe, éco-organisme vin, spiritueux, pharma (filiale Citeo)](https://www.adelphe.fr/) - [Ecosystem, éco-organisme DEEE, lampes, piles](https://www.ecosystem.eco/) - [Ecologic, éco-organisme DEEE et articles de sport et de loisirs](https://www.ecologic-france.com/) - [Refashion, éco-organisme textile, linge, chaussures (TLC)](https://refashion.fr/) - [Ecomaison, éco-organisme ameublement](https://ecomaison.com/) - [Valdelia, éco-organisme mobilier professionnel](https://valdelia.org/) - [ADEME, Agence de la transition écologique](https://www.ademe.fr/) - [Cadre général des filières REP, Ministère de la Transition écologique](https://www.ecologie.gouv.fr/politiques-publiques/cadre-general-filieres-responsabilite-elargie-producteurs)