PPWR Article 45, in force since 12 August 2026. In France, since 10 July 2026, Article L. 541-10-9-1 requires a producer not established in France to appoint a representative established in France.Request a written quote →
Three pre-written press releases on French EPR and PPWR 2026, ready for trade publications, journalists, partner blogs and analyst briefings. Each release is kept as originally published, with its date; later changes in the law are noted in a dated update. Free to publish in full or in part with credit to EPR Representative and a link to eprrepresentative.com. For exclusivity, commentary or quotes, write to contact@eprrepresentative.com.
Press release · PR-2026-01
PPWR Article 45 Application: 200,000 Foreign Sellers Need French Authorised Representatives by August 2026
Originally published · Paris, May 2026
On 12 August 2026, Article 45 of Regulation (EU) 2025/40 (the Packaging and Packaging Waste Regulation, PPWR) becomes directly applicable across all 27 European Union Member States. The regulation requires every producer of packaging not established in the destination Member State to designate, in that Member State, an authorised representative for extended producer responsibility. For foreign sellers, US, UK, Chinese, Hong Kong, Singaporean and other non-EU brands shipping packaged goods to European consumers, the obligation multiplies per Member State of shipment.
Industry estimates place the affected cross-border seller population in the range of 150,000-250,000 entities. France, the second-largest e-commerce market in the EU after Germany, is among the most frequent first destinations and the most heavily enforced through marketplace verification (Amazon France, Cdiscount, ManoMano, Fnac/Darty, TikTok Shop FR all query the public ADEME SYDEREP register before allowing third-party listings).
"The 12 August date is operationally close for any seller starting from zero. The mandate is signed electronically and the identifier follows within days of membership, about seven business days after the membership is validated at Citeo, but producers typically register for 2 to 4 streams, each with its own eco-organisation, so you need to be in motion now, not in July," says Léo Escourrou, founder of EPR Representative, a France-established mandataire REP for producers with no establishment in France.
EPR Representative operates on a public entry price (from €190/year excl. VAT per stream) with the exact fee fixed in a written quote within one business day, stating the annual fee, the one-time setup per stream and a refundable security deposit. The company contrasts this written-and-fixed approach with a French market it describes as "the most price-opaque corner of EU compliance services." The firm's open-data French EPR Market Benchmark 2026, published under CC BY 4.0, documents the segmentation between SaaS subscription platforms, fixed-fee specialists, and quote-only incumbents (€3,500 to €10,000 or more per stream per year on aggregated prospect quotes).
About EPR Representative. Paris-based France-established mandataire REP for producers without a French establishment (EU and non-EU), under Article L. 541-10-9-1 of the Code de l'environnement (law n° 2026-602 of 8 July 2026, in force since 10 July 2026) and PPWR Article 45, in force since 12 August 2026. Covers all 19 regulated French EPR streams: packaging (Citeo, Léko, Adelphe), WEEE (Ecosystem, Ecologic, Soren), textile (Refashion), furniture (Ecomaison, Valdelia, Valobat), batteries (Ecosystem), toys, sports and leisure (Ecologic), DIY and garden, graphic paper, construction (Valobat, Ecominéro), professional packaging (Citeo Pro, Léko Pro, Twiice). More: eprrepresentative.com.
Press release · PR-2026-02
French EPR Market Pricing Variance Hits 3x for Identical Scope, Open Benchmark Finds
Originally published · Paris, May 2026
A new open-data benchmark of the French Extended Producer Responsibility (EPR) provider market, released today by Paris-based mandataire REP firm EPR Representative under a Creative Commons Attribution 4.0 license, documents a 3x pricing variance for identical scope of work across the main French EPR provider archetypes.
The benchmark synthesises four data sources: public provider pricing pages where available, anonymised competitor quotes shared with the firm by prospects during scoping conversations, ADEME and eco-organism published documentation, and internal operational data. It compares provider archetypes, not named firms: specialised French mandataires REP, multi-country VAT and EPR platforms, multi-country EPR groups, large sustainability consultancies, and the Amazon France Pay-on-Behalf payment service.
Key findings:
The market is segmenting into 3 strata in 2026: SaaS subscription platforms; fixed-fee specialists, which publish an entry price and fix the exact fee in writing (EPR Representative works from €190/year excl. VAT per stream); quote-only incumbents, at €3,500 to €10,000 or more per stream per year on aggregated, anonymised prospect quotes.
Amazon Pay-on-Behalf is a payment service, not legal representation. If a marketplace takes on the EPR obligation for your products under Article L. 541-10-9 of the French Environmental Code (as Amazon offers to do in France), the obligation is deemed met for those products only, and only while you are not registered yourself. Anything sold outside that scheme, or once you register, remains your obligation.
The identifier follows membership within days, on each eco-organisation's own process: 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 first declaration has been filed and paid at Ecosystem.
Eco-organism small-producer floors are remarkably consistent in 2026: Citeo €110/year (less than 10,000 UVC), Léko €95 capped €150 (less than 20,000 UVC), Ecomaison €60/year (plus €50 one-off adhesion), Valobat €80 administrative minimum.
Pan-EU consolidation accelerated in 2025: Ecosystem (ex-Corepile) took over portable batteries, Reclay/Activate aggregated multiple PRO partnerships, Landbell and Interzero are acquiring national specialists. PPWR Article 45 mandatory authorised representative in 27 EU states (12 August 2026) is driving a market-expansion event with capacity squeezes expected in H2 2026.
"We published this because the French EPR market is the most price-opaque corner of EU compliance services," says Léo Escourrou, founder of EPR Representative. "Sellers cannot get comparable quotes, journalists cannot find reference numbers, partners cannot benchmark their referrals. This is our contribution, methodology open, license CC BY 4.0, refreshed quarterly."
The French EPR Representative Is Now Compulsory: Why Mandate Templates Written Before 10 July 2026 Need to Be Rewritten
Originally published · Paris, July 2026
Law n° 2026-602 of 8 July 2026, article 5, 2°, created Article L. 541-10-9-1 of the Code de l'environnement (JO of 9 July 2026, NOR TECX2407166L). Since 10 July 2026, any producer not established in France and subject to EPR must appoint a representative established in France, by written mandate, for every stream. For packaging, Article 45 of Regulation (EU) 2025/40 (PPWR) adds the same requirement at EU level. The rule is national and covers every French EPR stream, independently of the PPWR.
EPR Representative reports that a substantial portion of French mandate templates still in circulation were written when appointing a representative was an option. For a producer without a French establishment, that framing no longer matches the law, and it leaves the parties without the clauses the new regime calls for: what the representative takes charge of, the duration, the start date, and the deposit. The Conseil d'État EcoDDS ruling of 10 November 2023 (n° 449213) now concerns producers established in France only.
"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. The question to ask a prospective representative is whether its template was rewritten for the statute: what it covers, for how long and from what date," says Léo Escourrou, founder of EPR Representative.
Logo, founder portrait, EPR process diagram, PPWR timeline graphic, penalty grid diagram and EU multi-country map are all available on our press kit page. Open Graph image and other downloadable assets are linked from there.
