EPR France 2026 Compliance Checklist for Foreign Sellers

1. The 19 French EPR streams

Each stream is run by one or more eco-organisms accredited by the French state. You register, declare, and pay separately per stream. A single SKU can be subject to several streams (a Bluetooth speaker = packaging + WEEE + batteries). The table below shows the most common of the 19 official streams.

2. The documents to gather before applying

Before contacting an authorized representative, prepare these: they speed up onboarding from weeks to days.

1. Exact company name, legal form and registered address
2. Registration number and tax identifier in your country, EU VAT number if you have one
3. Company register extract less than three months old
4. Name and position of the signatory, who must appear on the extract, otherwise a written delegation
5. Full product scope, by reference or by product family
6. Volumes per stream in the stream's unit, and volumes of the three previous years if you already sell
7. Date of your first sale in France
8. Sales channels and customers, households or professionals
9. Who imports and who owns the goods when they enter France
10. Identifiers and memberships you already hold, with access or certificate
11. Billing details and operational contact, with phone number
12. Written acceptance of the deposit amount
13. Bank details on a document issued by your bank

Never an identity document. These are the same documents as a membership without a representative.

3. The 5-step path from zero to IDU

1. 1.

   Identify which streams apply

   Day 0

   Map each product type against the 19 official streams (the most common are tabled above). A single SKU can fall under several. Mistakes here cause rejection or under-declaration penalties.

2. 2.

   Appoint an authorized representative

   Day 1 to 3

   A producer not established in France must appoint a representative established in France, by a written mandate under Article L. 541-10-9-1 of the Code de l'environnement, signed electronically (no notary). You remain the producer.

3. 3.

   Eco-organism membership filing

   Within two business days

   We file your membership within two business days of receiving the signed mandate, the first invoice payment and the deposit: company file, product catalog and volume estimate to each relevant eco-organism (Citeo for packaging, Refashion for textile, Ecosystem for WEEE…). One filing per stream.

4. 4.

   The eco-organism issues your IDU

   Within days

   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. Ecosystem issues it after your first declaration has been filed and paid. The IDU is recorded on SYDEREP, the register marketplaces query.

5. 5.

   Upload IDU to each marketplace

   Once issued

   In Amazon Seller Central, Cdiscount Pro, ManoMano, Fnac, etc., paste the IDU into the EPR section per category. Reactivation timing depends on the marketplace.

4. Marketplace-specific rules

5. What it costs (and to whom)

French EPR has three cost layers. Be sure you understand the difference, most provider pricing you will see quoted only covers layer 1.

For a typical Amazon FBA seller with 3 streams (packaging, WEEE, batteries), our fee is a fixed annual amount per stream, stated in a written quote within one business day; quote-only providers commonly charge €3,500 to €10,000 or more per stream per year.

6. PPWR August 2026, what changes for foreign sellers

Regulation (EU) 2025/40 (PPWR) has applied directly since 12 August 2026. The most important change for foreign sellers sits in Article 45:

“Where the producer is not established in a Member State, the obligations shall be fulfilled by an authorised representative for extended producer responsibility, established in that Member State.”, PPWR Article 45(1)

• ✓Same representative model, EU-wide. 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.
• ✓No grace period. The regulation is direct-effect, it doesn't require national transposition. Marketplaces will block listings without proof of representative.
• ✓Packaging-only scope. PPWR covers packaging. WEEE, textile, furniture, etc. remain under their national EPR laws (which already require a representative in France).

7. Penalties under Articles L. 541-9-5 and L. 541-9-4 of the Code de l’environnement

Non-compliance is sanctioned under Article L. 541-9-5 of the Code de l'environnement, after a formal notice from the administration. The penalty structure is severe:

• ✓Up to €30,000 for placing products on the market without registering or obtaining an IDU.
• ✓Up to €7,500 per unit or per tonne for a company (€1,500 for an individual) for a substantive breach.
• ✓Marketplace deactivation. Article L. 541-10-9 obliges marketplaces to verify your registration and to deactivate listings when it is missing.

Amounts checked on Légifrance on 6 October 2026 (Article L. 541-9-5 of the Code de l'environnement).

8. The 5 most common rejection reasons

These are the patterns we see when a foreign seller's file is delayed or rejected. Each one is preventable.

1. 1. Wrong stream selection. A toy with a battery needs three filings (packaging + toys + batteries), not one. Single-stream applications get rejected when the catalog reveals others.
2. 2. Outdated register extract. Eco-organisms ask for a company register extract less than three months old. Older extracts are routinely refused.
3. 3. Unverifiable product description. Vague descriptions like “general merchandise” are rejected. Use the eco-organism's own category nomenclature.
4. 4. Underestimated tonnage. Declaring 10 kg when shipments visibly exceed that triggers an audit. Better to over-estimate slightly and correct downward.
5. 5. Sequence error: marketplace before IDU. Don't upload a pending IDU to Amazon, the listing will be blocked again on the next check. Wait for the SYDEREP confirmation.

9. Info-tri and Triman

Household packaging and graphic papers sold in France carry the Triman and the Info-tri sorting instructions. Check each point before you print. Full rules in our Info-tri and Triman guide.

• ✓Product sold to households (household packaging or graphic papers)
• ✓Every separable element listed with its destination
• ✓Size thresholds checked (10 and 20 cm², 20 and 40 cm² for round packaging)
• ✓FR tab placed first if the packaging is also sold abroad
• ✓Green Dot removed
• ✓Triman at least 10 mm, or 6 mm in the compact format
• ✓Shipping box delivered to consumers marked
• ✓Membership done, to access the official files
• ✓Not yet a Citeo or Léko member

10. Glossary, 12 acronyms you'll encounter

IDU

Identifiant Unique. The 12-character ID assigned by ADEME per EPR stream after eco-organism registration.

ADEME

Agence de la transition écologique. The French environmental agency that holds the SYDEREP registry and audits compliance.

SYDEREP

The ADEME system that publishes every IDU. Marketplaces query it.

AGEC

Loi anti-gaspillage pour une économie circulaire (2020). The law that introduced most current EPR obligations.

L. 541-10

Article of the Code de l'environnement that defines the producer (or representative) liability.

L. 541-9-5

Penalty article: up to €30,000, plus up to €7,500 per unit or tonne (company; €1,500 for an individual) for a substantive breach.

PPWR

Packaging and Packaging Waste Regulation (EU 2025/40). Applies since 12 August 2026.

TLC

Textile, linge de maison, chaussures. The textile EPR stream run by Refashion.

PMCB

Produits et matériaux de construction du bâtiment. Construction EPR stream.

DEA

Déchets d'éléments d'ameublement. Furniture EPR stream.

EPRO

Emballages professionnels. B2B packaging stream.

Eco-organism

State-authorized non-profit collecting EPR fees on behalf of one or more streams.