Market entry · French EPR

Selling in France as a non-EU brand: the French EPR map.

Three things decide whether your products can be sold in France under French extended producer responsibility (EPR): your registration through a representative established in France, the Info-tri marking on your packaging, and the identifiers your marketplaces check. This page covers them, in order.

Start the EPR application →See EPR pricing

What do I need to sell in France?

On the EPR side, three things: registration through a representative established in France, the Info-tri marking on household packaging, and the identifiers your marketplaces check. Each pillar below lists what it involves. VAT and customs are outside our scope: see a VAT or customs adviser for them.

Pillar 1

EPR (this is our focus)

Mandataire REP
France-established representative appointed under the written mandate required since 10 July 2026 by Article L. 541-10-9-1 (law n° 2026-602). You remain the producer; 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. Our fee: a fixed annual amount per stream, from €190/year excl. VAT, confirmed in a written quote within one business day, with the one-time setup and the refundable deposit stated.
Eco-organism registration
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.
IDU publication on SYDEREP
It depends on the eco-organisation. Citeo: about seven business days after the membership is validated. Léko: 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. Refashion: after membership, the signed contract and the first declaration with its payment, then about ten business days. Ecosystem: after the first declaration has been filed and paid. Queryable on syderep.ademe.fr.
Declarations
Most streams are declared once a year; Ecomaison and Valdelia quarterly, Ecominéro monthly, Ecosystem electrical equipment quarterly unless paid by SEPA direct debit. The eco-contribution is then set by the eco-organism on the declared volumes, separate from our fee; your eco-contributions stay invoiced to you and paid by you directly to the eco-organisation.

Pillar 2

Packaging marking (Info-tri)

Info-tri marking (with the Triman logo)
Mandatory on household packaging since 1 January 2022, always together with the Info-tri. The official files come with your Citeo or Léko membership; the artwork stays with you and your designer.
Info-tri sort instructions
Sorting information accompanying the Triman logo: each separable element and where it goes. 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.
Recyclability classes (from 2030)
PPWR Article 6: Grade A/B/C. Plan packaging redesign now for 2030 readiness.
Recycled content minimums
PPWR Article 7: no obligation on 12 August 2026. The first PCR thresholds for plastic packaging apply on 1 January 2030, and rise again on 1 January 2040.

Pillar 3

Marketplace verification

Amazon France
Seller Central → Compliance → EPR France. Enter each identifier per stream.
Cdiscount
Identifier entered in the seller account for each stream.
ManoMano
EPR identifiers asked at seller onboarding and when you open a new category.
Fnac / Darty Marketplace
EPR identifiers asked at onboarding.
All marketplaces
Marketplaces check identifiers before and after listing: keep each identifier current in every seller account.

In what order should I tackle market entry?

Streams first, mandate second, marketplaces last:

List your streams. Each product can fall into several streams: the packaging, the device itself, a battery inside it.
Accept the written quote and sign the mandate. The quote states the fixed annual fee per stream, the one-time setup and the refundable deposit.
Memberships. We file your eco-organisation memberships within two business days of the signed mandate, the first invoice payment and the deposit. Begin the Info-tri artwork updates with your packaging supplier.
Identifiers. About seven business days after the membership is validated at Citeo; at Refashion, after membership, the signed contract and the first declaration with its payment, then about ten business days; at Ecosystem, after the first declaration has been filed and paid.
Marketplaces. Enter each identifier in your seller accounts (Amazon, Cdiscount, ManoMano). Marketplaces check identifiers before and after listing.

Who is the EPR producer when goods enter France?

The EPR obligation starts with the first placing on the French market. Who owns the goods when they enter France decides who is the EPR producer, not the importer of record. Neither the brand on the label, the Incoterm nor the customs clearance decides it on its own: the transfer of ownership does. The criterion for needing a representative is establishment in France, not EU membership.

Practical consequences:

You ship from Shenzhen direct to a French consumer. You own the goods when they enter France, so you are the producer for French EPR (Article L. 541-10 II of the Code de l'environnement) and need a representative established in France.
You use Amazon FBA France warehouses. You still own the stock when it enters France, so you remain the producer. Amazon is the fulfilment provider, not the producer.
Amazon moves your stock into French warehouses from another country. You own that stock when it enters France, so French EPR applies from your first French sale.
You sell B2B to a French distributor who takes ownership before the goods enter France. The distributor is the producer for those goods and you do not need a mandataire REP for them. Check when ownership actually transfers in your contract.

How does each sales channel handle EPR?

Channel	Producer responsibility	Marketplace verification	Special considerations
Amazon France FBA	You (seller of record). Amazon is fulfilment only.	Identifiers checked before and after listing	Highest enforcement. Recovery guide
Amazon FBM (Fulfilled by Merchant)	You (seller of record)	Same as FBA, Amazon does not distinguish FBM from FBA for EPR	One identifier per stream, as for FBA
Cdiscount marketplace	You	Identifiers checked before and after listing	No identifier, no listing
ManoMano	You	EPR verification at onboarding and category expansion	DIY, sports, garden, furniture all checked
Shopify D2C	You	No platform-level EPR check (Shopify is a storefront, not a marketplace)	Same legal obligation, checked by the administration
TikTok Shop FR	You	Identifiers checked before and after listing	Register before you list
B2B distributor (chain of title)	French distributor (if they own the goods when they enter France)	N/A	Check when ownership transfers; the Incoterm alone does not decide

Which mistakes delay market entry?

Leaving EPR until the listings are ready. Start it first. We file your membership within two business days of receiving the signed mandate, the first invoice payment and the deposit, and Citeo issues the identifier about seven business days after the membership is validated. The mandate can be signed as soon as you accept our written quote.
Choosing an eco-organisation without comparing. For household packaging, Citeo and Léko publish different schedules and different identifier timings. We are eco-organisation-neutral: the quote states which one we propose for your products and why.
Forgetting embedded batteries. A wireless mouse has a battery inside. The Bluetooth speaker has a battery inside. The toy with a flashing light has a battery inside. These all trigger the batteries stream separately from the WEEE stream the device itself triggers. Two filings, two IDUs.
Missing Info-tri marking. Household packaging without the full Info-tri (Triman logo plus sorting instructions) has been non-compliant since January 2022 (Décret 2021-835). A missing Info-tri can cost up to €3,000 for an individual or €15,000 for a company per reference (Article L. 541-9-4 of the Code de l'environnement).
Underestimating catch-up declarations. 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. Gather your past French sales before you join.
Trusting Amazon Pay-on-Behalf for non-Amazon channels. 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. PoB does not produce an IDU and does not cover Cdiscount, ManoMano or Shopify direct sales. Don't use it as a multi-channel solution.

What a business like yours pays in year one

From €190/year excl. VAT, per stream.

Already registered with a French eco-organisation, household packaging: you prepare your declarations, we check and file them

Setup, once: €290
Annual fee: €190
Refundable deposit: equal to the eco-organisation’s annual minimum (€110 at Citeo or Léko in 2027)
Eco-contribution, paid to the eco-organisation: from €110 a year

Risk of doing nothing: A missing or inaccurate declaration: up to €30,000, and up to €7,500 per unit or tonne for a company (€1,500 for an individual), Article L. 541-9-5 of the French Environmental Code.

New brand, household packaging, small volume: we prepare and file

Setup, once: €290
Annual fee: €350
Refundable deposit: €110
Eco-contribution, paid to the eco-organisation: €110 a year at Citeo below 10,000 units in 2027

Risk of doing nothing: Selling without registration or without displaying your identifier: up to €30,000 (Article L. 541-9-5). Packaging without Info-tri: up to €15,000 per reference for a company (€3,000 for an individual), Article L. 541-9-4.

Marketplace seller, household packaging and electronics: we prepare and file

Setup, once: €1,050 (packaging €290 + electronics €760)
Annual fee: €1,150 (packaging €450 + electronics €700, electronics on annual declaration with direct debit at Ecosystem)
Refundable deposit: about one year of estimated eco-contributions (minimum €110 + €200)
Eco-contribution, paid to the eco-organisation: per the eco-organisations’ published scales

Risk of doing nothing: Listings blocked by the marketplace without an identifier for each stream, and for each stream the penalties of Article L. 541-9-5: up to €30,000, and up to €7,500 per unit or tonne for a company.

Your quote is fixed in writing within one business day. Eco-contributions are invoiced to you directly by the eco-organisation; we take no percentage on them.

Request a written quote →

When should you not enter France?

An honest take: market entry is not always worthwhile. Three profiles where you should reconsider:

You expect very little French revenue. EPR costs are fixed per stream and per year whatever you sell. Compare the year-one profiles above with your expected French margin before you start.
Your products fall into 5+ EPR streams. A multi-category seller (electronics + batteries + packaging + textile + toys) faces 5 simultaneous registrations, 5 sets of declarations, 5 separate cost trajectories. The compliance overhead is substantial. Consider focusing your French catalog to 1-2 streams for the first year and expanding once the operational machinery works.
You sell ultra-fast-fashion or non-recyclable products. Refashion's 2025-2027 eco-modulation framework penalises non-durable / non-recyclable textile heavily (up to +25% on the per-piece contribution). Same logic applies to non-recyclable packaging via Citeo's recyclability matrix. If your product line is structurally on the wrong side of these grids, the eco-contribution can rival the gross margin.

For deeper dives per pillar

EPR: complete EPR compliance guide; legal framework pillar; how our pricing works
Info-tri marking: Info-tri and Triman explained; sorting information for every EPR scheme
Marketplace verification: marketplace EPR pillar; Amazon FR recovery
PPWR: PPWR cornerstone
Country-specific: US, UK, China, Canada

Frequently asked questions

In what order should I tackle French EPR as a non-EU brand?

Practical order: (1) list your products by French EPR stream (household packaging, electrical equipment, batteries, textiles and so on). (2) Appoint a representative established in France by written mandate, compulsory since 10 July 2026 under Article L. 541-10-9-1 of the French Environmental Code. (3) Eco-organisation memberships and identifiers (IDU). (4) Info-tri marking on household packaging. (5) Enter each identifier in your marketplace seller accounts. VAT and customs are outside our scope: see a VAT or customs adviser for them.

How long does the EPR side of market entry take?

We file your eco-organisation memberships 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. Packaging artwork updates for the Info-tri depend on your print cycle.

What does French EPR cost in the first year?

Our fee is a fixed annual amount per stream, from €190/year excl. VAT, set in a written quote within one business day; the one-time setup per stream and the refundable deposit are stated in the quote. The year-one profiles on this page show typical budgets. Eco-contributions come on top, set by each eco-organisation on its published schedule according to your volumes, invoiced to you and paid by you directly to the eco-organisation: we take no percentage on them.

Can I delay EPR until after I have French revenue?

Technically yes, legally no. The producer obligation under Article L. 541-10 II of the Code de l’environnement applies from your first French sale, and since 10 July 2026 a producer not established in France must appoint a representative established in France. Marketplaces (Amazon France, Cdiscount, ManoMano) check identifiers before and after listing, so delaying EPR delays your launch on those channels. Shopify D2C has no marketplace check but the legal obligation is the same.

Which is the highest-risk EPR gap for new entrants?

A missing or wrong identifier. Marketplaces check identifiers before and after listing, and a listing without a valid identifier for its stream can be blocked. The administration can also impose sanctions under Article L. 541-9-5 of the Code de l’environnement, after a formal notice: up to €30,000 for non-registration, inaccurate data or an identifier not displayed, plus up to €1,500 for an individual or €7,500 for a company per unit or per tonne. A missing Info-tri can cost up to €3,000 or €15,000 per reference (Article L. 541-9-4).