Do I need a French EPR representative?

No. It gives a first indication based on how French EPR rules apply. The written scope we send after you contact us looks at your actual flows and products.

The producer is whoever first makes the product available in France. If a French reseller buys your goods, that reseller is the producer.

Extended Producer Responsibility — in French, responsabilité élargie du producteur (REP). The company that first places a product or its packaging on a market pays for its collection and recycling.

It is law. Article L. 541-10-9-1 of the French Environmental Code has applied since 10 July 2026.

Yes, if they are subject to French EPR and not established in France. The French requirement covers EU and non-EU producers alike. Check if you need a French EPR representative →

Penalties are set by article L. 541-9-5 of the French Environmental Code: administrative fines of up to €30,000 for failing to register, filing wrong data or not displaying the IDU, up to €7,500 per unit or per tonne placed on the market without meeting the obligation (€1,500 for individuals), and daily penalties of up to €20,000. Marketplaces operating in France can also deactivate your listings. Read the 2026 law and penalties explained →

Under the 2026 law the representative is subrogated in the EPR obligations covered by the written mandate: memberships, identifiers and declarations are handled in France on your behalf.

No. Eco-contributions follow each eco-organisme's public tariff. Our service fee is fixed per stream and quoted in writing before you sign.

Amazon.fr, Cdiscount, ManoMano, Fnac and other platforms operating in France request sellers' IDUs because French law makes them jointly responsible for non-compliant sellers.

If you are not established in France, yes. They are different layers: the eco-organisme is the scheme that collects and recycles and that you pay eco-contributions to, and the mandataire is the France-established company legally allowed to hold that membership and file your declarations. A producer established in France needs only the eco-organisme.

Only if your company is established in France. Since 10 July 2026, a producer not established in France designates a mandataire established in France by written mandate, and the membership and declarations are held through it.

Because since 10 July 2026 the membership has to be held by a mandataire established in France. Nothing is re-registered: your identifiers stay valid, your declaration history stands, the contributions you have paid are not paid again, and the membership is transferred into the mandate.

Both are approved for household and professional packaging, so it is a real choice. Their tariffs and eco-modulation differ by material, so compare against your own materials and tonnages rather than defaulting to the better-known name.

It depends on the plan. On Free you stay with the eco-organisme you are already with; on Standard we compare all approved schemes for your streams and review the eco-modulation. Either way you stay the producer and the choice is yours to approve.

There is a service fee that a French-established company would not pay, and the eco-contributions are the same either way when they are passed through at cost. For a producer not established in France, going direct is not an available option to compare against — it stopped being one on 10 July 2026.

Not if your company is not established in France. Since 10 July 2026 the eco-organisme membership and the declarations have to be held through a mandataire established in France. You still produce the underlying data — tonnages, materials, quantities — and the mandataire checks and files it.

It is usually translated as authorised representative, but that phrase also covers two other roles, under the EU packaging regulation and EU product safety rules. The French legal term is mandataire, and that is the role French EPR requires.

No. The mandataire is subrogated in the obligations it accepts, so it is the party pursued for a late or incorrect declaration. Representation that excludes the declarations is not something the law creates, or that a serious mandataire will sign.

No. Your identifiers stay valid and your declaration history stands. The membership behind them is transferred to a mandataire; nothing is registered again from scratch.

One written mandate can cover every French EPR stream you fall under, with one membership and one identifier per stream. You decide which streams the mandate covers.

No. A representative appointed under the EU packaging regulation in another member state, or a responsible person under EU product safety rules anywhere in the EU, does not satisfy the French requirement — which is national, covers all streams and requires establishment in France.

It depends on who buys. If your French customer resells the goods, that customer is the producer and you need no representative. If your French customer uses the goods itself, you are the producer in France and need a representative.

For packaging there is no general minimum: one parcel sent to a French customer can make you a producer. Some eco-organismes offer simplified flat-fee regimes for small volumes, but registration still applies.

Not the French requirement. It comes from national law (article L. 541-10-9-1, in force since 10 July 2026) and applies independently of the EU packaging regulation debate.

If the distributor buys your goods and resells them in France, it is the producer by law. Put the split of roles and the packaging weight data it needs in your supply contract.

The EU sets EPR rules for packaging (Regulation (EU) 2025/40), electrical and electronic equipment and batteries, but each member state runs its own registers and schemes. Registering in one country does not cover another, and France adds national streams such as furniture, toys and DIY products.

Yes. It has applied since 10 July 2026, the day after law n° 2026-602 was published in the Journal officiel.

Yes. It applies to every producer not established in France, including companies established elsewhere in the EU.

The law requires a natural or legal person established in France acting under a written mandate. We found no separate licence or accreditation requirement.

Eco-contributions follow each eco-organisme's public tariff and are owed for the producer's volumes. The representative handles membership, identifiers and declarations; invoicing depends on the scheme and the mandate.

EPR stands for Extended Producer Responsibility, REP (responsabilité élargie du producteur) in French. The company that first places a product on the French market pays for collecting and recycling it through an approved eco-organisme and holds an IDU for each scheme.

Under article L. 541-9-5 of the Environmental Code: up to €30,000 for not registering, filing wrong data or not showing the IDU; up to €7,500 per unit or tonne concerned for not meeting the EPR obligation (€1,500 for individuals); and a daily penalty of up to €20,000 until the breach is fixed. Marketplaces can also deactivate listings.

Yes, for household products under an EPR scheme, including household packaging except glass beverage packaging. The logo must come with sorting instructions (Info-tri). For electronics and batteries the crossed-out wheelie bin can replace the logo, but not the sorting instructions.

No. Article L. 541-10-9-1 contains no minimum volume, turnover or de minimis threshold. The duty follows from being subject to EPR at all, which comes from placing covered products on the French market. Low volumes can reduce what you pay an eco-organisme through flat-rate tariffs, but they do not remove the obligation.

Article L. 541-10-9-1 of the Code de l'environnement, on Légifrance. It was created by law n° 2026-602 of 8 July 2026, article 5, and has applied since 10 July 2026. It is two paragraphs long and quoted in full in this guide.

No. The IDU is specific to Extended Producer Responsibility and to one EPR scheme. It is unrelated to VAT or company registration numbers.

Professional (B2B) packaging is a separate scheme from household packaging, so it requires its own membership and identifier.

An IDU follows membership of an approved eco-organisme or an approved individual system. In practice most producers join a collective eco-organisme.

The operational start is 1 January 2027, after postponement from 1 July 2026. Companies are expected to join an eco-organisme before 31 December 2026.

Citeo Pro, Léko Pro and Twiice are approved for the professional packaging scheme.

No. Professional packaging is a separate scheme with its own membership, declarations and identifier.

If the French customer uses the goods itself, the exporter is the producer in France and needs a French representative. If the customer resells them, the customer is the producer.

Some providers price on perceived ability to pay rather than on workload, and quotes often mix service fees with eco-contributions. Ask for the two layers separately.

No. Eco-contributions follow the eco-organisme's public tariff. What can differ is the choice of eco-organisme where several are approved, and the accuracy of your declared weights and materials.

Many eco-organismes offer flat-rate regimes for small quantities, so the minimum is typically a small flat contribution per scheme plus the representative's service fee.

No. As of 15 September 2026 the suspension has not been adopted; the requirement applies as written.

No. Under the PPWR a representative is appointed per member state; there is no single EU-wide representative.

If you are subject to French EPR and not established in France, yes: the French requirement is national law and applies independently.

No. The declaration of conformity and the technical file are packaging product obligations that sit with the manufacturer and the importer under Regulation (EU) 2025/40. An EPR representative handles registration, declarations and eco-contributions in France. You need both.

Not your sales volume, and not the number of streams: all 19 are included on every plan. The plan decides how the work is split. On Free you enter your own figures and we file them. On Standard and Pro we do the data work. Registration and IDU issuance is included in Pro and added per stream on Standard.

No. Eco-contributions are set by each eco-organisme's public tariff and are prepaid yearly at cost, with 0% markup. We pay the eco-organismes from that prepayment and settle the difference on your actual declaration.

No. Setup is €0 on every plan, Standard and Pro included. The only one-off charge is registration and IDU issuance on Standard, at €190 per stream, and that is only for streams you are not already registered for.

Yes. Moving up applies immediately. Moving down applies at the next renewal.

Yes — that is what the Free plan is for. If you are already registered and hold your IDU, €0 a year covers the written mandate, the membership held under our mandate and your annual declaration filed from the figures you enter. Registration and IDU issuance is the part you no longer have to pay for.

No. Eco-contributions are paid once for the period declared, and declarations you have already filed stand. From the next declaration period they are prepaid through the mandate at cost, with 0% markup.