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AnswersOne question, one answer, one source
The specific questions we are asked, each answered on its own page with the article it comes from and the date it was checked. Broader background lives in the guides; situations live in the use cases.
Grouped by subject. Every answer states the rule, the source and the date it was last checked.
Who needs a representative 3
We are an EU company. Do we really need a French EPR representative?Yes, if you have no establishment in France and you sell directly to French end users. Article L. 541-10-9-1 is written around establishment, not nationality: it catches any producer not established in France, whether it sits in another member state or outside the EU. Being in the single market does not exempt you, and a representative appointed in your own country does not cover France.We only sell to businesses, not consumers. Do we still need a French EPR representative?Often yes. EPR is not only for consumer goods: professional packaging (pallets, film, crates) becomes a paying stream on 1 January 2027, and construction products, professional electrical equipment and chemicals are business streams already. If you deliver to the French company that uses your goods, you are the producer and, without a French establishment, you need a representative (article L. 541-10-9-1). If you sell to a French distributor that resells, the distributor is usually the producer, and for construction products it pays unless you have contributed.My product has a built-in rechargeable battery. Which French EPR streams apply?Usually three: the device is electrical and electronic equipment (Ecologic or ecosystem), the battery inside it is declared separately in the batteries stream (Batribox or ecosystem), and the box it ships in is household packaging (Citeo, Léko or Adelphe). A company not established in France needs a representative established in France for all three, and gets one IDU per stream.
Establishment and status 2
Does a French VAT number mean I am established in France?No. French tax law itself runs a category for foreign companies that are liable for French VAT and have no permanent establishment in France — the tax authority publishes guidance addressed to exactly those companies. A VAT number is a tax registration, not an establishment, so it does not remove the duty to appoint a French EPR representative under article L. 541-10-9-1.Does stock in a French warehouse or 3PL make me established in France?Almost always no, and it cuts the other way. Using a French warehouse or third-party logistics provider does not give you an establishment: the warehouse is your supplier's premises, not yours, and the operator is not your producer. What holding stock in France does confirm is that you are first on the French market for the goods you ship from it — so you are the producer, and without an establishment you need a representative.
Who is the producer 1
Professional packaging (EPRO) 4
Is my packaging household (EMPAP) or professional (EPRO)?It is decided by the arrêté of 2 December 2025, not by who your customer is. Work through three steps: does a product stream claim the packaging first, is it on the automatic EMPAP or EPRO list, and if neither, the répartition tables settle it by product type and volume. The exception that catches most online sellers: packaging used to ship e-commerce orders to consumers is EMPAP, even though it is transport packaging.Do I have to do anything about EPRO before 1 January 2027?Yes. The scheme applies from 1 January 2027, but ADEME asks producers to join an eco-organisme before 31 December 2026 — so the practical deadline is the end of this year, not the start of next. If you have no French establishment there is a step before that: the eco-organisme membership is held through a French representative, appointed by written mandate, so the mandate has to exist first.Who is the producer for professional packaging in France?Whoever first places the packaged product on the French market, professionally — article L. 541-10. It is not decided by who owns the pallet, who pays the freight or which Incoterm you use. If a French importer or distributor buys from you and is the first to place the goods on the market in France, that company is the producer. If you ship straight to the French business that uses the goods, you are.Which eco-organisme do I join for professional packaging, and can I run my own system?Three are approved, all on 5 June 2026: Citeo Pro, Léko Pro and Twiice. Any of them discharges the obligation, so the choice is about tariffs, materials and service rather than legality. There is a second route for pooled pallets: three approved individual systems — Euro Pool System France, La Palette Rouge and International Pallet Pool BV — which may already carry the obligation for pallets circulating in them.
Marketplaces 11
Amazon or another marketplace says it handles EPR. Am I covered?Partly, and only for that channel. Where a marketplace established in France ensures the EPR obligations for products it sells for you, article L. 541-10-9-1 treats your representative duty as satisfied for those products. It does not register you, it does not give you an IDU, and it does nothing for your own website or any other platform. Amazon asks sellers for their own identifier and deactivates listings without one.Is Amazon's EPR Pay on Behalf enough in France?Only for what you sell on Amazon.fr. If you have not given Amazon a valid French EPR number for a category, Amazon enrols you in Pay on Behalf: it reports your Amazon.fr sales to an eco-organisme, pays the eco-contributions and recovers them from your seller account, plus a service fee of €25 per EPR category a year since 1 January 2026. You get no membership and no IDU in your name, and your own website, other marketplaces and B2B sales stay uncovered.Amazon charges me French eco-contributions although I am a Citeo member. Why?Because Pay on Behalf works category by category. Amazon enrols you in a category whenever it has no valid French EPR number from you for it before the end of the reporting cycle, even if you are already a member of Citeo or another eco-organisme. Check that your IDU is entered for each category Amazon lists, under the same legal entity as your seller account; Amazon then stops paying on your behalf for that category.Selling on Cdiscount: which EPR numbers does it ask for, and what happens without them?Cdiscount asks for a valid IDU for every EPR stream you sell in, entered under Settings › Se conformer à la loi AGEC. Without one, Cdiscount declares and pays for you and bills you the higher simplified eco-contribution scale plus 7.3% of that amount per stream, taken from your sales.Selling DIY, garden or home products on ManoMano: what does French EPR require?ManoMano is a French marketplace, so article L. 541-10-9 applies to it: it must pay for sellers who give it no IDU, or collect one IDU per stream from those who have them. A DIY and home catalogue often spans several streams: DIY and garden tools, furniture, electrical equipment, building products, chemicals and packaging.Selling on TikTok Shop in France: EPR numbers, Pay on Behalf, and what it costsTikTok Shop asks producers for EPR registration numbers per product category and per market, registered under the same legal entity as the TikTok Shop account. A seller who lists EPR products without showing compliance is automatically enrolled in TikTok's Pay on Behalf service, which deducts the eco-contributions plus a TikTok service fee from the selling account.Selling on Temu, Shein or AliExpress to France: who pays EPR, and do I need my own IDU?If you are the seller of record on Temu, Shein or AliExpress, you are the producer for France. The platform must pay for you when you give it no IDU, but that covers its own sales only and gives you no IDU. Temu says it works with more than 60 authorised EPR schemes in Europe; AliExpress lists paid EPR services for France run by partners.Amazon, Cdiscount, ManoMano, TikTok Shop, Temu: how does each check French EPR?All of them apply the same article (L. 541-10-9): hold an IDU per stream from each seller or pay in its place. Cdiscount bills the higher simplified scale plus 7.3%; TikTok enrols sellers in Pay on Behalf with a service fee; Amazon offers Pay on Behalf; none of these gives you an IDU or covers your other channels.What proof of EPR compliance do marketplaces need in France?Your IDU (unique identifier), one for each product category you sell, packaging included, in the name of the legal entity on the seller account. Under article L. 541-10-9 a marketplace must contribute in your place unless it holds proof that you comply, and an ADEME IDU is that proof. Marketplaces are told to check that the IDU's format is coherent and matches the type of product sold.Does France EPR apply to Etsy sellers?Yes. French EPR has no minimum volume, so a maker sending a few parcels a month to France is caught. Etsy asks for your EPR number (IDU) for each relevant product category, under Shop Manager, Finances, Legal and tax information, and shows it to buyers. Since 10 July 2026 a seller with no establishment in France also needs a representative established in France by written mandate.What EPR rules apply to eBay sellers in France?eBay.fr asks for your EPR numbers (IDUs), including one for packaging on new or used items, under Account settings, Business details, EPR numbers. eBay says that without them it may charge you the matching eco-contributions and stop you creating listings or restrict existing ones. Shipping from abroad to French buyers, you are normally the producer yourself, and since 10 July 2026 you need a representative established in France.
The IDU (unique identifier) 9
How do I get a French IDU (unique identifier)?By joining an eco-organisme. In a collective scheme the eco-organisme you join registers you in SYDEREP, the French EPR declaration tool, and gives you your IDU; ADEME states you cannot register individually. Only a producer running an approved individual system gets its IDU from ADEME directly. If you have a French mandataire, it handles the membership for you.Do I need one IDU or several in France?One per EPR stream. ADEME issues an IDU per producer per stream, so you hold as many as the streams your products and their packaging fall under. A single product can be caught by several: ADEME's own example is a smartphone, under electrical and electronic equipment, household packaging and graphic papers, and batteries.What company details does a foreign producer need to get a French IDU?ADEME identifies companies by where they are resident. An EU company gives its intra-EU VAT number; a company outside the EU gives its intra-EU VAT number if it has one, or otherwise the registration number issued by the tax authority of its home country. You also give the legal name, full postal address, phone, website and the product categories your membership covers.Where do I have to show my French IDU?In your general terms and conditions of sale, or another contractual document if you have none (article R. 541-173), and on your website, alongside your legal notices (article L. 541-10-10). A seller must also give a buyer, on request, the IDU of the producer that meets the EPR obligations for the product.How can I check whether a company has a French IDU?ADEME publishes the IDUs it has issued: you can search by company name, SIRET or IDU in its search engine, and the full list is open data (the SYDEREP producers and IDU dataset). It is the quickest way to verify a provider's or a supplier's claim that a company is registered.Can my French IDU be withdrawn?Yes. In a collective scheme, removing an IDU is the decision of the eco-organisme alone, and it takes effect if you are not a member of another eco-organisme for that stream. In practice that follows a membership ending, for example unpaid contributions, which is why the membership has to be kept current for as long as you sell.A marketplace rejected my IDU. Why, and how do I fix it?Marketplaces check that each IDU has a coherent format, matches the type of product sold, is still valid in ADEME's list, and belongs to the company selling. Most rejections come from giving a packaging IDU for an electrical product, an IDU in another company's name, or one the eco-organisme has withdrawn.How do I check a French EPR number (IDU) in ADEME's registers?ADEME publishes three open-data lists: producers registered in SYDEREP with their IDU, producers no longer compliant whose IDU was withdrawn, and eco-organisme members. Marketplaces get the full list, withdrawn IDUs included, and check each seller's IDU format and coherence.How does a foreign company register in SYDEREP?A foreign company does not open a SYDEREP account itself in a collective scheme. SYDEREP is ADEME's declaration tool for the EPR schemes; the eco-organisme you join registers you in it and sends your IDU, and ADEME says you cannot register individually. You provide your company details: for an EU company its intra-EU VAT number, for a non-EU company the registration number issued by its home tax authority. Since 10 July 2026 you also need a representative established in France.
Existing registrations 2
I already have a French IDU. Do I need another one for professional packaging?Yes, if you are caught by both streams. The unique identifier is issued per EPR stream, not per company, so household packaging and professional packaging have separate ones. Your existing IDU stays valid and does not need redoing. What carries over is the representative: one written mandate can cover every stream you are caught by, so the mandate does not need repeating either.I already have a Citeo, Léko or Refashion membership. Do I have to start again?No. Your eco-organisme membership and your IDU stay valid, and nothing is registered again. Article L. 541-10-9-1 of the Environmental Code adds one requirement for a producer not established in France: it designates a France-established mandataire by written mandate, and the mandataire is subrogated in its EPR obligations. The membership then runs under that mandate.
Costs 2
Does the €990 a year cover everything?Yes, everything we do. Plus is €990 a year for up to three EPR streams and covers the written mandate, the eco-organisme memberships held under it, the IDU for each stream, the declarations and the correspondence with the eco-organismes and ADEME, with a median saving of €1,071 a year in eco-contributions across our published clothing, footwear, electronics and furniture examples. There is no setup fee, no deposit and no per-declaration charge. The only other amounts are the eco-organismes' own contributions, billed at their published tariff with 0% markup.If I start late in the year, why is the fee not pro rata, and when do I pay?Because the mandataire is answerable for the whole year, not for the days after you sign. Article L. 541-10-9-1 subrogates the mandataire in all the EPR obligations it accepts, and those obligations are annual: the declaration covers every unit you placed on the French market in the calendar year, including the months before the mandate. You pay the current year when you sign, and the plan renews every 1 January.
Construction products (PMCB) 20
Cement and concrete maker outside France: which eco-organisme, and what does it cost?Cement, concrete and mineral mortars are category 1 construction products (family 1.a of the 2023 scope notice). Two eco-organismes are approved for them: Ecominéro and Valobat. Cement costs €10.26 a tonne at Ecominéro (from 1 Aug 2026) and €7.70 a tonne at Valobat (2026 scale).Precast concrete manufacturer exporting to France: how does PMCB work?Precast concrete is category 1 (family 1.a), so a foreign plant joins Ecominéro or Valobat through a French representative. Ecominéro rates about twenty precast product types separately, from blocks at €1.19 to stairs at €8.69 a tonne; Valobat has blocks at €0.93 and other precast products at €4.21 a tonne.Ceramic and porcelain tile maker outside France: which eco-organisme, what cost?Ceramic and porcelain tiles are category 1, family 1.h (ceramics: wall, floor and ceiling coverings, indoor and outdoor). Two schemes take them: Ecominéro at €1.26 a tonne (from 1 Aug 2026) and Valobat at €3.12 a tonne (2026). A tile maker outside France joins through a French representative.Bathroom ceramics brand (WC, washbasins, shower trays) selling in France: what EPR applies?Sanitary ceramics are category 1, family 1.h. Ecominéro charges €13.43 a tonne; Valobat charges per unit (WC pack €0.35, washbasin €0.20, shower tray €1.29). Taps, flush mechanisms and metal fittings are category 2, so a brand that sells both needs Valobat, or Ecominéro plus a category 2 scheme.Brick and clay roof tile manufacturer exporting to France: which eco-organisme is cheaper?Clay bricks and roof tiles are category 1, family 1.d (fired or raw clay). Ecominéro charges €1.35 a tonne for bricks and roof tiles alike; Valobat €2.54 a tonne for clay masonry and €2.54 for clay roofing. On these scales Ecominéro is the cheaper scheme for fired clay.Natural stone, slate or aggregates supplier selling to France: is it covered by PMCB?Yes, when they are used in buildings and their plots: stone (family 1.c), slate (1.e) and aggregates (1.g) are category 1. Ecominéro: stone and slate €1.26 a tonne, aggregates €0.40. Valobat: building stone and slate €3.12, aggregates €0.34. Funeral monuments and excavated soil are excluded.Steel and metal building products (structure, rebar, roofing, pipes) sold in France: which eco-organisme?Metal building products are category 2, family 2.a. Three schemes take them: Valobat (€1.00 a tonne for most metal lines), Ecomaison (€2.00 a tonne for structure and envelope, €15.00 for networks) and Valdelia (€20.00 a tonne over 95% metal). Ecominéro does not take category 2.Window, door and shutter manufacturer selling into France: which eco-organisme and what rate?Windows, French windows, glazed doors, verandas, curtain walls and flat glass are category 2, family 2.d (joinery with glass), whatever the frame material. Valobat charges €5.57 per window, Ecomaison €3.20 per complete window; Valdelia charges per tonne of frame.Insulation manufacturer (mineral wool, PIR, PU, EPS, XPS, bio-based) selling to France: what are the PMCB rates?Insulation is category 2: glass wool (family 2.h), rock wool (2.i), plastic foam boards such as EPS, XPS, PU and PIR (2.f) and bio-based insulation such as wood fibre, hemp, cork and cellulose (2.j). Glass wool rolls cost €54.52 a tonne at Valobat, €58.00 at Ecomaison and €80.00 at Valdelia.Bitumen membrane and waterproofing producer selling to France: category 1 or 2?Category 2, family 2.g: bituminous membranes, shingles and primers. Only bituminous mixes such as asphalt are category 1 (family 1.f). Membranes cost €46.95 a tonne at Valobat, €54.00 at Ecomaison and €80.00 at Valdelia. Synthetic membranes are category 2 plastic (2.f).Plasterboard and gypsum products sold in France: which PMCB scheme costs least?Plaster products are category 2, family 2.e. Valobat charges per m² by thickness (€0.19 per m² for 6–13 mm boards), Ecomaison €14.26 a tonne for products over 95% plaster, Valdelia €50.00 a tonne.Adhesives, mortars, renders, sealants and paints for building: PMCB or chemicals EPR?They are construction products, category 2 family 2.c (mortars, renders, paints, varnishes, resins and application products, including their container), unless they are hazardous chemical products, which belong to the chemicals stream (EcoDDS and others). Valobat splits lines by pack size (over 25 kg or 25 L); Ecomaison and Valdelia rate per tonne.Flooring maker (parquet, laminate, vinyl, carpet, linoleum) selling in France: which eco-organisme?Floor coverings are construction products. Wood and laminate are category 2 (family 2.b), vinyl and plastic floors 2.f, carpet and linoleum 2.j; ceramic, terracotta and stone floors are category 1. Laminate costs €54.00 a tonne at Valobat and €40.10 at Ecomaison; solid wood €22.95 and €34.30.Plastic pipe, gutter and drainage manufacturer selling to France: PMCB rates comparedPlastic pipes, fittings, gutters and drainage elements for buildings are category 2, family 2.f. Plastic pipes cost €60.72 a tonne at Valobat, €54.00 at Ecomaison (single-resin) and €20.00 at Valdelia (rigid PVC).Timber and engineered wood (CLT, glulam, OSB, MDF) sold for buildings in France: what are the PMCB rates?Wood products for buildings are category 2, family 2.b. Valobat rates timber and panels mostly per m³ (OSB €11.30/m³, glulam €7.36/m³), Ecomaison per tonne (OSB €23.60/t, CLT/glulam/LVL €23.60/t), Valdelia €50.00/t for glued wood.Who pays the construction products eco-contribution: the foreign manufacturer or the French importer?The first to place the product on the French market. If a foreign manufacturer sells to a French distributor, contractor or client, that buyer is the importer and pays, unless it can prove the exporter already contributed. A foreign manufacturer can join an eco-organisme itself, through a representative established in France, so its French customers do not have to.How do construction products declarations work: monthly, annual and the simplified regime?It depends on the eco-organisme. Ecominéro: a declaration every month, online or by Excel file, per 8-digit product code. Valobat: one declaration a year, and under article R. 541-119 a simplified regime if your turnover is no more than €2 million (0.06% to 1.22% of turnover by sector) or you place under 100 tonnes a year (4 product lines), with a €90 minimum.Is my product a construction product (PMCB) in France, and is it category 1 or 2?A construction product is one intended to be permanently incorporated, installed or assembled in a building or used on its plot, including parking (article R. 543-289), except products used only during the works. Category 1 is mainly mineral products without glass, mineral wool or plaster (concrete, stone, clay, ceramics...); category 2 is everything else (metal, wood, plastics, glass, insulation, plaster, paints...).I sell building products in France: do I also have to declare my packaging?Partly. For mortars, renders, paints, varnishes, resins and adhesives (family 2.c) the container is part of the construction product. ADEME's packaging guide sends building-stream packaging to the building stream first. Other packaging, such as pallets, film, sacks and big bags, is professional packaging (EPRO) from 2027, or household packaging if it reaches consumers. Ask your PMCB eco-organisme first.How can a construction products manufacturer lower its French eco-contribution legally?Pay the right amount on the right lines: choose the cheapest approved scheme for your mix, declare each product on its most precise line, leave out what is outside the scope (works-only products, civil engineering, exports), use Valobat's simplified regime if you qualify, avoid a second contract where one covers both categories, and join yourself so your importers stop paying twice.
Choosing an eco-organisme 2
Valobat, Ecominéro, Ecomaison or Valdelia: which construction eco-organisme should I choose?It depends on your category and your product mix. Category 1 (mineral) goes to Ecominéro or Valobat; category 2 (everything else) to Ecomaison, Valdelia or Valobat. Valobat is the only scheme approved for both and the only one with a single annual declaration. On our 26-product comparison the lowest published rate is at Valobat for 12 types, Ecominéro 4, Ecomaison 8 and Valdelia 1.Citeo Pro, Léko Pro or Twiice: which professional packaging eco-organisme costs least?It depends on your materials. On the published 2027 scales Léko Pro has the lowest rate for plastics, steel, aluminium, glass and other materials; Twiice for paper and cardboard and wood; Citeo Pro is not the lowest on any material. Under 4 tonnes a year all three charge a flat fee (Twiice €200 in its calculator, Léko Pro €220, Citeo Pro €240). Steel packaging is the big gap: Twiice charges €23.84 a tonne against €5.05 at Léko Pro.
Obligations and penalties 14
What are the penalties for not complying with French EPR?Article L. 541-9-5 lets the minister fine a company up to €7,500 per unit or per tonne of product concerned (€1,500 for an individual), order a daily penalty of up to €20,000 until it complies, and fine up to €30,000 for not registering, false data or not showing the IDU. The company is first told the facts and has one month to respond.We received a French EPR non-compliance notice. What do we do now?Check who sent it first. A formal sanction procedure comes from the minister in charge of the environment and gives you one month to send observations before any fine. Use that month to join the eco-organismes for each stream, obtain your IDUs and file the missing declarations; a representative can answer for you.How do I register for French EPR, step by step, and which documents do I need?ADEME lists five steps: identify your streams, join an approved eco-organisme for each, receive your IDUs from them, declare your quantities every year, and keep up to date. A company not established in France first signs a written mandate with a representative established in France, who joins in its name.What did the Conseil d'État decide in the EcoDDS case, and does it still matter?The Conseil d'État annulled the decree article (R. 541-174) that let any producer appoint a representative in France who was "subrogated" in all its EPR obligations, because no statute allowed that subrogation. Since 10 July 2026 a statute, article L. 541-10-9-1, makes a written mandate compulsory for producers not established in France.When are French EPR declarations due? Deadlines by eco-organismeEach eco-organisme sets its own calendar. Citeo collects household packaging declarations every year in January and February. Refashion's 2026 window ran from 14 January to 28 February, with payment by 31 March. Ecologic runs six-week campaigns, yearly or half-yearly. Late declarations bring late-payment penalties under your contract.Is there a minimum threshold below which French EPR does not apply?No. The article requiring a representative in France has no minimum volume or turnover, and marketplaces must hold an IDU for every seller or pay in its place. Small volumes change the amount, not the duty: eco-organismes offer simplified scales, and the EU packaging regulation gives micro-enterprises and producers under 1,000 kg a year some lighter rules.Swiss, Norwegian and other non-EU European companies: what does French EPR require?A company in Switzerland, Norway or elsewhere in non-EU Europe that sells into France without an establishment there must appoint a representative established in France, for every EPR stream, since 10 July 2026. Under the EU packaging regulation, the EU business that brings its goods into the EU is the importer.Who pays the eco-contributions, and how does the money flow through a representative?The eco-organisme bills the eco-contribution on the quantities declared for your membership, at its published scale. We pass it on at cost with 0% markup and show you the amount before it is paid; our own fee is separate and fixed. Eco-contributions can be paid by bank transfer.How long does EPR registration take in France?Usually days. The written mandate with a representative established in France is signed online. The eco-organisme you join then registers you, and ADEME issues one IDU per stream, typically within days once the eco-organisme has done so. ADEME cannot speed this up: in a collective scheme the timing depends on the eco-organisme. Marketplaces then validate the IDU on their own schedule.Can a foreign company register for EPR itself in France?No. Two rules stop it. First, ADEME says that in a collective scheme you cannot register individually: the eco-organisme you join registers you in SYDEREP and sends the IDU. Second, since 10 July 2026 article L. 541-10-9-1 requires a producer not established in France to appoint a representative established in France by written mandate. You keep your own IDU and membership; the representative carries them.How do I cancel an EPR representative contract in France?Read your contract for its notice period and renewal date, sign a mandate with the new representative before the old one ends, give written notice, and ask for your file: IDUs by stream, eco-organisme accounts, declarations filed and what is due next. Your IDU does not change. If you stop selling to France altogether, end your eco-organisme memberships instead; while you still sell, the duty to have a representative does not pause.How do I report packaging weights for EPR in France?You declare to your eco-organisme, not to a government office, on its own calendar: Citeo collects household packaging declarations every year in January and February; Léko takes one declaration a year and, under 500,000 units, accepts units per product family with no weights. Count every layer that reaches the customer, including the shipping box and filling. With a representative, it files for you and sends you the amount before it is paid.How do I register for EPR in France without a local company?You do not need a French company. Since 10 July 2026 article L. 541-10-9-1 requires a producer not established in France to appoint a representative established in France by written mandate. The representative joins an eco-organisme for each of your streams in your name, ADEME issues one IDU per stream, and the representative files your declarations. With us: from €190 a year per stream, no setup fee.Do foreign sellers need the AGEC product environmental sheet (fiche produit) in France?The 'fiche produit relative aux qualités et caractéristiques environnementales' (article 13 of the AGEC law, décret 2022-748) applies to producers, importers and other businesses placing products on the French market, online sellers included, once they exceed €10 million turnover and 10,000 units a year (since 1 January 2025; €50 million and 25,000 units in 2023, €20 million and 10,000 in 2024). It is a free online page per product showing, where relevant, recycled content, recyclability, compostability, reusability, hazardous substances, precious metals and rare earths, and textile traceability. It is separate from EPR registration and the IDU.
By industry 5
Which French EPR streams apply to a cosmetics or beauty brand?Cosmetics themselves have no EPR stream, but their packaging does (household packaging, including leaflets), makeup-remover and face-care wipes have their own stream since the wipes rules of December 2024, and electrical beauty devices fall under electrical equipment. Without an establishment in France you also need a representative there.Which French EPR streams apply to food and drink brands?Food and drink are not an EPR stream, their packaging is. Packaging of products eaten by households, at home or out of home, falls under household packaging. Packaging of products sold to restaurants, hotels and other businesses falls under professional packaging (EPRO), whose eco-organisme membership starts 1 January 2027.Which French EPR streams apply to pharmaceutical and medical device companies?Human medicines fall under the unused medicines stream, run by Cyclamed, and their producer is the exploitant. Sharps used by patients treating themselves, and since 2021 the electronic devices attached to them, fall under DASTRI's stream. Packaging of both is household packaging. Veterinary products, parapharmacy and food supplements are outside the medicines stream.Do free samples and promotional items count for French EPR?The texts that mention it put free supply in scope: printed paper is covered "including free of charge", and the chemicals stream covers products supplied for payment or free. No stream text we read exempts samples. Their packaging and printed matter are declared with your other packaging.Are catalogues, leaflets and instruction manuals covered by French EPR?Yes. French law puts printed paper issued by or for a company, including free copies and except books, in the same stream as household packaging, together with graphic paper. Citeo names catalogues, instruction leaflets and posters as examples. One membership covers your packaging and your paper.
By EPR stream 81
Which products fall under the French household packaging and printed paper EPR stream?Household packaging, wherever households consume the product: at home or out of home. Not covered: packaging of products used only by professionals: from 1 January 2027 it falls under professional packaging (EPRO).Who is the producer for household packaging and printed paper under French EPR?For packaging, the producer is any business that packs or has its products packed to place them on the market, any importer of packaged products, or, if neither can be identified, whoever first places the products on the market. For printed paper it is the "donneur d'ordre" who issues or has the paper issued, including free copies.Which eco-organisme for household packaging and printed paper in France, and how long is it approved?3 approved: Citeo (1 January 2025 to 31 December 2029); Adelphe (1 January 2025 to 31 December 2029); Léko (1 January 2025 to 31 December 2029).Which other French EPR streams apply alongside household packaging and printed paper?Usually professional packaging (EPRO) (packaging of products sold to businesses, from 2027); wipes (single-use sanitary textiles) (if you sell wipes). Each stream needs its own membership and IDU.What bonuses and penalties apply to household packaging and printed paper eco-contributions in France?Weight reduction: minus x% of the packaging's contribution for an x% weight cut, or minus 8% of the unit's contribution per reduction action. Reusable packaging with a working reuse system: minus 100% of the unit's contribution.Which products fall under the French professional packaging (EPRO) EPR stream?Today: packaging of primary food products used by restaurants and bars, above the size thresholds of the scope order of 20 July 2023. Not covered: packaging that already belongs to another EPR stream.Who is the producer for professional packaging (EPRO) under French EPR?Today the producer is whoever packs or has its products packed, or imports packaged products.Which eco-organisme for professional packaging (EPRO) in France, and how long is it approved?3 approved: Citeo Pro (approved 5 June 2026 for 2027); Twiice (approved 5 June 2026); Léko Pro (approved 5 June 2026).Which other French EPR streams apply alongside professional packaging (EPRO)?Usually household packaging and printed paper (the same goods sold to consumers). Each stream needs its own membership and IDU.Which products fall under the French electrical and electronic equipment (WEEE) EPR stream?Equipment working on electric currents or electromagnetic fields, up to 1,000 V AC and 1,500 V DC (EU directive 2012/19/EU). Who is the producer for electrical and electronic equipment (WEEE) under French EPR?Article R. 543-174 names four producers: a business established in France that makes or has made equipment under its own brand.Which eco-organisme for electrical and electronic equipment (WEEE) in France, and how long is it approved?3 approved: ecosystem (1 January 2022 to 31 December 2027); Ecologic (1 January 2022 to 31 December 2027); Soren (1 January 2022 to 31 December 2027).Which other French EPR streams apply alongside electrical and electronic equipment (WEEE)?Usually batteries (built-in or supplied batteries); household packaging and printed paper (the box and leaflets). Each stream needs its own membership and IDU.What bonuses and penalties apply to electrical and electronic equipment (WEEE) eco-contributions in France?Recycled plastics: €450 per tonne incorporated (open loop) or €540 (closed loop). No brominated flame retardants in plastic parts over 25 g (professional equipment): €21 per tonne.Which products fall under the French batteries EPR stream?All batteries, whatever their shape, volume, weight or materials, rechargeable or not. Not covered: batteries in military equipment and equipment launched into space.Who is the producer for batteries under French EPR?Every producer placing batteries on the French market, in shops or online, including businesses placing batteries prepared for reuse, repurposed or remanufactured.Which eco-organisme for batteries in France, and how long is it approved?3 approved: Batribox (18 August 2025 to 31 December 2030); ecosystem (18 August 2025 to 31 December 2030); Recycler Mon Véhicule (RMV) (18 August 2025 to 31 December 2030).Which other French EPR streams apply alongside batteries?Usually electrical and electronic equipment (WEEE) (the device the battery sits in); vehicles (vehicle batteries). Each stream needs its own membership and IDU.Which products fall under the French clothing, household linen and shoes EPR stream?All clothing, household linen and shoes for households: new, sold or given away, to consumers, placed on the French market including the overseas departments. Not covered: clothing in 100% leather or natural fur.Who is the producer for clothing, household linen and shoes under French EPR?ADEME sends producers to its definition and a dedicated form to check status.Which eco-organisme for clothing, household linen and shoes in France, and how long is it approved?1 approved: Refashion (1 January 2023 to 31 December 2028).Which other French EPR streams apply alongside clothing, household linen and shoes?Usually household packaging and printed paper (bags, boxes and tags); batteries (items with lights or electronics). Each stream needs its own membership and IDU.What bonuses and penalties apply to clothing, household linen and shoes eco-contributions in France?Durability criteria of annex III of the specifications: €0.035 to €1.05 per unit. Metallised plastic fibres (recycling disruptor): plus 50% of the contribution.Which products fall under the French furniture and textile decoration EPR stream?Furniture and its components whose main function is seating, sleeping, storage, or a surface to put things on or work on, in homes, shops and places open to the public. Who is the producer for furniture and textile decoration under French EPR?Whoever first places the furniture on the French market: maker, importer or brand owner.Which eco-organisme for furniture and textile decoration in France, and how long is it approved?3 approved: Ecomaison (1 January 2024 to 31 December 2029); Valdelia (1 January 2024 to 31 December 2029); Valobat (1 January 2024 to 31 December 2029).Which other French EPR streams apply alongside furniture and textile decoration?Usually household packaging and printed paper (the cartons); electrical and electronic equipment (WEEE) (furniture with motors or lights). Each stream needs its own membership and IDU.What bonuses and penalties apply to furniture and textile decoration eco-contributions in France?Foam or textile with at least 50% sustainably managed renewable resources: €0.05 per kg. Recycling disruptors: plus €0.15 per kg.Which products fall under the French toys EPR stream?Toys as defined by the toy safety decree 2010-166. Not covered: writing and drawing articles, and products of 5° of article L. 541-10-1.Who is the producer for toys under French EPR?Anyone who, as a business, makes in France, imports, assembles or first places toys on the French market, intended to be supplied for payment or free to the end user by any sales method.Which eco-organisme for toys in France, and how long is it approved?1 approved: Ecomaison (21 April 2022 to 31 December 2027).Which other French EPR streams apply alongside toys?Usually electrical and electronic equipment (WEEE) (electric toys); batteries (toys with batteries); household packaging and printed paper (the box). Each stream needs its own membership and IDU.What bonuses and penalties apply to toys eco-contributions in France?Spare parts within 15 working days, guaranteed 2 years (multi-part products): minus 10% of the contribution.Which products fall under the French sports and leisure goods EPR stream?Non-motorised bikes and personal mobility devices. Not covered: products designed only for professional use.Who is the producer for sports and leisure goods under French EPR?Anyone who, as a business, makes in France, imports, assembles or first places sports and leisure goods on the French market, for payment or free, by any sales method.Which eco-organisme for sports and leisure goods in France, and how long is it approved?1 approved: Ecologic (31 January 2022 to 31 December 2027).Which other French EPR streams apply alongside sports and leisure goods?Usually household packaging and printed paper (the packaging); electrical and electronic equipment (WEEE) (e-bikes and powered devices). Each stream needs its own membership and IDU.What bonuses and penalties apply to sports and leisure goods eco-contributions in France?Recycled material (bikes, scooters, ski bindings, paddles, poles, neoprene): minus 5% to 20% of the contribution. Recyclability under 50% (14 products): a penalty set by the eco-organisme.Which products fall under the French dIY and garden goods EPR stream?Category 1: painters' tools. Not covered: products for professional use only.Who is the producer for dIY and garden goods under French EPR?Anyone who, as a business, makes in France, imports, assembles or first places DIY and garden goods on the French market, for payment or free, by any sales method.Which eco-organisme for dIY and garden goods in France, and how long is it approved?4 approved: EcoDDS (24 February 2022 to 31 December 2027); Ecologic (24 February 2022 to 31 December 2027); Ecomaison (21 April 2022 to 31 December 2027); Valobat (1 January 2024 to 31 December 2027).Which other French EPR streams apply alongside dIY and garden goods?Usually electrical and electronic equipment (WEEE) (corded and battery power tools); chemical products (PCHIM) (paints, glues, fertilisers). Each stream needs its own membership and IDU.What bonuses and penalties apply to dIY and garden goods eco-contributions in France?All spare parts and documentation available beyond 12 years: minus €25 per tonne. Spare parts later than 15 working days: plus €25 per tonne.Which products fall under the French chemical products (PCHIM) EPR stream?Household waste from chemical products that present a significant risk, in 10 regulated categories. Who is the producer for chemical products (PCHIM) under French EPR?Anyone who, as a business, makes in France, imports or first places chemical products on the market, intended to be supplied for payment or free to the end user.Which eco-organisme for chemical products (PCHIM) in France, and how long is it approved?3 approved: EcoDDS (1 January 2022 to 31 December 2027); Pyréo (13 July 2022 to 31 December 2027); Ecopae (1 January 2025 to 31 December 2027).Which other French EPR streams apply alongside chemical products (PCHIM)?Usually dIY and garden goods (painters' tools); household packaging and printed paper (outer packaging). Each stream needs its own membership and IDU.What bonuses and penalties apply to chemical products (PCHIM) eco-contributions in France?Water-based paints without hazard pictogram: €5 per tonne bonus. Extinguisher with 5% to 50% recycled powder: €0.30 per unit bonus.Which products fall under the French tyres EPR stream?Household and professional tyres: cars, trucks, motorbikes, construction equipment, tractors, aircraft, including solid tyres. Not covered: tyres fitted to electrical equipment, toys, sports and leisure goods, and DIY and garden goods.Who is the producer for tyres under French EPR?Anyone who, as a business, produces in France, imports or first places tyres on the market, for payment or free.Which eco-organisme for tyres in France, and how long is it approved?3 approved: Aliapur (1 January 2024 to 31 December 2028); France Recyclage Pneumatique (FRP) (1 January 2024 to 31 December 2028); Tyval (1 January 2024 to 31 December 2028).Which other French EPR streams apply alongside tyres?Usually vehicles (tyres fitted to new vehicles). Each stream needs its own membership and IDU.What bonuses and penalties apply to tyres eco-contributions in France?Hazardous substance from decree 2021-1285 above 0.1% of the tyre's mass: plus 10% or 20% of the contribution, depending on the eco-organisme.Which products fall under the French lubricants and industrial oils EPR stream?Mineral or synthetic lubricating and industrial oils that can become waste oils: for engines and turbines, gears, compressors, hydraulics and shock absorbers, electrical uses, heat treatment, metalworking (non-soluble), heat-transfer fluids, multi-purpose. Not covered: oils inside equipment imported for the first time (other than motor vehicles and non-road mobile machinery): their importers are not producers.Who is the producer for lubricants and industrial oils under French EPR?Businesses that produce oils and lubricants in France, or import them from another EU country or from outside the EU (article R. 543-3).Which eco-organisme for lubricants and industrial oils in France, and how long is it approved?1 approved: Cyclevia (24 February 2022 to 31 December 2027).Which other French EPR streams apply alongside lubricants and industrial oils?Usually vehicles (oil in new vehicles); pleasure boats (engine oil). Each stream needs its own membership and IDU.Which products fall under the French vehicles EPR stream?Categories M and N: passenger cars and vans under 3.5 tonnes. Who is the producer for vehicles under French EPR?Anyone who, as a business, produces in France, imports or first places new vehicles in scope on the French market, for the end user (article R. 543-154).Which eco-organisme for vehicles in France, and how long is it approved?1 approved: Recycler Mon Véhicule (RMV) (8 April 2024 to 31 December 2029).Which other French EPR streams apply alongside vehicles?Usually tyres (the tyres); batteries (the battery); lubricants and industrial oils (the oils). Each stream needs its own membership and IDU.Which products fall under the French unused medicines EPR stream?Human medicines: substances presented as curing or preventing human disease, or used to diagnose or restore body functions. Not covered: empty primary and secondary packaging (household packaging stream).Who is the producer for unused medicines under French EPR?The exploitants of medicines defined in article R. 5124-2 3° of the Public Health Code: in practice the marketing authorisation holder or the company running the medicine for it.Which eco-organisme for unused medicines in France, and how long is it approved?1 approved: Cyclamed (1 January 2022 to 31 December 2027).Which other French EPR streams apply alongside unused medicines?Usually household packaging and printed paper (boxes, blisters and leaflets); medical sharps of patients in self-treatment (needles and lancets). Each stream needs its own membership and IDU.Which products fall under the French pleasure boats EPR stream?Pleasure boats from 2.5 to 24 metres, for personal leisure, sport or training. Not covered: human-powered craft.Who is the producer for pleasure boats under French EPR?Anyone who makes, imports or first places pleasure or sports boats on the French market as a business, for payment or free.Which eco-organisme for pleasure boats in France, and how long is it approved?1 approved: APER (28 June 2024 to 31 December 2029).Which other French EPR streams apply alongside pleasure boats?Usually lubricants and industrial oils (engine oil); batteries (on-board batteries). Each stream needs its own membership and IDU.Which products fall under the French tobacco products with filters EPR stream?Tobacco products with filters made wholly or partly of plastic. Who is the producer for tobacco products with filters under French EPR?Whoever first places on the French market, as a business, tobacco products with filters, with or without plastic, or products meant to be used with them, for the end consumer (article 10 of decree 2020-1725).Which eco-organisme for tobacco products with filters in France, and how long is it approved?1 approved: Alcome (28 July 2021 to 28 July 2027).Which other French EPR streams apply alongside tobacco products with filters?Usually household packaging and printed paper (packs and cartons). Each stream needs its own membership and IDU.Which products fall under the French wipes (single-use sanitary textiles) EPR stream?Wipes: small pieces of natural, artificial or synthetic fibre material, possibly pre-moistened, not designed to be reused. Not covered: four other categories listed by decree 2024-1166 (personal protective wear, hygiene paper, absorbent intimate products, medical-care products) are not yet in the stream.Who is the producer for wipes (single-use sanitary textiles) under French EPR?A business established in France that makes, sells or imports wipes.Which eco-organisme for wipes (single-use sanitary textiles) in France, and how long is it approved?1 approved: Citeo Soin & Hygiène (1 July 2025 to 31 December 2030).Which other French EPR streams apply alongside wipes (single-use sanitary textiles)?Usually household packaging and printed paper (the pack). Each stream needs its own membership and IDU.Which products fall under the French medical sharps of patients in self-treatment EPR stream?Perforating medical devices used by patients in self-treatment and self-test users. Not covered: waste of health professionals.Who is the producer for medical sharps of patients in self-treatment under French EPR?Medicine exploitants and medical device manufacturers, or their mandataire.Which eco-organisme for medical sharps of patients in self-treatment in France, and how long is it approved?1 approved: DASTRI (1 January 2023 to 31 December 2028).Which other French EPR streams apply alongside medical sharps of patients in self-treatment?Usually unused medicines (the medicines used with them); household packaging and printed paper (the boxes). Each stream needs its own membership and IDU.
EU packaging regulation (PPWR) 2
When do the EU packaging regulation (PPWR) rules apply? The timeline from 2026 to 2040The PPWR entered into force on 11 February 2025 and applies since 12 August 2026. What applies now: PFAS limits in food-contact packaging, heavy-metal limits, a declaration of conformity and traceability marking for manufacturers and importers, and an authorised representative for producers. Recyclability, recycled content, minimisation, labelling and reuse rules come progressively, many from 2030.Who must draw up a PPWR declaration of conformity for packaging, and what goes in it today?Manufacturers and importers draw up the declaration. You are the manufacturer if packaging or a packaged product is designed or made under your name or trademark, even if someone else makes it. For now the declaration covers lead, cadmium, mercury, hexavalent chromium and PFAS in food-contact packaging, and your supplier must give you the data.
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