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Grouped by subject. Every answer states the rule, the source and the date it was last checked.

Who needs a representative 1

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.

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

We sell DDP or DAP into France. Who is the producer?The Incoterm does not decide it. DDP, DAP and EXW allocate cost, risk and customs duties between buyer and seller by contract; producer status under article L. 541-10 follows who first places the product on the French market, which is a question of fact about the supply chain. Selling DDP to a French distributor who resells leaves the distributor as the producer. Selling DDP to the business that uses the goods makes you the producer.

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 1

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.

Existing registrations 1

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.

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