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Since 10 Jul 2026 · Check if it applies to you →
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We received a French EPR non-compliance notice. What do we do now?

A formal French EPR notice gives you one month to respond before any fine, and the best answer is to be compliant by then.

Last updated 6 November 2026Sources linked below
Quick answer

A formal French EPR notice gives you one month to respond before any fine, and the best answer is to be compliant by then. Under article L. 541-9-5 the minister in charge of the environment first informs you of the facts and the sanction you face; you then have one month to present written or oral observations, and you may be represented by a mandataire of your choice. Légifrance Messages from a marketplace or an eco-organisme are not that procedure, but they usually come first: a marketplace asking for your IDU, or an eco-organisme warning that it will withdraw it. Ministère de l'Écologie

First, who sent it

SenderWhat it usually meansWhat to do
The ministry (sanction procedure)Facts and the sanction you face; one month to answer LégifranceJoin, get IDUs, declare, and answer within the month
Your eco-organismeMissing declaration or unpaid contributions; your IDU may be withdrawn Ministère de l'ÉcologieDeclare and pay; a withdrawn IDU stops working on marketplaces ADEME
A marketplaceNo valid IDU on file for a stream you sell inGive a valid IDU per stream, or accept the platform's charge Octopia (Cdiscount Marketpla

Your one-month plan

  1. List what you sold into France and through which channels, per stream.
  2. Appoint a representative established in France if you have no establishment there. Légifrance
  3. Join an approved eco-organisme for each stream and obtain the IDUs. ADEME
  4. Declare the past quantities your eco-organisme asks for.
  5. Send your observations, with proof of membership and IDUs, before the deadline. Légifrance

What a representative does here

The article lets you be represented by a mandataire of your choice during the procedure. Légifrance As your representative established in France we file the memberships, obtain the IDUs and handle the declarations; the reply to the ministry is yours or your lawyer's to sign.

Price

Our fee. Standard is €190 a year per eligible stream, Plus is €990 a year for up to three streams in one mandate, with a median saving of €1,071 a year in eco-contributions across our published clothing, footwear, electronics and furniture examples. Setup is €0, and eco-contributions are paid at the eco-organisme's published rate with 0% markup. See pricing.

Frequently asked questions

Can we ignore a notice if we are outside France?

No. The duty to appoint a representative applies precisely to producers without an establishment in France, and marketplaces in France act on missing IDUs.

Will joining now cover the past?

Joining stops the failure going forward; your eco-organisme decides what past quantities it asks you to declare. ADEME

Razvan Toma
Written byRazvan Toma

Razvan Toma is the founder of EPR France Rep, a France-established authorised representative (mandataire) for producers with no French establishment. He has worked in waste management and recycling since 2009, running waste-separation programmes inside large B2B organisations in France for clients including Chanel, Microsoft, Decathlon, Pirelli, IKEA, Vinci, Capgemini and E.Leclerc.

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What the article allows, by breach

Maximums under article L. 541-9-5, not what a given case will cost. The ministry decides after the one-month procedure. Légifrance

BreachMaximum
Specified registration, IDU and reporting breachesUp to €30,000
Other EPR breaches, for a companyUp to €7,500 per unit or tonne
Not complying after formal noticeAn enforcement payment of up to €20,000 a day until you comply

Two other consequences often come first: your eco-organisme can withdraw an IDU when declarations or contributions are missing, and marketplaces block listings without a valid one. ADEME summarises the regime on its sanctions page. ADEME

What the notice can lead to

FailureSanctionSource
Not meeting EPR duties after formal noticeUp to €1,500 (individual) or €7,500 (company) per unit or tonne concernedLégifrance
Still not complyingDaily penalty up to €20,000Légifrance
Register and IDU failuresFine up to €30,000Légifrance
No IDU on a marketplaceThe platform blocks the listing or pays in your placeMinistère de l'Écologie
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