Yes, and the working deadline is 31 December 2026, not 1 January 2027. ADEME's own words on the scheme page are „Pensez à anticiper vos obligations en adhérant à un éco-organisme avant le 31 décembre 2026" — plan ahead by joining an eco-organisme before 31 December 2026. From 1 January 2027 all professional packaging is covered and every producer concerned must already have joined. Three eco-organismes were approved on 5 June 2026: Citeo Pro, Léko Pro and Twiice. If your company is not established in France there is a step in front of that one: the membership is held through a French representative appointed by written mandate under article L. 541-10-9-1, so the mandate has to be in place before the membership can be.Sources (3)
ADEMEADEME — professional packaging (EPRO) scheme page
Ministry for Ecological TranMinistry for Ecological Transition — 28 July 2026 announcement of the 1 January 2027 start
LégifranceLégifrance — article L. 541-10-9-1 of the Environmental Code (full text)
The two dates, and why the earlier one is the real one
Professional packaging (EPRO) has an operational start date of 1 January 2027. The Minister confirmed it in a press release of 28 July 2026, after the scheme was postponed from 1 July 2026. ADEME states that on that date all professional packaging is covered by an EPR scheme and every producer concerned must already have joined an eco-organisme.
Which is why ADEME puts a different date in front of it:
« Pensez à anticiper vos obligations en adhérant à un éco-organisme avant le 31 décembre 2026. »
Read together, the two dates mean the same thing: 1 January 2027 is when you must already be compliant, so 31 December 2026 is when the work has to be finished. Treating January as the deadline is how companies arrive late.
The order of operations if you are not established in France
This is where a foreign producer's sequence differs from a French one, and where the time actually goes.
- Confirm you are caught. Professional packaging is defined by the arrêté of 2 December 2025, not by who you invoice — see household or professional packaging. Pallets, palletisation items, IBCs, drums over 29 litres and transport packaging to business customers are the usual triggers.
- Appoint a French representative. Article L. 541-10-9-1 requires a producer not established in France to appoint, by written mandate, a person established in France. This applies to EPRO exactly as it applies to every other stream. Same day, once the mandate is signed.
- Join an eco-organisme — Citeo Pro, Léko Pro or Twiice — held in the representative's name under the mandate. This is the step ADEME wants done before 31 December 2026.
- Get the IDU. The eco-organisme registers you in SYDEREP and ADEME issues the unique identifier for the stream. Allow weeks, not days.
- Declare on the eco-organisme's cycle once the scheme is running.
Steps 2 to 4 are sequential: the membership cannot precede the mandate, and the IDU cannot precede the membership. That is the argument for starting now rather than in December.
There is a second route: an approved individual system
Joining an eco-organisme is the common path, not the only one. ADEME lists three approved individual systems for this scheme:
| Individual system | Approved |
|---|---|
| Euro Pool System France | 09/07/2026 to 31/12/2030 |
| La Palette Rouge | 09/07/2026 to 31/12/2031 |
| International Pallet Pool BV | 06/07/2026 to 31/12/2031 |
All three are pallet pooling operators, which tells you what the route is for. If your professional packaging is pooled pallets already circulating in one of those systems, the obligation may be handled there rather than through a membership of your own. It is worth checking before paying twice; it is not a general-purpose alternative for a company shipping its own cartons and film.
What it will cost, and why we are not quoting a number yet
The three eco-organismes publish their own tariffs, and ADEME noted publication was expected during September 2026. Contributions are per tonne by material, and can be modulated up or down — a prime for good environmental characteristics, a pénalité where a product has features the scheme penalises.
We track those tariffs in the free calculator rather than restating figures here, because a copied tariff goes stale and a stale tariff is worse than none. Our own mandate fee is published in pricing and every competitor's published price sits in market data, re-checked daily.
If you already deal with household packaging in France
EPRO does not replace it. A company shipping online orders to French consumers and palletised goods to French businesses is caught by both streams and declares to each separately. Your existing IDU for household packaging does not cover professional packaging; the stream has its own registration. What does carry over is the representative: one mandate can cover every stream you are caught by.
Frequently asked questions
What happens if I join after 1 January 2027?
You would be placing professional packaging on the French market without being covered by a scheme, which is the situation the registration duty exists to prevent. ADEME's guidance is to join before 31 December 2026 precisely so the question does not arise. Joining late is better than not joining; the obligation does not disappear because the date passed.
Can I join an eco-organisme now, before the scheme starts?
That is what ADEME is asking producers to do. The three eco-organismes were approved on 5 June 2026 and the scheme starts on 1 January 2027; the window in between is when the memberships are meant to be set up.
Does the representative duty apply to EPRO as well?
Yes. Article L. 541-10-9-1 applies to a producer not established in France for the obligations it is caught by, and professional packaging is one of them. The same written mandate can cover several streams.
Is restaurant and catering packaging already covered?
Yes, separately and earlier. ADEME records the catering packaging scheme as running in France since March 2024, with Citeo Pro approved for it. The 1 January 2027 date is when the scheme widens to all professional packaging.
Sources
- ADEME — professional packaging (EPRO) scheme page
- ADEME — the professional packaging scheme widens its scope
- Ministry for Ecological Transition — 28 July 2026 announcement of the 1 January 2027 start
- Légifrance — article L. 541-10-9-1 of the Environmental Code (full text)
- ADEME — all about the unique identifier (IDU)
Founder of EPR France Rep, the France-based EPR authorised representative for companies selling into France.
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