French EPR representative rule in effect since 10 July 2026 · day 125Check if it applies to you →
Since 10 Jul 2026 · Check if it applies to you →
Home / Answers

Do free samples and promotional items count for French EPR?

Giving products away does not take them out of French EPR where the texts speak to it.

Last updated 6 November 2026Sources linked below
Quick answer

Giving products away does not take them out of French EPR where the texts speak to it. The household packaging and paper article covers printed paper issued "y compris à titre gratuit" (including free of charge). Légifrance The chemicals stream's producer is whoever makes or imports products "destinés à être cédés à titre onéreux ou à titre gratuit" to the end user. ADEME None of the stream pages we checked carves out samples.

Typical cases

CaseWhat to declare
Sample sachets and minis sent with ordersTheir packaging, in your household packaging declaration Légifrance
Catalogues, flyers, brochures handed out or mailed in FrancePrinted paper, including free ones
Free cleaning, DIY or garden chemical samplesThe chemicals stream, content and container ADEME
Free wipes in a gift packThe wipes stream; distance sellers outside France are producers too ADEME
Branded gadgets with a battery or plug (power banks, speakers) ADEMEElectrical equipment and batteries, like sold units
Goods given to a French distributor who resells themUsually the distributor's to declare if it is the first to place them on the French market

How to keep it simple

  • Count samples with your sold units when you declare, by packaging type.
  • If samples are your only French activity, the volumes are small and so are the contributions, but the IDU is the same. ADEME
  • Keep the shipping list from trade shows and influencer campaigns: it is your quantity record.

If you are not established in France

A company with no establishment in France that is the producer must appoint a representative established in France by written mandate, since 10 July 2026. Légifrance The representative joins the eco-organismes in your name and you receive the IDUs.

Price

Our fee. Standard is €190 a year per eligible stream for household packaging, textiles, furniture, toys, graphic paper, sports and DIY goods, up to 1 tonne a year per stream. Every other stream (electrical equipment, batteries, wipes) and anything above 1 tonne is on Plus: €990 a year for up to three streams. Plus Pro, also €990, when you sell to businesses too. Setup is €0, and eco-contributions are paid at the eco-organisme's rate with 0% markup. See pricing.

Frequently asked questions

Are samples sent to French influencers placed on the market?

They reach French end users and their packaging becomes French household waste, so declare it with your other packaging.

We hand out catalogues at a Paris trade show. Is that EPR?

Yes: printed paper issued in France, including for free, is in the household packaging and paper stream. ADEME

Is there a minimum quantity?

No minimum appears in these texts. Eco-organismes have simplified scales for small volumes, but membership and the IDU are the same. 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.

Connect on LinkedIn →

Who is the producer for samples

Set-upProducer for French EPR
You sell to French customers and ship from abroadYou Légifrance
Your stock is in a French or EU warehouse, sold in your nameYou
A French distributor imports and resellsThe distributor
A marketplace buys and resells as retailerThe marketplace
A retailer sells your goods under its own brandThe retailer

If they go undeclared

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
Keep reading

Related reading

By industry

Are catalogues, leaflets and instruction manuals covered by French EPR?

Printed paper (catalogues, flyers, leaflets, instruction notices, posters) is part of the French household packaging and paper stream, including free copies, books excepted. Who declares, and how it fits with your packaging membership.

Read →
By industry

Which French EPR streams apply to a cosmetics or beauty brand?

The French EPR streams a cosmetics brand selling in France falls under: household packaging, printed leaflets, makeup-remover and face-care wipes (Citeo Soin & Hygiène), and electrical beauty devices, with the official sources for each.

Read →
By industry

Which French EPR streams apply to food and drink brands?

Food and drink have no product stream in France; their packaging does. Household packaging covers products eaten at home and out of home; packaging sold to restaurants and other businesses moves to the professional packaging stream from 1 January 2027.

Read →
By industry

Which French EPR streams apply to pharmaceutical and medical device companies?

Medicines (Cyclamed), sharps and electronic devices used by patients in self-treatment (DASTRI), other electrical medical devices, and the packaging of all of them: who is the producer in each stream and what is excluded, from the ADEME stream pages.

Read →
By EPR stream

Which products fall under the French household packaging and printed paper EPR stream?

Scope of the French household packaging and printed paper EPR stream as ADEME states it: products covered, exclusions, with the official source next to each point.

Read →
By EPR stream

Who is the producer for household packaging and printed paper under French EPR?

The official producer definition for the French household packaging and printed paper stream, and what it means for importers, own brands, retailers and foreign online sellers.

Read →

Get your French EPR numbers

We act as your representative in France: registration, IDUs and declarations. No setup fee.