Packaging manufacturers and importers must draw up an EU declaration of conformity; for now it only needs to cover the substances of concern. Those are the heavy-metal limits for lead, cadmium, mercury and hexavalent chromium, already in the old directive, and the new PFAS limits for food-contact packaging. European CommissionSources (2)European CommissionEuropean Commission — PPWR SME guide
LégifranceLégifrance — article L. 541-10-9-1 of the Environmental Code (full text) European Commission
Are you the manufacturer?
- Yes, if packaging or a packaged product is designed or made under your own name or trademark, even when another company makes it. Affixing your brand label to generic packaging makes you the manufacturer. European Commission
- No, for generic unbranded transport packaging (boxes, tape, pallets) you never brand: its supplier is the manufacturer. A shipping sticker is not branding. European Commission
- An importer places packaging or packaged products from outside the EU on the EU market and has the same obligations as a manufacturer. European Commission
What you need from your supplier
If you are the manufacturer but do not make the packaging yourself, the physical manufacturer or supplier is legally bound to give you the data and technical documentation to draw up the declaration. European Commission
Traceability marking
Packaging must carry a type, batch or serial number or another identifier and the manufacturer's contact details. Packaging already produced need not be repacked: the details can travel in invoices or digitally, as long as they link the packaging to its declaration. European Commission
Micro-enterprise exemption
A micro-enterprise whose branded packaging comes from a supplier in the EU is exempt, under conditions: the supplier becomes the manufacturer and draws up the declaration. European Commission
Not the same as French EPR
The declaration is a product-compliance duty under the PPWR. French EPR membership, IDUs and declarations of quantities are separate, and since 10 July 2026 producers not established in France need a representative there. Légifrance See the PPWR timeline.
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
Does a French EPR representative draw up our declaration of conformity?
No. It is the manufacturer's or importer's document. We handle French EPR: memberships, IDUs and declarations of quantities.
We only resell packaged goods bought in the EU under the maker's brand. Do we need one?
No: the manufacturer whose name is on the packaging draws it up.
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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