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Answer · The IDU
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Do I need one IDU or several?

One per EPR stream, so often several.

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Razvan TomaBy Razvan Toma · Founder
Last updated 4 October 2026Sources linked below
Quick answer

One per EPR stream, so often several. ADEME issues an IDU to a producer for one stream only, and the producer holds as many IDUs as the streams its products fall under, “including their packaging”. One product can be caught by several streams: ADEME's own example is a smartphone, which can fall under electrical and electronic equipment, household packaging and graphic papers (EMPAP), and batteries. Professional packaging (EPRO) is another stream again, with its own IDU.ADEME

Frequently asked questions

We only sell clothes. Is the textile IDU enough?

Usually not: if the clothes are packaged, the packaging falls under household packaging (EMPAP), which needs its own IDU. ADEME warns specifically against forgetting packaging and batteries.

Sources

Razvan Toma
Written byRazvan Toma

Founder of EPR France Rep, the France-based EPR authorised representative for companies selling into France.

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EPRO

Is my packaging household (EMPAP) or professional (EPRO)?

The arrêté of 2 December 2025 decides whether packaging falls under the household stream (EMPAP) or the professional one (EPRO). The three-step test, the automatic lists and the e-commerce exception that catches most online sellers.

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Do I have to do anything about EPRO before 1 January 2027?

ADEME asks producers to join an eco-organisme before 31 December 2026, ahead of the professional packaging scheme starting on 1 January 2027. What that means for a company with no French establishment, and what has to happen in which order.

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Who is the producer for professional packaging in France?

Producer status under EPRO follows the first placing on the French market, not who owns the pallet or who pays the freight. How it lands for a foreign supplier, a French importer, a distributor and a marketplace.

Read →Establishment

Does a French VAT number mean I am established in France?

No. French tax law has a standing category for companies liable for French VAT with no permanent establishment in France. A VAT registration does not remove the EPR representative duty under article L. 541-10-9-1.

Read →Establishment

Does stock in a French warehouse or 3PL make me established in France?

Holding stock in France, using a French 3PL or selling through FBA does not give you a French establishment, and it does not remove the EPR representative duty. It does confirm you are the producer for what you sell from it.

Read →Who is the producer

We sell DDP or DAP into France. Who is the producer?

Incoterms allocate cost and risk between buyer and seller. They do not move producer status under French EPR, which follows who first places the goods on the French market.

Read →Existing registrations

I already have a French IDU. Do I need another one for professional packaging?

Yes. The IDU is issued per EPR stream, so household packaging and professional packaging each have their own. Your existing identifier stays valid and the same representative mandate can cover both.

Read →Who needs one

We are an EU company. Do we really need a French EPR representative?

Yes. Article L. 541-10-9-1 turns on establishment in France, not on nationality or EU membership. A German, Dutch, Italian or Spanish company selling directly to French end users is in the same position as a non-EU one.

Read →EPRO

Which eco-organisme do I join for professional packaging?

Three eco-organismes are approved for French professional packaging — Citeo Pro, Léko Pro and Twiice — plus three approved individual systems, all pallet poolers. How to choose, and what an individual system does and does not cover.

Read →Marketplaces

Amazon says it handles EPR. Am I covered?

A marketplace established in France carries a backstop duty for sellers who have not registered, and the French article treats the obligation as satisfied for those products. It is not a substitute for your own IDU, and it covers only that channel.

Read →The IDU

How do I get a French IDU?

By joining an eco-organisme for each stream you are caught by. The eco-organisme registers you in SYDEREP and sends you the IDU; you cannot register yourself in a collective scheme.

Read →The IDU

What details does a foreign company need to get a French IDU?

An EU company identifies itself with its intra-EU VAT number; a company outside the EU with the registration number from its home tax authority. Plus address and product categories.

Read →The IDU

Where do I have to show my IDU?

In your general terms of sale, on your website, and to any buyer who asks. Articles R. 541-173 and L. 541-10-10 of the Environmental Code.

Read →The IDU

How can I check whether a company has an IDU?

In ADEME's search engine of issued IDUs, or in ADEME's open dataset of producers and IDUs.

Read →The IDU

Can my IDU be withdrawn?

Yes. In a collective scheme the eco-organisme can remove it, and it takes effect if you are not a member of another one.

Read →

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