There is no de minimis threshold in French EPR for producers. Article L. 541-10-9-1 applies to every producer not established in France, whatever its size. 
Légifrance Marketplaces must check each seller's IDU or pay in its place, with no exception for small sellers. 
Ministère de l'ÉcologieSources (6)LégifranceLégifrance — article L. 541-10-9-1 of the Environmental Code (full text)Ministère de l'ÉcologieMinistère de l'Écologie — FAQ places de marché, article L. 541-10-9 (version du 1er août 2022)ValobatValobat — Le régime de déclarations simplifiées pour l'année 2027European CommissionEuropean Commission — PPWR SME guideRefashionRefashion — FAQ, déclarer ses mises en marchéLégifranceLégifrance — Article L541-10-1, Code de l'environnement
What small volumes do change
- The amount. Eco-contributions follow units or weight placed on the market.
- The format. Some eco-organismes offer simplified declarations for small producers, such as Valobat's simplified regime for building products. Valobat
- EU reporting. Under the PPWR, businesses placing less than 1,000 kg of packaging a year get more proportionate EPR reporting. European Commission
Common myths
- "Free items do not count." Refashion requires donations to be declared, and printed paper is covered including free copies. Sources (2)RefashionRefashion — FAQ, déclarer ses mises en marchéLégifranceLégifrance — Article L541-10-1, Code de l'environnement See free samples.
- "The marketplace covers me." Only for its own sales, and you get no IDU. Ministère de l'Écologie See does the marketplace cover me.
- "Micro-enterprises are exempt from EPR." The PPWR exempts micro-enterprises from EPR duties only when their packaging supplier is in the same member state, which rarely fits a foreign seller. European Commission
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
We sell 50 parcels a year to France. Do we need a representative?
Yes, if you are the producer and have no establishment in France. The cost scales with what you sell; the duty does not.
Is there a cheaper plan for very small volumes?
Standard: €190 a year per eligible stream, up to 1 tonne a year, with simplified reporting and one declaration a year. Eco-contributions at cost.
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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