Whoever first places on the French market, as a business, tobacco products with filters, with or without plastic, or products meant to be used with them, for the end consumer (article 10 of decree 2020-1725). 
ADEMESources (3)ADEMEADEME — Filière REP Produits du tabac
LégifranceLégifrance — article L. 541-10-9-1 of the Environmental Code (full text)ADEMEADEME — all about the unique identifier (IDU)
The official definition
Whoever first places on the French market, as a business, tobacco products with filters, with or without plastic, or products meant to be used with them, for the end consumer (article 10 of decree 2020-1725). ADEME
Typical cases
- A brand outside France selling directly to French customers online: the producer, and since 10 July 2026 it must appoint a representative established in France. Légifrance
- A French importer buying from a foreign maker: usually the importer, as the first to place the goods on the French market.
- Your goods sold under a French retailer's own brand: in most streams the retailer becomes the producer; check the definition above.
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. This stream is Enterprise: we quote it in writing after looking at your products and volumes. Setup is €0, and eco-contributions are paid at the eco-organisme's published rate with 0% markup. See pricing and the calculator.
Frequently asked questions
We only sell from outside France. Are we the producer?
If you sell directly to French customers, usually yes, and you need a representative established in France.
Does a marketplace take the producer role?
No. It must hold your IDU or pay in your place for its own sales only. See does the marketplace cover me. ADEME
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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