French EPR is not new; the 2026 changes are. Packaging EPR has existed in France since 1992 and marketplaces have demanded French IDU numbers since 2022. What changed in 2026 is threefold: (1) since 10 July 2026 a company not established in France can no longer register itself and must appoint a France-based representative (law n° 2026-602, article L. 541-10-9-1 of the Environmental Code); (2) since 12 August 2026 the EU packaging regulation (PPWR) requires registration in every country of sale; (3) from 1 January 2027 professional (B2B) packaging pays eco-contributions for the first time. Last checked 15 September 2026.
Why people think French EPR is new
Because the search results changed, not the law. Until 2026, a small foreign seller could open an account with Citeo or Léko, get an IDU and paste it into Amazon Seller Central. Forum threads from 2023 still show sellers doing exactly that. In 2026 three rules landed within six months of each other, and every provider started publishing "new obligation" content. The obligation to pay for packaging waste is over thirty years old; the obligation to go through a French representative is a few months old.
What did not change
- Who is the producer. Whoever first makes a product or its packaging available in France pays for its end of life (article L. 541-10 of the Environmental Code, AGEC law of 2020). A German webshop shipping to French consumers has been a French producer since long before 2026.
- The eco-organismes. Citeo, Léko, Ecomaison, Refashion, Ecologic, ecosystem and the others still collect the eco-contributions on their published schedules.
- The IDU. ADEME has issued one identifier per EPR stream through SYDEREP since 2022, and marketplaces (Amazon, Cdiscount, ManoMano, Fnac) have been required to verify it since then (article L. 541-10-9).
- The 19 EPR streams. Packaging, textiles, furniture, electronics, batteries, toys, sports, DIY, building products and the rest were all in force before 2026.
Change 1: the mandatory French representative (10 July 2026)
Law n° 2026-602 of 8 July 2026 created article L. 541-10-9-1. Since 10 July 2026, any producer not established in France, whether in another EU country or outside the EU, must appoint a representative established in France by written mandate. The representative is subrogated: it takes over the producer's obligations and the liability that comes with them, for every stream covered by the mandate.
The practical effect: the self-service route is closed. A foreign company can no longer join an eco-organisme in its own name; the eco-organisme registers it through its representative, and ADEME issues the IDU in the producer's name via that mandate. That is what turned "you should register" into "you legally need a French company to do it".
Change 2: the EU packaging regulation (12 August 2026)
Regulation (EU) 2025/40, the PPWR, applies directly in all 27 member states since 12 August 2026. Article 44 requires producers to register in every country where they first make packaging available; article 45 requires an authorised representative in each country where they sell directly to end users without being established there. The European Commission has proposed suspending the representative duty for EU-based companies, but as of 15 September 2026 nothing has been adopted, and non-EU producers were never in the proposal. France's national rule applies regardless of the outcome.
Change 3: professional packaging pays (1 January 2027)
Until now only household packaging carried eco-contributions. Decree n° 2025-1081 created a separate scheme for professional packaging: pallets, stretch film, cartons, drums, crates and IBCs delivered to businesses. Three eco-organismes are approved (Citeo Pro, Léko Pro, Twiice). The operational start was postponed from 1 July 2026 to 1 January 2027; membership is expected before 31 December 2026. This brings in a population that has never dealt with EPR: industrial exporters, wholesalers and B2B suppliers shipping into France.
Timeline at a glance
| Date | What | New or old |
|---|---|---|
| 1992 | Household packaging EPR starts in France (Eco-Emballages, now Citeo) | Old |
| 2020 | AGEC law: producer definition, marketplace co-liability, new streams | Old |
| 2022 | IDU per stream via ADEME/SYDEREP; marketplaces verify it | Old |
| 10 Jul 2026 | France-based representative mandatory for producers not established in France | New |
| 12 Aug 2026 | PPWR applies: registration per country, representative for cross-border direct sales | New |
| 31 Dec 2026 | Join a professional packaging eco-organisme | New |
| 1 Jan 2027 | Professional packaging eco-contributions start | New |
Key figures (2026)
| Figure | Value | Source |
|---|---|---|
| French EPR streams in force | 19 | ADEME, first half 2026 |
| Producers registered with Citeo (household packaging & paper) | 98,000+ | Citeo, 2026 |
| Amazon sellers live on the four largest EU marketplaces | 9,579, of which 40.8% foreign-based | Eldris Seller Index, June 2026 |
| Non-EU sellers active on those marketplaces | 1,364 | Eldris, 2026 |
| Estimated market for authorised-representative services in the EU | €1–2 billion per year | European Commission estimate, reported Aug 2026 |
| Fine for missing registration / IDU | up to €30,000 per stream | Art. L. 541-9-5, Code de l'environnement |
| Fine per non-compliant unit or tonne (company) | up to €7,500 | Art. L. 541-9-5 |
| Professional packaging, plastics (2026 schedules) | €217.80–217.90 per tonne | Léko Pro, Citeo Pro |
| Professional packaging, paper & cardboard | €34.70–34.72 per tonne | Léko Pro, Citeo Pro |
| Professional packaging, flat fee at or under 2 t | €95–125 per half-year | Léko Pro, Citeo Pro |
| Days since the representative rule took effect | 68 | 10 July 2026 → today |
What this means if you sell into France
- Already registered before July 2026? Your IDUs stay valid, but your eco-organisme membership must now be held through a French representative. Check with your eco-organisme how it handles existing foreign members.
- Selling to French consumers without French registration? You were already non-compliant; the fines (up to €30,000 per stream under article L. 541-9-5) and marketplace suspensions are the same as before. What changed is how you fix it: through a representative.
- Selling packaged goods to French businesses? This is the new part. Inventory your transport and sales packaging by material and weight, and join a professional packaging eco-organisme before the end of 2026.
Use the scope check to see which case is yours, and the Free EPR Calculator to see what the eco-contributions cost at the official 2026 rates.
Frequently asked questions
Is EPR in France new in 2026?
No. Packaging EPR has existed since 1992 and the IDU since 2022. What is new in 2026 is the mandatory France-based representative (10 July), the EU packaging regulation (12 August) and professional packaging fees (1 January 2027).
Could a foreign company register with Citeo or Léko directly before 2026?
Yes. Until 10 July 2026 a foreign producer could join an eco-organisme in its own name. Since then, a producer not established in France must go through a France-based representative.
Does the EU suspension proposal cancel the French representative rule?
No. The proposal concerns the EU regulation (PPWR) and only EU-based companies, and it has not been adopted. France's article L. 541-10-9-1 is national law and applies regardless.
I only ship pallets and cartons to French businesses. Am I affected?
Yes, from 1 January 2027. Professional packaging joins EPR then; membership with Citeo Pro, Léko Pro or Twiice is expected before 31 December 2026. If you are not established in France you also need a representative.
Sources
- Légifrance — Code de l'environnement
- Ministère de la Transition écologique — filières REP
- EUR-Lex — Regulation (EU) 2025/40 (PPWR)
- European Commission — PPWR guidance notice C(2026)3702
- ADEME — French EPR schemes, PROs and IDU register
- Léko Pro — Barème emballages professionnels, 2nd half 2026
- Citeo Pro — Guide du tarif EPRO 2026
- Eldris — EU EPR Seller Compliance Index 2026 (June 2026)
- Eldris — Non-EU sellers EU EPR gap (2026)
- Citeo — Déclarer (98,000 clients)
- Commission estimate of the representative-services market (€1–2 bn/yr), reported Aug 2026