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*Example: 2,000 women's T-shirts a year, at Refashion's published 2026 rates. Your saving depends on your products and volumes.

French EPR representative rule in effect since 10 July 2026 · day 113Check if it applies to you →
Since 10 Jul 2026 · Check if it applies to you →
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FAQ

French EPR questions, answered

Everything foreign sellers ask about the French representative requirement, identifiers, costs and the EU context.

What does EPR stand for?

Extended Producer Responsibility — in French, responsabilité élargie du producteur (REP). The company that first places a product or its packaging on a market pays for its collection and recycling.

Is the French EPR representative requirement a proposal or law?

It is law. Article L. 541-10-9-1 of the French Environmental Code has applied since 10 July 2026.

Do EU companies need a French EPR representative?

Yes, if they are subject to French EPR and not established in France. The French requirement covers EU and non-EU producers alike. Check if you need a French EPR representative →

How much are the fines for not complying with French EPR?

Penalties are set by article L. 541-9-5 of the French Environmental Code: administrative fines of up to €30,000 for failing to register, filing wrong data or not displaying the IDU, up to €7,500 per unit or per tonne placed on the market without meeting the obligation (€1,500 for individuals), and daily penalties of up to €20,000. Marketplaces operating in France can also deactivate your listings. Read the 2026 law and penalties explained →

Does the representative take over my obligations?

Under the 2026 law the representative is subrogated in the EPR obligations covered by the written mandate: memberships, identifiers and declarations are handled in France on your behalf.

Do you take a percentage of eco-contributions?

No. Eco-contributions follow each eco-organisme's public tariff. Our service fee is set by the plan and published: €190 a year on Standard for one stream, €990 a year on Plus for up to three, with a median saving of €1,071 a year in eco-contributions across our published examples.

Which marketplaces check French EPR numbers?

Amazon.fr, Cdiscount, ManoMano, Fnac and other platforms operating in France request sellers' IDUs because article L. 541-10-9 of the Code de l'environnement puts the EPR obligations for products sold through a marketplace on the marketplace itself, unless the seller already covers them. Asking for your IDU is how a platform establishes that you do.

Do I need both an eco-organisme and a representative?

If you are not established in France, yes. They are different layers: the eco-organisme is the scheme that collects and recycles and that you pay eco-contributions to, and the mandataire is the France-established company legally allowed to hold that membership and file your declarations. A producer established in France needs only the eco-organisme.

Can I join Citeo directly without a representative?

Only if your company is established in France. Since 10 July 2026, a producer not established in France designates a mandataire established in France by written mandate, and the membership and declarations are held through it.

I already have a Citeo membership. Why would I need a representative?

Because since 10 July 2026 the membership has to be held by a mandataire established in France. Nothing is re-registered: your identifiers stay valid, your declaration history stands, the contributions you have paid are not paid again, and the membership moves under the mandate.

Citeo or Léko — which should I choose?

Both are approved for household and professional packaging, so it is a real choice. Their tariffs and eco-modulation differ by material, so compare against your own materials and tonnages rather than defaulting to the better-known name.

Does the representative choose the eco-organisme for me?

You decide, with our advice. If you already belong to one, you can stay with it; on Plus we compare all approved schemes for your streams and review the eco-modulation. Either way you stay the producer and the choice is yours to approve.

Is using a representative more expensive than going direct?

There is a service fee that a French-established company would not pay, and the eco-contributions are the same either way when they are passed through at cost. For a producer not established in France, going direct is not an available option to compare against — it stopped being one on 10 July 2026.

Can I keep managing my French EPR declarations myself?

Not if your company is not established in France. Since 10 July 2026 the eco-organisme membership and the declarations have to be held through a mandataire established in France. You still produce the underlying data — tonnages, materials, quantities — and the mandataire checks and files it.

Is there an English word for mandataire?

It is usually translated as authorised representative, but that phrase also covers two other roles, under the EU packaging regulation and EU product safety rules. The French legal term is mandataire, and that is the role French EPR requires.

Can I appoint a representative just to have a name on file?

The law sets the scope by what the mandataire accepts in the written mandate: it is subrogated in those obligations and is the party pursued for a late or incorrect declaration. So a mandate that excludes the declarations leaves them with you while your name sits on someone else's paperwork — which is why we do not sign one, and why you should read the scope clause of any mandate you are offered.

I already have my IDU numbers. Do they disappear?

No. Your identifiers stay valid and your declaration history stands. The membership behind them is transferred to a mandataire; nothing is registered again from scratch.

Does one mandataire cover every stream?

One written mandate can cover every French EPR stream you fall under, with one membership and one identifier per stream. You decide which streams the mandate covers.

Does a German or EU authorised representative cover France?

No. A representative appointed under the EU packaging regulation in another member state, or a responsible person under EU product safety rules anywhere in the EU, does not satisfy the French requirement — which is national, covers all streams and requires establishment in France.

Do I need a French EPR representative if I only sell B2B?

It depends on who buys. If your French customer resells the goods, that customer is the producer and you need no representative. If your French customer uses the goods itself, you are the producer in France and need a representative.

Is there a minimum quantity before French EPR applies?

For packaging there is no general minimum: one parcel sent to a French customer can make you a producer. Some eco-organismes offer simplified flat-fee regimes for small volumes, but registration still applies.

What drives the price?

Your plan, chosen for the calendar year. Standard is €190 a year for one EPR stream, Plus €990 a year for up to three, with a median saving of €1,071 a year in eco-contributions across our published examples, Plus Pro €990 a year when you also sell to businesses. There is no per-item fee and no setup fee. All plans cover up to 10 tonnes of packaging a year; above that, and for more than three streams, we quote a Custom plan.

Are eco-contributions included?

No. Eco-contributions are set by each eco-organisme's public tariff and paid at cost, with 0% markup. They are always shown separately from our fee.

Is there a setup fee?

No. Setup is €0 on every plan, and registration and IDU issuance are included.

Can I switch from Standard to Plus during the year?

Plans are chosen for the calendar year before the service starts and can be changed at renewal. If a second stream starts during the year, the extra work is scoped and priced separately. Choose using your expected full-year sales.

Which plan if I have more than one stream?

Plus. Standard covers one EPR stream, which for most sellers is household packaging. If you also sell textiles, electronics, furniture or another product with its own stream, Plus covers up to three, with eco-contribution optimisation that often lowers what you pay the eco-organismes.

Which plan if I sell to businesses?

Plus Pro, whenever you deliver to businesses as well: professional packaging (EPRO), professional equipment or another professional stream. It covers your consumer and business obligations together, up to three streams in total.

I already have my eco-organisme memberships and IDUs. Do I start again?

No. Your memberships move under our mandate and your IDUs stay valid. Contributions already paid for the year are not paid again.

I sign up in October. Do I pay again on 1 January?

Yes. Your plan covers the calendar year you join in, to 31 December, whatever the date you start, and renews on 1 January. There is no pro rata.

How long until I get my IDU?

It depends on the eco-organisme; we file on the day we have your details. Léko (household packaging): a few working days after its invoice is paid, about a week in our recent cases. Ecologic (electricals): about 72 hours after the membership contract is signed. Refashion (textiles): about 15 working days after its invoice is paid. These are their timings, so we cannot guarantee them.

What is the itemised total for two streams, for example clothing and packaging?

Setup: €0. Annual fee: €990 for Plus, with a median saving of €1,071 a year in eco-contributions across our published examples, which covers both streams together (up to three); it is not a fee per stream. Registration, IDU issuance and the annual declarations are included, and so is the written mandate required by article L. 541-10-9-1. There is no deposit and no other fee from us. Eco-contributions are separate, at the eco-organisme's published rate with 0% markup.

Is there a deposit or a minimum commitment?

No deposit and no security. The plan is annual and runs for the calendar year; it renews on 1 January unless you cancel in advance, as set out in our terms. Eco-contributions for the year are prepaid to us as an advance, estimated from your figures, and passed on to the eco-organisme at cost; any surplus is carried forward.

Can I ask for a quote, and is there a cheaper self-service option?

You can always ask us for a written quote, but you do not need one. Our prices are fixed and published, so nothing is added at the quote stage: what you see on this page is what you pay, and your invoice states the same amount. We prefer simple, transparent pricing upfront, with no surprises. Custom is the only plan priced on request. There is no separate self-service tier: Standard, at €190 a year for one stream, already includes the declarations.

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