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French EPR representative rule in effect since 10 July 2026 · day 105Check if it applies to you →
Since 10 Jul 2026 · Check if it applies to you →
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French EPR representative for China sellers

No establishment in France means you are the producer for French EPR, wherever your company is registered.

Quick answer

A company based in China that sells to customers in France without an establishment there is the producer under French EPR. Since 10 July 2026 it must appoint an authorised representative established in France (article L. 541-10-9-1 of the Environmental Code), join an eco-organisme for each stream and hold one IDU per stream. No registration in China replaces the French one. EPR France Rep handles all of it: Standard costs €190 a year for one stream and Plus €990 a year for up to three, with a median saving of €1,071 a year in eco-contributions across our published examples, with €0 setup. Eco-contributions are paid at the official rate, with 0% markup. Our website and written support are available in English, French, German, Spanish, Italian, Chinese and Turkish.Légifrance

Quick facts
Based in
China
Typical sales channels
Amazon.fr and FBA, Temu, Shein, AliExpress, TikTok Shop, Cdiscount, own stores, French importers
Your home registration
No registration in China counts in France
Our fee
Standard €190 a year for one stream; Plus €990 a year, with a median saving of €1,071 a year in eco-contributions across our published examples
Setup
€0, no deposit
IDU
One per stream, typically one to three weeks after the membership is filed
Languages
Website and written support in English, French, German, Spanish, Italian, Chinese and Turkish
Your setup

Who is the producer in your setup?

Amazon FBA, France or Pan-European

Every unit Amazon delivers to a French customer is placed on the French market by the seller: your company is the producer.

Temu, Shein, AliExpress, TikTok Shop sellers

If you are the seller on the platform, you are the producer for your goods, and the platform asks for your IDU. See does a marketplace cover me?

Own store shipping from China

You sell directly to French consumers: you are the producer from the first parcel, and your IDU goes on your website.

Factory selling to a French importer

If the importer buys your goods and resells them, the importer is the producer. If you still own the goods when they reach the French customer, you are.

Hong Kong or trading company in the group

The company that sells to French customers and holds the seller account is the producer and signs, whichever company in your group that is.

French businesses use the goods

You are the producer. Professional streams apply, and professional packaging from 1 January 2027.

The rule

Do we need it?

When does French EPR start for a company based in China?

With the first product it places on the French market: the first Amazon.fr order delivered to a French customer, the first parcel from your own store to a French address, the first shipment to a French business that uses the goods. There is no minimum quantity, and free samples and giveaways count too. Where the goods are made or stored plays no part.

Is a French representative compulsory for a company based in China?

Yes. Since 10 July 2026, article L. 541-10-9-1 of the Environmental Code requires every producer not established in France, inside or outside the EU, to appoint a representative established in France by written mandate, for every EPR stream. The representative is subrogated in your obligations: it holds your memberships, your IDUs and your declarations. You remain the producer, and the eco-contributions remain yours.

Does any registration in China count in France?

No. France keeps its own register and issues its own identifier, the IDU, for each stream. Nothing registered in China, Hong Kong or another EU country replaces it.

We have a French VAT number. Does that make us established in France?

No. French tax law itself treats companies with a French VAT number as foreign companies not established in France. You still need a French representative. See VAT number and establishment.

Our stock is at a fulfilment centre or 3PL in France. Does that make us established there?

No. A warehouse, a 3PL or an Amazon fulfilment centre is someone else's premises run by someone else's staff, not an establishment of your business. What French stock does mean is that its parcels to French customers are your sales, so you are the producer. See does a French warehouse make me established?

Which company

Who signs and who is the producer

Which company should sign: the factory, the trading company or our Hong Kong company?

The company that sells to French customers, because it first places the goods on the French market. On a marketplace that is normally the company holding the seller account and invoicing the customer. That company is the producer, signs the mandate and receives the IDU. A factory selling to a French importer that buys and resells the goods is not the producer for those goods: the importer is.

Must the IDU be in the name of the company that holds our seller account?

Yes. The IDU is issued to the legal entity that places the goods on the French market, and marketplaces check it against ADEME's public register. Register the company that holds the seller account and invoices French customers; an IDU in the name of a sister company or your factory will not match.

We sell to a French distributor or importer. Who is the producer?

The company that first places the goods on the French market. If a French company buys your goods and resells them, it is the producer for those goods and you need nothing in France for that flow. If you sell directly to French consumers, or to French businesses that use the goods themselves, you are. The Incoterm (DDP, DAP, FOB) does not change this. See DDP, DAP and who the producer is.

We also sell to French businesses. What changes?

Products used by businesses can fall under professional streams, and professional packaging (EPRO) applies from 1 January 2027. Plus Pro, €990 a year, covers your consumer and business streams together, up to three.

Amazon and marketplaces

Amazon.fr, Temu, Shein, AliExpress, TikTok Shop

We sell on Temu, Shein, AliExpress or TikTok Shop. Is the platform the producer?

Not for your goods. A marketplace must make sure its sellers are covered, and the law treats the duty to appoint a representative as met only for products where a platform established in France ensures compliance. That carve-out is per product and per channel: it gives you no IDU and does not cover Amazon.fr, your own store or any other platform. See does a marketplace cover me?

Amazon.fr asks for our EPR number, or has deactivated listings. What now?

You need your own IDU for each stream your products fall under. We sign the mandate with you, join the eco-organismes in your name, and ADEME issues the IDUs, typically within one to three weeks. Once a valid IDU is entered in Account Health, reactivation typically follows within a few business days. See Amazon.fr asks for an EPR number.

Do we need a separate IDU for each marketplace?

No. The IDU is issued to your company per stream, not per marketplace. The same identifier goes into Amazon.fr, Cdiscount, ManoMano, TikTok Shop, Zalando and your own website. What you need is one IDU per stream: a speaker with a built-in battery needs three (packaging, electrical equipment, batteries). See several IDUs.

Amazon or TikTok Shop pays the eco-contributions for us. Isn't that enough?

No. Pay on Behalf services only pay eco-contributions for what that platform sells for you. They give you no IDU, do not cover your own website or other marketplaces, and the platforms ask sellers for their own EPR numbers. See Amazon Pay on Behalf.

Your products

Streams, labels and fast fashion

We sell electronics. Which streams apply?

Usually three: household packaging, electrical and electronic equipment (ecosystem or Ecologic), and batteries when your products contain or come with batteries. Each has its own membership and IDU. Plus covers all three: Plus €990 a year, with a median saving of €1,071 a year in eco-contributions across our published examples. See electrical equipment.

We sell clothing. Does the fast-fashion malus apply to us?

Since 1 September 2026 Refashion applies a malus to ultra-fast-fashion practices: very wide ranges and very frequent new offers. Most brands are not affected; we assess your range against the criteria before you declare. See textiles.

Do our packaging labels need to change for France?

Household packaging sold in France must carry the Triman logo with sorting instructions (Info-tri), whatever its origin. Many brands add a French sticker or a France-specific print run. See Triman and the sorting label.

Getting registered

Cost, documents and timing

What does it cost?

Standard costs €190 a year for one stream. Plus covers up to three streams: Plus €990 a year, with a median saving of €1,071 a year in eco-contributions across our published examples. Setup is €0 and there is no deposit. Eco-contributions are paid to the eco-organismes at their published rates, with 0% markup. You see the full price on the pricing page and can order online the same day.

What details do you need from a Chinese company?

Your company name and address and, without an EU VAT number, the registration number issued by your tax authority: for a mainland company, its unified social credit code. Then your product families, packaging, sales channels into France, and the signed mandate. See details for a French IDU.

Do you work in Chinese?

Yes. Our website is available in Chinese, and our written support answers in Chinese as well as English, French, German, Spanish, Italian and Turkish. Your mandate, memberships and declarations are filed in French with the eco-organismes; we explain each step to you in Chinese.

How long until we have our IDUs?

Once the memberships are filed, the eco-organismes register you and ADEME issues one IDU per stream, typically within one to three weeks.

How often do we declare, and who files?

Most streams declare once a year, for the previous year's sales, on each eco-organisme's own calendar; some ask for more frequent declarations above certain volumes. You send your sales figures; we prepare and file each declaration.

We already joined Citeo or another eco-organisme directly. Do we start again?

No. Your membership and your IDU stay valid. Since 10 July 2026 you need a representative on top: you appoint us and the membership runs under our mandate. See keeping an existing membership.

What happens if we are not registered?

Marketplaces selling to French customers must check that their sellers hold an IDU for each stream (article L. 541-10-9) and deactivate listings without one. Article L. 541-9-5 provides fines of up to €30,000, and up to €7,500 per unit or tonne for a company.

Year one

What a business like yours pays in year one

Electronics seller on Amazon.fr

Streams
Household packaging, electrical equipment, batteries
Plan
Plus, €990 a year, €0 setup
Example
1,000 smartphones a year: €4,420 at basic rates, €2,560 with Plus

Saving in eco-contributions with Plus
€1,860

Toy seller on Amazon.fr and Temu

Streams
Household packaging, toys, batteries if the toys contain them
Plan
Plus, €990 a year, €0 setup
Example
8,000 plush toys a year: €1,760 at basic rates, €640 with Plus

Saving in eco-contributions with Plus
€1,120

Apparel seller on Shein, TikTok Shop or its own store

Streams
Household packaging, textiles
Plan
Plus, €990 a year, €0 setup
Example
2,000 women's trainers a year: €1,282.80 at basic rates, €226.80 with Plus

Saving in eco-contributions with Plus
€1,056

Eco-contributions at the eco-organismes' published 2026 rates, before our fee. Packaging contributions and VAT not included. Calculate your saving with Plus →

After you order

What happens after you order

1. Order online

Choose your plan on the pricing page and pay by card. No quote to wait for.

2. Your client portal

You land in your portal: sign the mandate, add your company details and name your streams.

3. Memberships filed

We join the eco-organismes in your name, one per stream.

4. Your IDUs

ADEME issues one IDU per stream, typically within one to three weeks. You enter them in your marketplace accounts and on your website.

5. Declarations

You send your sales figures; we prepare and file each declaration.

Know your cost in two minutes

Official eco-organisme rates, 0% markup, no waiting for a quote.