Avoiding double declaration of packaging in France
If a supplier and an importer both declare the same units, you pay twice for one pack. The fix is a written split by flow.
Who declares, by supply chain
Each package is declared once, by the company that places it on the French market. 
Légifrance Two parties declaring the same unit is the most common overpayment we see.
| Situation | Who declares the packaging | Who must not |
|---|---|---|
| You sell to French consumers from abroad | You | Your carrier or 3PL |
| You sell on Amazon.fr and Amazon pays on your behalf Amazon Seller Central | Amazon, for those orders Amazon | You, for the same orders |
| You supply a French retailer that sells under its own brand | The retailer | You |
| You supply a French retailer under your brand | You, unless the contract moves it to the retailer | Both |
| A French importer clears and resells | The importer | You |
| Dropshipping supplier ships to the shop's French customers | The shop that sells to the consumer | The supplier |
What a split looks like in practice
| Packaging element | Typical declarant |
|---|---|
| Product box and inner packaging | Brand owner or importer |
| Shipping box added by a French warehouse | The company selling to the consumer |
| Pallets and stretch film to a French retailer | Professional packaging from 1 January 2027, declared by the supplier  ADEME |
| Retailer's own carrier bag | The retailer |
Write the split into your supply contract and give each party's IDU. Keep the units each party declares so the figures add up at year end. ADEME
Household rates you could pay twice
Per kilogram, at Léko's published household rates: 
Léko Léko
Household packaging and graphic paper Emballages ménagers et papiers graphiquesCiteo, Léko, AdelpheLéko9 rates
| Product | Official rate |
|---|---|
| Steel | €0.0645 / kg |
| Aluminium | €0.246 / kg |
| Paper and cardboard | €0.255 / kg |
| Glass | €0.02 / kg |
| Clear PET bottles | €0.68 / kg |
| PE packaging, rigid or flexible | €0.748 / kg |
| Packaging containing PVC | €2.72 / kg |
| Wood, cork | €0.255 / kg |
| Graphic paper (under 5 t a year exempt) | €92.00 / t |
Who is the producer
| Set-up | Producer for French EPR |
|---|---|
| You sell to French customers and ship from abroad | You Légifrance |
| Your stock is in a French or EU warehouse, sold in your name | You |
| A French distributor imports and resells | The distributor |
| A marketplace buys and resells as retailer | The marketplace |
| A retailer sells your goods under its own brand | The retailer |
Who runs what in France
- Household packaging and graphic paper: Citeo, Léko and Adelphe are the approved eco-organismes. Sources (3)
CiteoCiteoLékoLékoAdelpheAdelphe - The Ministry for Ecological Transition publishes the general framework for French EPR schemes.
Ministère de la Transition é - SYDEREP, ADEME's register, holds each producer's registration and IDU. ADEME
Why it happens
Both sides act in good faith. The foreign supplier declares everything it ships to France. The French importer declares everything it sells. France has one producer per flow: the party first placing the goods on the French market. Légifrance Nobody cross-checks the two declarations for you.
Who declares, by scenario
| Scenario | Who declares | Watch out for |
|---|---|---|
| You sell to French consumers from abroad | You | All your channels together |
| A French importer buys from you and resells | The importer | Remove those units from yours |
| Both at once | Each for its own flow | This is where overlap starts |
| You supply a marketplace seller based in France | Normally that seller | Agree it; see the producer question |
| You buy from a French supplier and sell on Zalando | Your supplier for the goods, you for shipping packaging | Zalando asks for both numbers Zalando |
| Amazon paid on your behalf for some units | Amazon, for those units | Do not declare them again without checking; see Pay on Behalf |
A clause you can adapt
A short line in the supply contract settles most of it. Adapt it with your lawyer:
“For goods sold under this agreement and first placed on the French market by the Buyer, the Buyer is the producer for household packaging and shall declare them under its own unique identifier. The Seller shall not declare those units. Each party shall give the other its unique identifier on request.”
Keeping the split
- Tag each sale by flow in your export.
- Keep the other party's IDU, and check it.
- Keep the working with your declaration.
- Recheck when a distributor or channel starts or ends.
If you already declared twice
Ask your eco-organisme: each has its own rules and deadlines for corrections, and we will not guess at them here. If we file for you, send us both declarations. Never correct by simply lowering a figure you cannot support. ADEME
Selling into France without a French entity?
Start your mandate online today: we register you with the eco-organismes and obtain your IDU.