French EPR representative or EU authorised representative?

Five representatives sellers mix up

Representative	Law	Covers	Where
French EPR representative (mandataire)	Code de l'environnement Légifrance	All French EPR streams	France
PPWR authorised representative	Regulation (EU) 2025/40 EUR-Lex	Packaging EPR	Each member state
German WEEE authorised representative	ElektroG	Electronics in Germany	Germany
GPSR responsible person	Regulation (EU) 2023/988 EUR-Lex	Product safety	EU
Fiscal representative	VAT rules	VAT	Per country

One company can hold several roles, but each needs its own mandate. We act as the French EPR representative.

Who is the producer, by set-up

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

Dates

When	What	Source
Before the first French sale	Representative appointed, IDU per stream, IDUs in every marketplace ADEME	Légifrance+1
On every household pack	Triman and Info-tri	French Ministry of Ecologica
From 1 January 2027	Professional packaging scheme, if you sell to businesses	ADEME
Early the following year	Declaration of the previous year's French sales	Citeo
All year	Eco-contributions at published rates, no markup	Léko

Sanctions

Failure	Sanction	Source
Not meeting EPR duties after formal notice	Up to €1,500 (individual) or €7,500 (company) per unit or tonne concerned	Légifrance
Still not complying	Daily penalty up to €20,000	Légifrance
Register and IDU failures	Fine up to €30,000	Légifrance
No IDU on a marketplace	The platform blocks the listing or pays in your place	Ministère de l'Écologie

Streams the French rule covers

Stream	Eco-organismes	Source
Household packaging and paper	Citeo, Léko, Adelphe	Léko
Professional packaging (2027)	Citeo Pro, Léko Pro, Twiice	ADEME
Electrical and electronic equipment	ecosystem, Ecologic, Soren	ADEME
Batteries	Batribox, ecosystem	BBatribox
Textiles and shoes	Refashion	Refashion
Furniture	Ecomaison, Valdelia, Valobat	ADEME
Toys	Ecomaison	Ecomaison
Sports and leisure	Ecologic	Ecologic

Who does what with a partner

Task	Your firm	EPR France Rep
Spot that a client sells into France	Yes
Act as representative in France		Yes Légifrance
Join eco-organismes and obtain IDUs		Yes ADEME
Collect sales figures	Often, from the client's books	We tell you what we need
File declarations		Yes
VAT, customs, product safety	Yours or the client's	Not covered

Short version

French EPR asks for a representative established in France, appointed by written mandate, for every producer not established there, EU or not, and for every French EPR stream. Légifrance An EU-wide product-safety person or a representative in another member state does not meet it unless it is established in France and signs that mandate.

The roles side by side

Role	Set by	Covers	Covers French EPR?
French EPR representative (mandataire)	Article L. 541-10-9-1, French law Légifrance	Memberships, IDUs, declarations and contributions in France, all streams	Yes
Authorised representative for packaging EPR	EU packaging regulation 2025/40 EUR-Lex	Packaging EPR in the member state where it is appointed	Only packaging, and only if appointed for France
Product-safety responsible person	General Product Safety Regulation 2023/988 EUR-Lex	Product safety documents and contact for authorities	No
German packaging representative	German packaging law, LUCID register SStiftung Zentrale Stelle Ver	Packaging in Germany	No
German WEEE representative	ElektroG, stiftung ear SStiftung EAR	Electrical equipment in Germany	No

Why one European representative is not enough

EPR is run country by country: each member state has its own register, schemes and fees. The EU packaging regulation keeps that shape, with a representative appointed per member state. EUR-Lex France's own rule goes further than packaging: it covers every French EPR stream, from electronics to furniture. Légifrance

Questions to ask a provider

1. Which entity signs the mandate, and is it established in France?
2. Does the mandate cover every stream you sell in, or only packaging?
3. Who files the declarations and pays the contributions?
4. Whose name is on the eco-organisme account?

The safety role is separate

Product safety rules need an economic operator in the EU for many products sold online. EUR-Lex That person keeps safety documents and answers authorities; it does not join eco-organismes or declare packaging. You may need both roles, and one company can hold both if it is set up for each.

Standard is €190 a year per eligible stream (up to three), up to 1 tonne a year per stream, with simplified reporting and one declaration a year; Plus is €990 a year for up to three streams, with detailed reporting that optimises your eco-contributions, up to 10 tonnes. There is no setup fee. Eco-contributions are passed on at cost, with 0% markup. See pricing or the calculator.