Costly French EPR declaration mistakes
Most errors in a declaration come from counting, not from the form. Here are the ones to check, with the official rules behind them.
Counting units the wrong way
Your contribution is usually the number of units times a rate, so the unit matters. Citeo's own examples: Citeo Citeo
| What you sell | Units |
|---|---|
| A pack of 4 yoghurts sold together | 1 |
| A pack of 6 milk cartons that can be split | 6 |
| An appliance box with polystyrene wedges | 1 |
| A product pack plus its shipping carton | 2 |
Check whether that last line moves you across the 10,000-unit limit for Citeo's flat rate. Léko defines a unit as a packaged product for the end consumer, Léko so read the rules of your own scale.
Léko
Using the wrong rate column
Scales separate products shipped in a box from products that are not. For clothing at Citeo in 2026 that is €0.0069 against €0.0453 a unit, more than six times as much. Citeo If you ship to customers, use the shipping rate. Citeo says its shipping table is suited to marketplaces and their sellers.
Forgetting a sales channel
Your declaration covers what you placed on the French market in that stream, across all channels. Selling on Amazon plus your own store means merging both: how to merge the year's data. Amazon Seller Central
Declaring what someone else already covers
A supplier and an importer can both declare one pack. Units Amazon paid for under Pay on Behalf need checking too. Who declares what.
Filing only for packaging
Packaging is one stream. Clothing, electronics, furniture and others have their own eco-organisme and IDU. How many streams you have. Paper is another easy one to miss: leaflets and inserts. Sources (2)ADEMEADEME — Filière REP Éléments d'ameublement (EA)
ADEMEADEME — Filière REP Équipements électriques et électroniques (EEE)
Ministère de la Transition é
Mixing household and professional packaging
Professional packaging is a separate stream with its own scales, starting on 1 January 2027: what changes.
Assuming the simple route is the cheapest
At Citeo, bonuses and premiums need the per-unit declaration. Citeo Price both if your packs are light and recyclable. Citeo and Léko compared.
Missing the date
Dates vary by eco-organisme: the calendar. For specified registration, IDU and reporting breaches, article L. 541-9-5 allows fines of up to €30,000. Légifrance
A check before you submit
- Total sales match your channel exports for the calendar year.
- Every product sits in one family, with the right shipping column.
- Units covered by someone else are documented.
- Every stream you sell in has its own declaration.
- The working is saved with the declaration.
If you spot a mistake afterwards
Ask your eco-organisme: each has its own rules and dates for corrections, and we will not guess at them here. Keep the evidence for the figures you report. If we file for you, tell us first. ADEME
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.
Selling into France without a French entity?
Start your mandate online today: we register you with the eco-organismes and obtain your IDU.