Law n° 2026-602 of 8 July 2026 created article L. 541-10-9-1 of the French Environmental Code. Since 10 July 2026, every producer subject to French EPR that is not established in France — in another EU country or outside the EU — must appoint, by written mandate, a representative established in France. The representative is subrogated in the EPR obligations it accepts under the mandate. The rule covers all French EPR schemes, not only packaging, and applies independently of the EU packaging regulation.Sources (4)
LégifranceLégifrance — article L. 541-10-9-1 of the Environmental Code (full text)
EUR-LexEUR-Lex — Regulation (EU) 2025/40 (PPWR)
Ministère de la Transition éMinistère de la Transition écologique — filières REPFrench Ministry of EcologicaFrench Ministry of Ecological Transition — FAQ on the Triman logo and sorting instructions
EPR in French law in brief
EPR (responsabilité élargie du producteur, REP) puts the cost of collecting and recycling products at end of life on the company that places them on the French market: the polluter-pays principle. According to ADEME, the first regulated EPR scheme in France was set up for household packaging in 1992; the general framework is article L. 541-10 of the Environmental Code. The 2020 anti-waste law (AGEC) extended it to new products, and France now runs 19 EPR streams (full list). The 2026 law explained below adds a mandatory French representative for producers based abroad.
What the law says, word for word
This is the whole of article L. 541-10-9-1 of the French Environmental Code, the provision that creates the duty. It is two paragraphs long. Read it on Légifrance.
« Lorsqu'une personne non établie en France est soumise au principe de responsabilité élargie du producteur en application des articles L. 541-10 ou L. 541-10-9, elle désigne, par mandat écrit, une personne physique ou morale établie en France en tant que mandataire chargé d'assurer le respect de ses obligations relatives au régime de responsabilité élargie des producteurs. Ce mandataire est subrogé dans toutes les obligations découlant du principe de responsabilité élargie du producteur dont il accepte le mandat. »
« L'obligation de désignation d'un mandataire est réputée satisfaite pour les produits pour lesquels une personne physique ou morale mentionnée à l'article L. 541-10-9 établie en France assure le respect des obligations relatives au régime de responsabilité élargie du producteur. »
Article L. 541-10-9-1, Code de l'environnement — created by law n° 2026-602 of 8 July 2026, art. 5. In force since 10 July 2026.
In plain English, the two paragraphs say:
- A person not established in France who is subject to EPR under article L. 541-10 (producers) or L. 541-10-9 (marketplaces) designates, by written mandate, a person or company established in France as its mandataire, and that mandataire is subrogated in all the obligations it accepts under the mandate.
- The duty is deemed satisfied for products where a marketplace established in France already ensures the EPR obligations for them.
There is no minimum volume, turnover or threshold
The article sets no floor. It does not mention units, tonnes, revenue, order counts or any de minimis. What triggers it is being subject to EPR at all — which follows from placing covered products on the French market, not from how much you place. A company shipping a few dozen parcels a year is caught on the same terms as one shipping millions. Small volumes change what you pay an eco-organisme, through flat-rate or simplified tariffs, and never whether the duty applies.
Key facts
| Item | Detail |
|---|---|
| Legal basis | Article L. 541-10-9-1, Code de l'environnement, created by law n° 2026-602 of 8 July 2026 (Journal officiel, 9 July 2026) |
| In force | 10 July 2026 |
| Who must appoint | Any person subject to French EPR not established in France (EU and non-EU) |
| Who can be appointed | A natural or legal person established in France, by written mandate |
| Scope | All French EPR schemes (packaging, professional packaging, electronics, batteries, textiles, furniture, toys and others) |
| Effect | The representative is subrogated in the EPR obligations covered by the mandate |
What changed compared with before
Since the 2020 anti-waste law (AGEC), foreign producers could already appoint a French representative, but it was an option. A 2023 Conseil d'État decision questioned whether such a representative could take over the producer's obligations. The 2026 law settles both points: appointment is now mandatory and the representative is subrogated within the scope of the mandate.
How it relates to the EU packaging regulation
The EU Packaging and Packaging Waste Regulation (EU) 2025/40 applies since 12 August 2026. Its Article 45 requires producers that sell packaging directly to end users in another member state to appoint an authorised representative there. The European Commission proposed suspending that requirement for EU-established companies; as of 15 September 2026 nothing has been adopted. Whatever happens at EU level, the French national obligation stays in place and covers schemes beyond packaging. More in PPWR authorised representatives.
Penalties and enforcement
Fines for producers are set by article L. 541-9-5 of the Environmental Code. The environment minister imposes them after giving the company one month to respond; the amounts below are maximums, scaled to the seriousness of the breach and the gain from it.
| Breach | Maximum |
|---|---|
| Not registered in ADEME's register, register not filled in, wrong data, or IDU missing from required documents | €30,000 |
| EPR obligation not met (no eco-organisme membership or contribution) | €7,500 per unit or tonne concerned for a company, €1,500 for an individual |
| Breach not corrected after a formal order | Daily penalty of up to €20,000 |
| Missing Triman logo or sorting instructions | Separate fine under article L. 541-9-4, checked by DGCCRF inspectors, applicable per product |
- Marketplace blocking: under article L. 541-10-9 a platform carries the EPR obligations for what it lists unless the seller covers them, so platforms check IDUs.
- Controls cross-referencing EPR registrations with company registers.
Article text checked in September 2026.
Consumer information: Triman logo and sorting instructions
- What: household products under an EPR scheme, including household packaging (except glass beverage packaging), must carry the Triman logo together with sorting instructions, known as Info-tri (article L. 541-9-3, in force since 1 January 2022).
- Where: on the product or its packaging; a sticker on the packaging counts. For products, the documents supplied with them are allowed as a fallback.
- Small packs: if the largest face is 10 to 20 cm², only the logo is required on pack and the instructions can be online; below 10 cm², both can be online.
- Electronics and batteries: the EU crossed-out wheelie bin can replace the Triman logo, but not the French sorting instructions.
- B2B only: products that cannot reach households do not need it.
Timeline
| Date | Event |
|---|---|
| 10 July 2026 | Mandatory French EPR representative for producers not established in France |
| 12 August 2026 | EU packaging regulation (PPWR) applies in all member states |
| 31 December 2026 | Deadline to join an eco-organisme for professional packaging |
| 1 January 2027 | Professional packaging eco-contributions start (details) |
Frequently asked questions
Is the French EPR representative requirement already in force?
Yes. It has applied since 10 July 2026, the day after law n° 2026-602 was published in the Journal officiel.
Does the law apply to companies based in other EU countries?
Yes. It applies to every producer not established in France, including companies established elsewhere in the EU.
Does a French EPR representative need a licence?
The law requires a natural or legal person established in France acting under a written mandate. We found no separate licence or accreditation requirement.
Does the representative pay the eco-contributions?
Eco-contributions follow each eco-organisme's public tariff and are owed for the producer's volumes. The representative handles membership, identifiers and declarations; invoicing depends on the scheme and the mandate.
What does EPR mean in France?
EPR stands for Extended Producer Responsibility, REP (responsabilité élargie du producteur) in French. The company that first places a product on the French market pays for collecting and recycling it through an approved eco-organisme and holds an IDU for each scheme.
What are the fines for French EPR non-compliance?
Under article L. 541-9-5 of the Environmental Code: up to €30,000 for not registering, filing wrong data or not showing the IDU; up to €7,500 per unit or tonne concerned for not meeting the EPR obligation (€1,500 for individuals); and a daily penalty of up to €20,000 until the breach is fixed. Marketplaces can also deactivate listings.
Is the Triman logo mandatory in France?
Yes, for household products under an EPR scheme, including household packaging except glass beverage packaging. The logo must come with sorting instructions (Info-tri). For electronics and batteries the crossed-out wheelie bin can replace the logo, but not the sorting instructions.
Is there a minimum number of shipments or a turnover threshold before I need a French EPR representative?
No. Article L. 541-10-9-1 contains no minimum volume, turnover or de minimis threshold. The duty follows from being subject to EPR at all, which comes from placing covered products on the French market. Low volumes can reduce what you pay an eco-organisme through flat-rate tariffs, but they do not remove the obligation.
Where can I read the French EPR representative law itself?
Article L. 541-10-9-1 of the Code de l'environnement, on Légifrance. It was created by law n° 2026-602 of 8 July 2026, article 5, and has applied since 10 July 2026. It is two paragraphs long and quoted in full in this guide.
Sources
- Légifrance — article L. 541-10-9-1 of the Environmental Code (full text)
- Légifrance — Code de l'environnement
- EUR-Lex — Regulation (EU) 2025/40 (PPWR)
- Ministère de la Transition écologique — filières REP
- French Ministry of Ecological Transition — FAQ on the Triman logo and sorting instructions
Founder of EPR France Rep, the France-based EPR authorised representative for companies selling into France.
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