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.
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
- Administrative fines under articles L. 541-9-5 and L. 541-9-6 — reported by practitioners as up to €30,000 for failing to register or display a valid identifier, and up to €7,500 per unit or tonne placed on the market without contribution (legal persons).
- Marketplace blocking: platforms are jointly responsible for sellers' EPR compliance in France and check IDUs.
- Controls cross-referencing EPR registrations with company registers.
Always check the current wording of the articles on Légifrance before relying on an amount.
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.