PPWR Article 45(3): the authorised representative rule

PPWR Article 45 authorised representative in France: who needs one

Your situation	PPWR Article 45(3)	French law (L. 541-10-9-1)
EU company selling directly to consumers in France	Representative for packaging in France EUR-Lex	Representative for every French stream Légifrance
Non-EU company selling directly to consumers in France	Representative for packaging in France: points (c) and (d) include producers established in a third country EUR-Lex	Representative for every French stream Légifrance
EU company selling only to a French distributor	Not caught: it does not sell directly to end users in France EUR-Lex	Depends on who first places the goods on the French market
Company established in France	Not caught in France EUR-Lex	Not caught Légifrance

In France one mandate with a representative established in France covers both rules: packaging under the PPWR and every other stream under French law. EUR-Lex

Packaging in France: 10 July and 12 August 2026

Date	What started	Source
10 July 2026	French law: a representative established in France for every producer not established there	Légifrance
12 August 2026	PPWR applies: producer registration in each member state (Article 44) and the authorised representative rule (Article 45(3)) EUR-Lex	EUR-Lex

PPWR registration in France and the packaging EPR representative

Article 44 requires registration in the producer register of each member state before packaging is made available there. EUR-Lex In France, a producer of household packaging joins an approved eco-organisme and is registered with ADEME, which gives it an IDU for the stream. ADEME As your representative we do both for you, in your company's name: see household packaging.

EU producer selling across the border into France: three examples

• A German online shop shipping to French consumers: a producer under point (d) in France. It needs a representative in France under both rules.
• A Spanish brand on Amazon.fr: the same, unless Amazon ensures its EPR obligations for those products, in which case the French duty is deemed satisfied for them. Légifrance
• An Italian maker selling only to a French importer: the importer first places the goods on the French market and is the producer there.

The same rule in other countries: which roles cover what.

Article 45 next to the French rule

	PPWR Article 45	French rule
Applies since	12 August 2026 EEuropean Commission	10 July 2026 Légifrance
Streams	Packaging	Every French EPR stream
EU companies	Covered	Covered
Form	Written mandate EUR-Lex	Written mandate

What the representative takes on

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

First year in France

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

What the article says

Article 45 of Regulation (EU) 2025/40 is headed "Extended producer responsibility". Its paragraph 3 says that a producer referred to in Article 3(1), point (15)(c) and (d), "shall appoint, by written mandate, an authorised representative for the extended producer responsibility in each Member State where the producer makes packaging or packaged products available for the first time, other than the Member State where the producer is established." EUR-Lex We read the text on EUR-Lex on 6 November 2026.

Who points (c) and (d) cover

Both are producers established in a member state or in a third country that make packaging available for the first time on the territory of another member state, directly to end users. EUR-Lex

Who it catches, in practice

How France's own rule differs

	PPWR Article 45(3)	French article L. 541-10-9-1
Source	EU regulation, applies since 12 August 2026 EUR-Lex	French law, in force since 10 July 2026 Légifrance
Streams	Packaging only	Every French EPR stream
Who	Producers selling directly to end users in another member state	Every producer subject to French EPR and not established in France

What to do

1. List each member state where you sell directly to end users.
2. Appoint a representative in each one, by written mandate.
3. Register in each national producer register.
4. In France, one mandate with a representative established in France covers packaging and your other French streams.

How this fits with us

For France we are the representative under both rules. For Germany and Spain our sister companies do the same: which roles cover what.

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.