A mandataire REP is a company established in France that a foreign producer appoints by written mandate to carry its French Extended Producer Responsibility obligations. English usually translates it as authorised representative, but the role is defined by French law, not by the translation. Since 10 July 2026 it is mandatory: a producer with no establishment in France can no longer join an eco-organisme, hold its own identifiers or file its own declarations alone — even if it has been doing exactly that, correctly, for years. The mandataire is subrogated in the obligations it accepts, which is why a name-only arrangement — you still declaring, the mandataire merely listed — does not exist.
If you have been doing it yourself, you no longer can
This is the part that surprises people. Thousands of foreign companies joined Citeo, Léko, Refashion, ecosystem or Ecomaison directly, obtained their identifiers and filed their own declarations, correctly, for years. That route closed on 10 July 2026 for any producer without an establishment in France.
Nothing you did before was wrong and nothing is cancelled: your identifiers stay valid and your declaration history stands. What changed is who is allowed to hold the membership and file. It now has to be a mandataire established in France, and the eco-organismes are asking their foreign members to designate one. The law behind it sets no transition period.
Three different things are called "representative"
| Role | Rules | Established where |
|---|---|---|
| Mandataire REP | French EPR, every stream | In France |
| Authorised representative (PPWR) | EU packaging regulation | In each member state of sale |
| Responsible person (GPSR) | EU product safety | Anywhere in the EU |
They are not interchangeable. A GPSR responsible person in Germany does nothing for French EPR, and an EU authorised representative for packaging does not satisfy the French requirement, which covers every stream and not only packaging.
What subrogation changes
The mandate does not create an assistant. Within the scope it accepts, the obligations become the mandataire's own: it is the party the administration and the eco-organisme pursue if a declaration is late, wrong or missing. Penalties reach €30,000 for failing to register or to display the identifier, and up to €7,500 per unit or tonne placed on the market without meeting the obligation.
That single fact explains the shape of the whole service, and the next section.
Why "representation only, we keep our declarations" is not on offer
It is a reasonable thing to ask for, and it is the most common request from companies that already manage their own compliance. It cannot be done — for a structural reason, not a commercial one. You cannot accept responsibility for a stream and disclaim the declarations inside it, because the declarations are the obligation. A mandataire that signs a mandate and never sees the figures is carrying unlimited liability for numbers it has not checked.
What is genuinely possible is a split of work rather than a split of responsibility:
- You keep the data. Your team produces tonnages, materials and unit counts exactly as it does today — that never moves, because only you know what you shipped.
- You submit it once, in your dashboard, by hand or by connecting your own system so the figures arrive automatically.
- The mandataire checks and files it under the mandate, holds the eco-organisme memberships and answers to ADEME.
The scope of the mandate is yours to set: one stream or all of them. What it cannot do is cover a stream halfway.
What a mandataire is not
- Not an eco-organisme. Citeo, Léko, Refashion and the others collect the eco-contributions; the mandataire joins them in your name.
- Not a lawyer or an accountant. There is no licence and no bar to join — the law asks for a person or company established in France acting under written mandate.
- Not a mailbox. An address in France with nobody carrying the obligations satisfies nothing.
- Not a substitute for product compliance. Declarations of conformity, technical files and safety marking stay with the manufacturer and the importer.
A two-minute check tells you whether the duty applies to you at all.
Frequently asked questions
Can I keep managing my French EPR declarations myself?
Not if your company is not established in France. Since 10 July 2026 the eco-organisme membership and the declarations have to be held through a mandataire established in France. You still produce the underlying data — tonnages, materials, quantities — and the mandataire checks and files it.
Is there an English word for mandataire?
It is usually translated as authorised representative, but that phrase also covers two other roles, under the EU packaging regulation and EU product safety rules. The French legal term is mandataire, and that is the role French EPR requires.
Can I appoint a representative just to have a name on file?
No. The mandataire is subrogated in the obligations it accepts, so it is the party pursued for a late or incorrect declaration. Representation that excludes the declarations is not something the law creates, or that a serious mandataire will sign.
I already have my IDU numbers. Do they disappear?
No. Your identifiers stay valid and your declaration history stands. The membership behind them is transferred to a mandataire; nothing is registered again from scratch.
Does one mandataire cover every stream?
One written mandate can cover every French EPR stream you fall under, with one membership and one identifier per stream. You decide which streams the mandate covers.
Does a German or EU authorised representative cover France?
No. A representative appointed under the EU packaging regulation in another member state, or a responsible person under EU product safety rules anywhere in the EU, does not satisfy the French requirement — which is national, covers all streams and requires establishment in France.
Sources
- Légifrance — Code de l'environnement
- ADEME — French EPR schemes, PROs and IDU register
- EUR-Lex — Regulation (EU) 2025/40 (PPWR)
Founder of EPR France Rep, the France-based EPR authorised representative for companies selling into France.
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