You need a French EPR representative if you are the first company to make a product covered by French EPR available on the French market and you are not established in France. That includes companies in other EU countries and outside the EU. Since 10 July 2026 the appointment is mandatory under article L. 541-10-9-1 of the French Environmental Code. If a French importer or distributor buys from you and resells, that French company is the producer instead, and you do not need a representative.Sources (4)
LégifranceLégifrance — Code de l'environnement
EUR-LexEUR-Lex — Regulation (EU) 2025/40 (PPWR)European CommissionEuropean Commission — PPWR guidance notice C(2026)3702
ADEMEADEME — French EPR schemes, PROs and IDU register
How the "producer" is decided
EPR (Extended Producer Responsibility, REP in French) makes the producer pay for collecting and recycling products and packaging. The producer is whoever first makes the product or packaging available in France — manufacturer, importer or distributor — regardless of where it is based or how it sells. The EU packaging regulation uses the same logic: the European Commission's guidance says a company that buys a packaged product abroad and supplies it in its own country is the producer there.
- Producer status is per country. Being registered in Germany or the Netherlands does nothing for France.
- Selling directly counts. A company based elsewhere that sells straight to French consumers — or to French businesses that use the goods themselves — is the producer in France.
Worked examples
| Situation | Producer in France? | French representative? |
|---|---|---|
| German online shop selling to French consumers (own site or Amazon.fr) | Yes | Yes |
| Turkish or Chinese manufacturer shipping directly to French consumers | Yes | Yes |
| Non-EU brand with a Dutch BV shipping to consumers across the EU | Yes, in France (and in each destination country) | Yes — the Dutch BV is not established in France |
| Foreign supplier selling to a French shop or distributor that resells | No — the French buyer is | No |
| Foreign supplier selling to a French hotel or factory that uses the goods itself | Yes | Yes |
| Foreign group importing through its own French subsidiary | Yes — the French subsidiary | No, but the subsidiary must join the schemes, hold IDUs and declare |
Which products are covered
Packaging is the broadest trigger: almost every physical product sold in France comes in packaging, including shipping boxes and B2B packaging such as pallets, film and cartons. On top of packaging, France runs product-specific schemes — electrical and electronic equipment, batteries, textiles and shoes, furniture, toys, sports and leisure items, DIY and garden items, building products and more. One company can fall under several schemes at once. Even when a product itself is outside every scheme, the box it ships in is still packaging. See all French EPR streams.
Does an EU subsidiary remove the obligation?
No. A subsidiary in another EU country turns a non-EU company into an EU company, but that company is still not established in France. Only a French establishment removes the need for a French representative — and then that French entity carries the EPR obligations directly.
What happens if you do nothing
Marketplaces such as Amazon.fr check French EPR identifiers (IDUs) and can deactivate listings. The Environmental Code (article L. 541-9-5) provides administrative fines of up to €30,000 for not registering or not showing the IDU, up to €7,500 per unit or tonne placed on the market without meeting the obligation, and daily penalties of up to €20,000. the 2026 law explained.
Frequently asked questions
Do I need a French EPR representative if I only sell B2B?
It depends on who buys. If your French customer resells the goods, that customer is the producer and you need no representative. If your French customer uses the goods itself, you are the producer in France and need a representative.
Is there a minimum quantity before French EPR applies?
For packaging there is no general minimum: one parcel sent to a French customer can make you a producer. Some eco-organismes offer simplified flat-fee regimes for small volumes, but registration still applies.
Does the EU proposal to suspend authorised representatives affect France?
Not the French requirement. It comes from national law (article L. 541-10-9-1, in force since 10 July 2026) and applies independently of the EU packaging regulation debate.
Can a French distributor take over my EPR obligations?
If the distributor buys your goods and resells them in France, it is the producer by law. Put the split of roles and the packaging weight data it needs in your supply contract.
What does EPR stand for?
Extended Producer Responsibility. In French it is REP, responsabilité élargie du producteur: producers finance the collection and recycling of what they place on the market once it becomes waste.
What is the EPR system in the EU?
The EU sets EPR rules for packaging (Regulation (EU) 2025/40), electrical and electronic equipment and batteries, but each member state runs its own registers and schemes. Registering in one country does not cover another, and France adds national streams such as furniture, toys and DIY products.
Sources
- Légifrance — Code de l'environnement
- EUR-Lex — Regulation (EU) 2025/40 (PPWR)
- European Commission — PPWR guidance notice C(2026)3702
- ADEME — French EPR schemes, PROs and IDU register
Founder of EPR France Rep, the France-based EPR authorised representative for companies selling into France.
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