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Use case · B2B supplier

We ship pallets of goods to French businesses. Are we affected?

Yes, if your French customers use the goods themselves (factories, hotels, offices, installers).

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Razvan TomaBy Razvan Toma · Founder
Last updated 15 September 2026Sources linked below
Quick answer

Yes, if your French customers use the goods themselves (factories, hotels, offices, installers). From 1 January 2027 the professional packaging you ship them, pallets, stretch film, cartons, drums and crates, falls under France's new B2B packaging scheme, with membership of Citeo Pro, Léko Pro or Twiice expected before 31 December 2026. Since 10 July 2026 a supplier not established in France acts through a French representative. If your French customer resells the goods, the customer is the producer and you are not.

The producer test for B2B

The question is what the French customer does with the goods. A distributor or retailer who resells them is the producer for the packaging that reaches its own customers, and for the transport packaging it received. A business that uses the goods, a plant installing your machine or a restaurant using your consumables, is an end user, which makes you, the foreign supplier, the producer. Contracts and Incoterms decide who is "first to make available" in borderline cases.

What the scheme costs

Contributions follow tonnage by material: 2026 published rates are about €218 per tonne for plastics, €35 for paper and cardboard, €8 to €9 for wood, with flat fees of €95 to €125 per half-year at or under two tonnes. A supplier shipping twenty tonnes of cardboard and two tonnes of film a year is looking at roughly €1,100 in eco-contributions.

What to do before the end of 2026

  1. Inventory your packaging by material and weight per shipment (your packaging supplier's specs are enough).
  2. Decide the eco-organisme: the three tariffs are within 1% of each other for plastics and cardboard; Twiice is cheapest under two tonnes.
  3. Appoint the French representative and join before 31 December 2026.
  4. Add electrical equipment (professional WEEE) if you ship powered equipment.

Frequently asked questions

Our customer is a French wholesaler. Are we the producer?

No. If the wholesaler buys and resells, it is the producer in France. Put the packaging data it needs in your supply contract.

Does the 2027 postponement mean we can wait?

Membership is expected before 31 December 2026; contributions start 1 January 2027. The representative obligation already applies.

We also sell spare parts online to French consumers. Which scheme?

Consumer sales fall under household packaging (Citeo, Léko); B2B shipments under professional packaging. Both can sit under one mandate.

Sources

Razvan Toma
Written byRazvan Toma

Founder of EPR France Rep, the France-based EPR authorised representative for companies selling into France.

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