Two questions decide it, in this order. First: does your French customer use the goods or resell them? A customer that uses them, a hotel, a canteen, a factory, an office, is an end user, which makes you the producer in France. Second: which stream does the product fall in? Furniture, electrical equipment, batteries and textiles are live today, so if your goods fall in one of them you owe eco-contributions now, not in 2027. Only the transport packaging waits for professional packaging on 1 January 2027. A B2B sale is not the same thing as professional packaging, and assuming it is makes companies two years late. A producer not established in France acts through a French EPR representative such as EPR France Rep for whichever streams apply.
The two questions, in order
- Does your French customer use the goods, or resell them? If it buys and resells, that French company is the producer and you are not, for those flows. If it uses them itself, you are the producer.
- Which stream does the product fall in? This decides whether you are late. Professional furniture, electrical and electronic equipment, batteries and textiles all have running schemes today. Professional packaging is the only one that starts on 1 January 2027.
Most people collapse the two and conclude "we are B2B, so our deadline is 2027". That is wrong whenever the product itself sits in a live stream.
Worked example: Dutch company, office chairs, hotel in Lyon
The hotel uses the chairs, so it is an end user and the Dutch company is the producer in France. Office chairs supplied to a hotel are professional furniture, a stream run by Valdelia, with published schedules for 2026 and 2027 charged per kilogram by function and main material. That scheme has been running for years.
So this company owes eco-contributions today, and because it is subject to French EPR and not established in France, article L. 541-10-9-1 requires it to act through a French representative now. The packaging around the chairs is a second, later matter: it goes to a professional, so it falls under professional packaging from 1 January 2027.
Worked example: German company, packaged sandwiches, caterer in Paris
Here it turns on what the caterer does. A catering company normally serves the sandwiches on to its own customers, so it resells. In that case the caterer, as the first company placing the packaged product on the French market, is the producer for the sandwich wrapping, and the German supplier is not.
The wrapping is worth a second look: packaging that reaches a consumer is household packaging whatever the sales channel, not professional packaging. What the German supplier is producer for is the transport packaging it delivered to the caterer, the crates, film and cartons, which are used by a professional. That is professional packaging, from 1 January 2027.
Two things flip this. If the customer is a staff canteen consuming the sandwiches itself, it is an end user and the supplier becomes the producer for the household packaging too, which is live now. And if the German company also sells anything direct to French consumers, a webshop or a marketplace listing, that flow is household packaging and it is late already.
Where the packaging ends up decides the stream
| Packaging | Stream | Live from |
|---|---|---|
| Wrapping that reaches a consumer, whoever you invoiced | Household packaging | In force (since 1992) |
| Pallets, film, crates used by the business you supply | Professional packaging (EPRO) | 1 January 2027 |
| The product itself: furniture, EEE, batteries, textiles | Its own stream | In force |
When you do not need a mandataire
- Your French customer resells. The customer is the producer for those flows; give it the packaging weights and materials it needs and put that in the supply contract.
- You are established in France. A French entity carries the obligations directly, joins the eco-organismes in its own name and holds the IDUs.
- A French-established company already assumes the obligations for those products. Article L. 541-10-9-1 says the duty is then deemed satisfied.
In every other case, a producer not established in France must appoint one by written mandate.
What we do
We map your customers into users and resellers, tell you in writing which streams are live for you today and which start in 2027, and register only the flows that need it. Where you are late, we regularise the live streams first. Check your streams with the scope check and the cost with the Free EPR Calculator.
Frequently asked questions
We only sell B2B. Is our deadline 1 January 2027?
Only if professional packaging is your sole exposure. If the product itself falls under a live stream, professional furniture, electrical equipment, batteries or textiles, you owe eco-contributions today and the representative obligation already applies.
Our customer is a hotel. Does that make us the producer?
Yes, if the hotel uses the goods rather than reselling them. A business end user is not a distributor, so the foreign supplier is the first to make the goods available in France.
We sell packaged food to a French caterer who serves it on. Who registers?
If the caterer resells or serves the product on, the caterer is the producer for the packaging that reaches consumers. You remain the producer for the transport packaging you delivered, under professional packaging from 1 January 2027.
Is B2B packaging always professional packaging?
No. The stream follows where the packaging ends up, not who you invoiced. Wrapping that reaches a consumer is household packaging even when you sold to a business.
Sources
- Légifrance — Code de l'environnement
- ADEME — French EPR schemes, PROs and IDU register
- Valdelia — Barème éco-contribution DEA professionnels 2026 / 2027
- Citeo Pro — Guide du tarif EPRO 2026
- Twiice — Guide des barèmes Emballages professionnels, July 2026
Founder of EPR France Rep, the France-based EPR authorised representative for companies selling into France.
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