It depends on who first makes the product available on the French market. If a French retailer, wholesaler or distributor buys your goods and resells them, that French company is the producer for household packaging and product streams, and you need no French registration for those flows. If you ship directly to the retailer's customers (dropshipping), or to French businesses that use the goods themselves, you are the producer and need a French representative. Most suppliers have both flows and must sort them.
The rule
Article L. 541-10 of the Environmental Code defines the producer as the person who first places the product on the French market. A French buyer who resells is, by definition, that person. Amazon's own guidance to sellers says the same: if you are not the producer, enter your supplier's registration numbers and tick "not the producer".
Three flows, three answers
- Sale to a French distributor who resells: the distributor is the producer. Give it the packaging weights and materials it needs to declare; put that in the supply contract.
- Dropshipping: the French retailer sells, you ship to its customer from abroad: you are the producer for the packaging that reaches the consumer, because it never passed through a French company.
- Sale to a French business that uses the goods (hotel, factory, office): you are the producer; professional packaging applies from 2027, plus product streams.
What we do
We map your flows customer by customer, confirm in writing which ones make you the producer, and register only those. For the resale flows we provide the packaging data sheet your French customers ask for.
Frequently asked questions
Our French distributor asks us for an IDU. Are they right?
Usually not. If they buy and resell, they are the producer and need their own IDU. They may need your packaging data, not your number.
We dropship for a French Shopify store. Who registers?
You do, for the packaging reaching the consumer. The French store is the producer for the products only if it holds and resells them; in a pure dropship flow it never does.
Can our distributor's IDU cover our direct sales too?
No. Their IDU covers what they place on the market. Your direct sales need your own registration.
Sources
Founder of EPR France Rep, the France-based EPR authorised representative for companies selling into France.
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