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Use case · United Kingdom

We are a UK company selling to France. What does French EPR require?

Since Brexit a UK company is a non-EU producer in France.

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

Since Brexit a UK company is a non-EU producer in France. Every parcel to a French customer makes you liable for household packaging EPR, plus any product stream your goods fall under (textiles, electronics, furniture, toys). Your UK packaging EPR registration has no effect in France. Since 10 July 2026 you must act through a French EPR representative; non-EU producers were never covered by the proposed EU relief, so nothing changes that.

What changed with Brexit and again in 2026

Before 2021 a UK company was an EU producer and could deal with French eco-organismes as any EU business. After Brexit it is a third-country producer. In 2026 two rules landed: the French mandatory representative (10 July) and the EU packaging regulation (12 August), which also requires a representative for producers outside the EU in every member state of sale. Both apply to UK companies without exception.

UK EPR versus French EPR

They are separate systems. UK packaging EPR (the pEPR scheme) covers packaging placed on the UK market and is reported to the UK regulator. French EPR covers packaging and products placed on the French market and is paid to French eco-organismes. Being registered in the UK does not reduce or replace the French obligation.

Typical UK cases

  • Fashion label on Amazon.fr or Zalando: household packaging plus textiles (Refashion), two IDUs.
  • Homeware brand on its own Shopify store shipping DDP: household packaging; furniture stream if you sell furniture, bedding or lighting.
  • Industrial supplier selling to French factories: professional packaging from 1 January 2027, plus electrical equipment where applicable.

What we do

Mandate, eco-organisme memberships, IDUs and declarations in France, with eco-contributions prepaid at cost. You keep your UK registration for the UK.

Frequently asked questions

Does the EU proposal to suspend representatives help UK companies?

No. Every version of the proposal keeps the requirement for producers established outside the EU, and the French national rule applies regardless.

We ship DDU and the French customer pays import VAT. Are we still the producer?

Yes. The producer is the one who first makes the product available on the French market; the Incoterm does not change that for direct-to-consumer sales.

Do we need a French VAT number as well?

EPR and VAT are separate. Distance sales to French consumers usually involve VAT registration or IOSS; EPR requires the eco-organisme memberships and IDUs described here.

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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