compliance teamEPR in France: a practical guide for foreign sellers
Step 1
Map the entity and channel
Step 2
Identify every scheme
Step 3
Appoint and register
Step 4
Declare, display and retain evidence
| Control | Evidence to retain |
|---|---|
| Scope | Entity, product, channel, scheme and source |
| External action | Version, date, authorised filer and issued receipt |
| Maintenance | Source data, approval, invoice and next deadline |
Start with the entity, not the product page
French extended producer responsibility, known locally as REP, attaches to whoever places a product on the French market. Record the selling entity, its country of establishment, the customer, the contract and the route by which goods reach France before anything else.
A marketplace sale, an own-webshop sale, a direct sale to a French business end user and a sale to a French importer or reseller do not produce the same answer. Mixed channels are separated flow by flow rather than averaged into one conclusion.
France has a real register, and it is public
ADEME operates the national register. A producer joins an approved eco-organisation for each scheme concerned; once that membership is validated, ADEME generates a unique identifier and publishes it. A company covered by three schemes therefore holds three identifiers.
That publicity cuts both ways. Anyone, including a marketplace or a competitor, can check whether an entry exists. As checked on 18 August 2026 the open dataset contained 306,657 registrations, of which 211,302 belonged to companies established outside France.
Representation, declaration and marking are three different duties
Since 10 July 2026 a person not established in France that is subject to extended producer responsibility designates, by written mandate, a representative established in France. That is separate from joining an eco-organisation, and separate again from declaring volumes each year between January and the end of February.
Marking is a fourth duty that reaches every seller regardless of volume: sorting information on household packaging, and the unique identifier stated in the sales terms and published on the website.
Conclusion
Scope comes before a form. Connect the legal entity, product, sales channel and EPR stream to the rule that actually applies.
Evidence must remain traceable. Keep source data, versions, approvals, filings, receipts and every record issued by an external body.
Third-party decisions are never guaranteed. Eco-organisations, the public register and marketplaces control their own procedures, timing and decisions.