France · duty in force

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FAQs

French EPR, explained carefully.

Common questions from businesses that are not established in France about French extended producer responsibility, answered with sources and clear limits.

What is EPR in France?

French extended producer responsibility, known locally as REP, allocates the cost and organisation of waste management to the producer of a product placed on the French market. In practice a producer joins an approved eco-organisation for each scheme concerned, receives a unique identifier through the public ADEME register, declares its volumes and pays the eco-contribution set by that eco-organisation.

Who is responsible when a foreign seller supplies France?

The answer depends on the entity, its establishment, the customer and the route. A seller shipping to French consumers through a marketplace, a seller shipping from its own webshop, a direct sale to a French business end user and a sale to a French importer or reseller do not give the same answer. Mixed channels require a flow-by-flow review.

Is a representative established in France mandatory?

Article L. 541-10-9-1 of the Code de l'environnement, created by law no. 2026-602 of 8 July 2026 and in force since 10 July 2026, provides that a person not established in France that is subject to extended producer responsibility designates, by written mandate, a natural or legal person established in France as its representative, and that this representative is subrogated in the obligations whose mandate it accepts. The trigger is establishment in France, not nationality, so an EU company without a French establishment is covered on the same wording as a non-EU company.

Is there an exception when a marketplace handles compliance?

The same article states that the appointment duty is treated as satisfied for products for which a person covered by article L. 541-10-9 established in France ensures compliance with the extended-producer-responsibility obligations. That is product-specific and evidence-specific: it does not extend to your own webshop, it does not create a register entry in your name, and a fee or a payment service is not by itself such a statement.

What is the unique identifier (IDU)?

It is the registration number issued by ADEME once an eco-organisation transmits a validated membership, and it is published on the public register. A producer holds one identifier per scheme concerned, so a company covered by three schemes holds three identifiers. eprfrance.com does not issue identifiers and cannot commit ADEME or an eco-organisation to a timing.

Where must the unique identifier appear?

Article R. 541-173 requires the producer to state it in its general conditions of sale, or in another contractual document given to the buyer, and to publish it on its website under the same conditions as the legally required online mentions. Marketplaces separately ask for it in their own compliance fields, which is a platform requirement rather than the legal basis.

Which eco-organisation should we join?

For household packaging and papers several eco-organisations are approved, including Citeo, Adelphe and Léko, and their published scales differ. Other schemes have their own approved organisations. Comparing them is part of our work; the choice belongs to the client, and we hold no mandate, commission or affiliation from any of them.

How is the household packaging contribution calculated?

The published French scales are built per consumer sales unit and by product family, with a separate amount when shipment packaging is used, rather than by kilogram alone. Larger volumes move to a detailed declaration by material and weight. Eco-modulation bonuses and penalties then apply on published criteria.

Can a small seller owe almost nothing?

The published 2026 Léko scale caps the simplified declaration amount at €150 excluding VAT below 20,000 consumer sales units a year and sets a minimum annual billing amount of €95 excluding VAT. Those figures belong to that scale and that eco-organisation, they can change, and another eco-organisation publishes different terms. A calculator result is an estimate, not a decision.

When are French declarations filed?

Household packaging and papers are declared once a year, for the previous calendar year, in a window that opens on 1 January and closes at the end of February. Under the published Léko terms an annual contribution of €10,000 or less is invoiced annually by 31 March and larger amounts are invoiced quarterly. The eco-organisation actually joined confirms the portal and the exact deadline.

Do we need a French VAT number or a SIRET?

ADEME describes a SIRET for French companies and a VAT number for EU and foreign companies among the registration information. We do not sell or promise a French tax identifier, and any additional administrative step is disclosed in the written scope rather than promised on this page.

Are a notary or an apostille required?

The route is prepared around a written mandate, company evidence and identity documents rather than a notarised or apostilled instrument. The final document list and signing method are confirmed before filing; this page does not override a request made by an eco-organisation or an authority.

What role can eprfrance.com perform?

A separately contracted service may act as the representative established in France under a written mandate whose perimeter is stated stream by stream, coordinate eco-organisation membership, follow the unique identifier, prepare annual declarations and keep the evidence. It is not an eco-organisation, holds no State approval, is not a fiscal representative and claims no affiliation with ADEME, Citeo, Adelphe, Léko, Refashion or Amazon.

Who pays the eco-contribution?

The eco-organisation sets it on its published scale and invoices it. Our private service fee is separate and includes no percentage of the contribution. Where a mandate is in place, the payment route is written into that mandate rather than assumed.

What are the penalties?

Article L. 541-9-5 provides for a contradictory procedure, then an administrative fine capped at €1,500 per unit or per tonne of product for a natural person and €7,500 for a legal person, a daily penalty payment of up to €20,000, and a separate fine of up to €30,000 where a person is not registered, has not completed the register, has supplied incorrect data or has not displayed the unique identifier. Sorting-information breaches follow their own penalty article. We describe these amounts; we do not predict whether an authority will apply them.

What sorting information must appear on the packaging?

Products under extended producer responsibility that are intended for households carry consumer sorting signage under decree no. 2021-835 of 29 June 2021. Small-surface packaging has defined cases where the information can be provided in dematerialised form. The applicable combination for a given pack is a measurement and format question answered in a review.

Do electrical equipment, batteries and textiles use the packaging identifier?

No. Each scheme has its own approved eco-organisations and its own identifier. A textile, furniture, toy, battery or electrical-equipment obligation is never satisfied by a packaging registration.

Does Amazon pay-on-behalf replace our own compliance file?

Do not infer that from a marketplace label. Paying a contribution through a platform does not produce a register entry or an identifier in your name, does not cover sales made outside that platform and does not answer the marking duties. The exact scope, fee and evidence effect must be checked in the live seller account and in the current official terms.

What about periods before we registered?

Past periods are a separate question from a mandate signed today. Some schemes require declaration of previous years on joining. The treatment of history is reviewed on the facts and agreed in writing rather than absorbed silently.

Can eprfrance.com guarantee an identifier, a timing or marketplace acceptance?

No. We can scope, prepare and coordinate the private work described in a written proposal. Eco-organisations, ADEME and marketplaces control their own processing, records, timing and decisions.

Where these answers come from. The answers draw on the Code de l’environnement, ADEME register documentation, published eco-organisation scales and applicable EU regulations. They are general information, not legal advice or a third-party decision. Last reviewed: 18 August 2026.