A written mandate with a scope you can read,
not an open-ended promise.
Since 10 July 2026, French law requires a person not established in France that is subject to extended producer responsibility to designate, by written mandate, a representative established in France. The representative is subrogated in the obligations it accepts, so the scope of that acceptance is the whole subject of the contract.
Indicative private-service pricing: Standard €474/year + €150 setup for the first stream · €149/year per additional stream · eco-contributions and other third-party costs excluded
✓ Free ✓ Human review ✓ No commitment
Timing depends on document completeness and independent registry and scheme review
The outcome
One written mandate whose perimeter is explicit
- Streams accepted, and streams deliberately excluded, listed by name
- Start date, duration, renewal and termination route recorded
- Data responsibilities, filing responsibilities and periods outside the mandate separated
The mandate is a private contract; the register entry and the unique identifier are issued by ADEME through the eco-organisation
The duty and the subrogation are set by statute, not by a service provider
Article L. 541-10-9-1, created by law no. 2026-602 of 8 July 2026 and in force since 10 July 2026, requires the written designation of a representative established in France and states that this representative is subrogated in the extended-producer-responsibility obligations whose mandate it accepts. The same article treats the appointment duty as satisfied for products whose obligations are ensured by a person covered by article L. 541-10-9 established in France, which is a per-product question of evidence rather than a general exemption.
Primary sources · Reviewed 18 August 2026
Where a representative arrangement goes wrong
The mandate has no perimeter
Subrogation follows what the representative accepts. A mandate that does not name the streams creates uncertainty for both sides.
Past periods are assumed to be covered
A mandate signed today does not retroactively absorb undeclared previous years. Regularising history is separate work with a separate decision.
A marketplace service is treated as the appointment
A platform fee or a payment service is not the same as a written statement that a France-established platform ensures the obligations for those products.
Included in the written scope.
- Establishment, entity and product-scope review
- Stream-by-stream mandate perimeter, in writing
- Coordination with the eco-organisation joined for each stream
- Point of contact for the eco-organisation and the register
- Change, renewal and termination handling
- Evidence register kept per stream and per period
Four controlled steps.
Document the facts
Collect the entity, products, channels, contracts and available evidence for the representative mandate.
Confirm scope and dependencies
Receive a written map of assumptions, exclusions, third parties and points requiring approval.
Authorise the agreed work
Private fees, external costs and client responsibilities are confirmed before any submission or commitment.
Coordinate and retain evidence
After a valid engagement, each action, external decision and authentic receipt is stored with its date and version.
Frequently asked
Does the duty apply to EU companies too?
The trigger written in the article is establishment in France, not nationality or EU membership. A company established elsewhere in the EU is covered on the same wording as a company established outside the EU.
What does subrogation actually transfer?
The article states that the representative is subrogated in the obligations arising from extended producer responsibility whose mandate it accepts. What is accepted is defined in the written mandate, which is why the perimeter is drafted before signature rather than after.
Does this make you responsible for our data?
No. The volumes, materials and product information remain the producer's responsibility. The mandate says so explicitly, because a declaration can only be as accurate as the data behind it.
Is a notary or an apostille required?
The route is prepared around a written mandate, company evidence and identity documents. The final document list is confirmed before filing and this page does not override a request made by an eco-organisation or an authority.
Discuss the facts with the team.
Independent private service · human scope review · no third-party outcome promised.
✓ Free ✓ Human review ✓ No commitment