France — packaging EPR

What changed in July

The legal basis is Art. L. 541-10-9-1 of the Code de l'environnement, created by Law n° 2026-602 of 8 July 2026 and in force from 10 July. If you are reading a French compliance guide that does not mention that law, it predates the change — and most of them do, because the provision arrived inside a bill primarily about fast fashion and textiles rather than in anything labelled "packaging".

The timing matters for a second reason. France moved a month before Art. 45(3) PPWR made representatives compulsory across the Union on 12 August. So there was a window in July where France required something the rest of the EU did not, and a French obligation now sits alongside the EU one rather than being derived from it. Where the two differ, the French text is broader — see below.

Does it apply to me?

French packaging EPR attaches from the first household package placed on the French market. There is no turnover floor, no weight floor and no general small-business exemption to fall under. If a French consumer orders from you and a parcel crosses the border, you are a producer in France.

You ship to French consumers, no French establishment

Yes. Appoint a mandataire, join an approved scheme, get an IDU, declare annually and apply the sorting marks.

You're established elsewhere in the EU

Caught. Art. L. 541-10-9-1 says "not established in France", which includes producers established in another member state.

You're established outside the EU

Also caught, and expressly so. France did not wait to see whether it would exercise the third-country option in Art. 45(3) PPWR — its own law covers you either way.

You're established in France

No mandataire needed. You join a scheme and declare in the normal way.

You run a marketplace, and you're not French

You need one too. This is unusual and worth flagging: the French duty reaches non-established online marketplaces facilitating distance sales, not just the sellers on them.

You sell only B2B into France

Different stream. Household packaging and professional packaging have separate schemes and separate rules — see B2B is a separate stream.

The mandataire

France's representative is a stronger creature than Germany's or Austria's. The statutory word is subrogé: the mandataire is subrogated to the producer's obligations, meaning the EPR liability transfers to them rather than merely being administered by them.

Legal basis

Art. L. 541-10-9-1 Code de l'environnement, created by Law n° 2026-602 of 8 July 2026.

In force since

10 July 2026. No transition period was provided.

Who can be one

A natural or legal person established in France, appointed by written mandate.

Which streams it covers

All of them. The article is not packaging-specific — it applies across every French EPR stream you happen to be caught by. If you also sell textiles, furniture, electricals or toys into France, the same appointment logic reaches those.

What they actually do

Sign the scheme membership contract, handle your registration and data in SYDEREP, make the declarations, pay the eco-contribution, and deal with ADEME. In practice the scheme membership is signed by the mandataire rather than by you.

Does it remove your exposure?

Legally the obligations are subrogated to the mandataire, which is a stronger transfer than the German or Austrian model. We would still not treat that as an indemnity — we have not seen this tested, the law is weeks old, and your contract with the provider is a separate question from the statute.

Registration and the IDU — the mirror image of Germany

Germany makes registration a strictly personal duty that nobody may perform for you. France does the opposite: in the normal collective route you never touch the register yourself. This is the Art. 44(3) PPWR option in action — member states may allow registration to be met under a written mandate, and France allows it.

Publishing your IDU — the bit that catches everyone

This has no German or Austrian equivalent and it is the single most missed French obligation. Having the number is not enough. You have to display it.

Legal basis

Art. R. 541-173 Code de l'environnement.

Where it goes

In your contractual information — general terms and conditions — and on your website.

Why people miss it

Because every other country's registration number is something you hold and quote on request. France's is something you publish. A shop can be perfectly registered, paid up and declared, and still be in breach because the number isn't on the site.

What it costs to get wrong

Failing to include the unique identifier where required is one of the things expressly sanctioned under Art. L. 541-9-5 — up to €30,000. See below.

The three schemes

Three producer responsibility organisations are approved for household packaging and graphic papers for the 2025–2029 accreditation period. You join one. They compete, and their minimum charges differ enough to matter at small volumes.

Citeo

The largest. Publishes the €80 flat-rate route for small producers.

Adelphe

Part of the Citeo group; historically wine and spirits, open more broadly.

Léko

The independent alternative, and the one that has published the clearest guidance for foreign producers on the mandataire rules.

What it costs

These are published 2026 list prices, not quotes we have negotiated, and not a recommendation. Mandataire fees are separate from all of them and are the line we expect to vary most.

Reporting

You declare to your scheme, and the scheme reports onward to ADEME and SYDEREP. You do not file with the register directly.

Rhythm

Annual, for the preceding calendar year.

Deadline

Household packaging declarations are due to the scheme by 28 February. Confirm the exact date and format with your own scheme — it is contractual, and it moves.

On the flat rate

The declaration is dramatically simplified, but it is not abolished. You still confirm annually that you are under the threshold, and you still keep the records that prove it.

Under 10 tonnes

Art. 44(8) PPWR gives producers under 10 tonnes a year a reduced EU reporting set. It sits alongside the French route rather than replacing it, and everyone reading this page is under it.

Triman and Info-tri — France really does make you print something

This is the other place France differs sharply from Germany and Austria. Neither of those requires a sorting mark on ordinary shipping packaging. France does, and has since 1 January 2022 — long before the PPWR.

What it is

The Triman logo together with Info-tri sorting instructions, telling the customer how to separate each component of the packaging.

Who it applies to

All household packaging and graphic papers placed on the French market. It follows the destination, not your establishment — a foreign distance seller is caught.

Very small surfaces

Derogations exist by size. Where the largest face is under 10 cm² the signage may be provided digitally instead. Between 10 and 20 cm² the Triman must appear but the sorting instructions may be dematerialised.

Where to get the artwork

From your scheme. Do not redraw it — the layout, wording and language are prescribed, and the schemes publish approved files.

B2B is a separate stream, and it is moving

Everything above is emballages ménagers — household packaging, which is what a distance seller shipping to consumers produces. France runs professional packaging as its own REP stream with its own scheme arrangements and its own scale, and that stream has been coming into full application through 2026.

If you sell B2B into France as well as B2C, treat it as a second question with a second answer. This desk does not cover it, and we would rather say so than imply the household answer travels.

What happens if you don't

The core sanction is administrative, imposed by the environment minister with ADEME operating the register side.

GPSR is a separate problem

Packaging EPR and product safety are different regimes with different representatives. The General Product Safety Regulation requires an EU-based Responsible Person for consumer products, with no exemption for small sellers. Your French mandataire is not automatically your GPSR Responsible Person, and your scheme certainly isn't. France is the country where this confusion is most likely, because the same providers often sell both — check what is actually in the mandate you sign.

"It's been suspended"

You will be told this, usually by someone selling you something, and it is worth answering once.

Until something is adopted and enters into force, Art. 45(3) applies as written, and it has applied since 12 August 2026. We think the proposal is worth watching and worth arguing about — see our note on it — and we do not think it is worth planning around.

Known traps

Sources

Primary law first, then the official register and ministry, then the schemes, then secondary summaries. Where a claim on this page rests only on a secondary source, we have said so in the body text rather than leaving it to a footnote.

1. Art. L. 541-10-9-1 Code de l'environnement — Légifrance The mandataire obligation, as in force from 10 July 2026. Created by Law n° 2026-602 of 8 July 2026, published in the Journal officiel on 9 July
2. Art. L. 541-9-5 Code de l'environnement — Légifrance Source for the €30,000 administrative fine, the €20,000-a-day astreinte, the mise en demeure procedure and the ten-day window for observations
3. ADEME — the identifiant unique (IDU) Official. What the IDU is, that it is issued through SYDEREP, and that each REP stream generates its own separate identifier
4. ADEME — public list of producers registered in SYDEREP The open dataset of registered producers and their IDUs. Where you check that a provider actually registered you
5. Citeo — declaring your packaging Scheme source for the annual declaration route and the 28 February deadline
6. Citeo — the simplified declaration Scheme source for the €80 flat rate below 10,000 UVC and the simplified declaration route for small producers
7. Citeo — Info-tri Scheme source for the Triman and Info-tri signage requirements and the approved artwork
8. Léko — the obligation to designate a mandataire Scheme source, and the clearest published explanation of the July 2026 change. Source for the absence of a transition period, the coverage of non-established marketplaces, and the subrogation of obligations to the mandataire. Léko is one of the three approved schemes — useful, but not a neutral source
9. Regulation (EU) 2025/40 (PPWR) — EUR-Lex Read in full, 14 August 2026. Source for Art. 44(3) on delegated registration, Art. 44(8) on the 10-tonne reporting threshold, Art. 45(3) on the EU representative duty, Art. 12(1) on the 2028 harmonised label and Art. 62 on formal non-compliance
10. European Commission — PPWR Frequently Asked Questions, 2nd edition DG ENV Unit B01, August 2026 (KH-01-26-068-EN-N). Read in full. Source for the enforcement approach from 12 August
11. European Commission — PPWR guidance (Commission Notice), 30 March 2026 The guidance document, distinct from the FAQ above. Not read in full by us

Help us finish this desk

This draft was assembled on 14 August 2026 from official French sources and from a contributed country profile, and it has not been checked by anyone who has actually been through the French process. It has no keeper. If you ship to France, you can improve it faster than we can.

Three things we specifically don't know. What a mandataire costs — no provider publishes it, and the obligation is six weeks old. Whether the €80 Citeo route is genuinely available to a foreign producer going through a mandataire, or whether it is priced differently in practice. And what the free-rider sanction actually is — we have a figure we could not pin to an article, and we have said so above rather than publish it as fact.