Frequently asked questions about French EPR.

The basics

What is an EPR authorized representative in France?

A French legal entity appointed in writing by a non-EU producer to execute its Extended Producer Responsibility obligations. The role is anchored in Article 8a §5 of Directive 2008/98/EC and transposed into the French Environment Code (L. 541-10). The representative registers with the relevant eco-organisms, obtains an Identifiant Unique Producteur (IDU) from ADEME, files periodic declarations, and pays eco-contributions for the producer.

Do I need an authorized representative to sell into France from outside the EU?

Yes, if you place products subject to French EPR on the French market without a French or EU establishment. This applies to packaging, electronics, textile, furniture, batteries, toys, sports, DIY, garden, paper, construction, and professional packaging streams. Marketplaces (Amazon, eBay, ManoMano, Cdiscount) are required by L. 541-10-9 to verify your EPR registration number, and they suspend listings when it is missing.

What is the IDU (Identifiant Unique Producteur)?

A unique producer identifier issued by ADEME through the SYDEREP system after registration with the relevant eco-organisms. Each EPR stream gives you a different IDU. Marketplaces ask for these numbers to keep your listings active.

Is France the same as Germany (LUCID) or Spain?

No. France has more EPR streams than any other EU country (currently 10+) and runs them through several eco-organisms (Citeo, Léko, Ecosystem, Ecologic, Refashion, Ecomaison, Valdelia, Corepile, Screlec, Valobat, Ecominéro, Citeo Pro). A German LUCID number does not cover France. You need a separate French registration per stream.

The mandate, legally

On what legal basis do you act as my representative?

A written mandate, governed by articles 1984 and 1998 of the French Civil Code, and authorized by Article 8a §5 of Directive 2008/98/EC. The mandate is civil, revocable, and limited in scope to French EPR execution. You remain the producer.

Do I lose my producer status when I appoint you?

No. The Conseil d Etat ruling of 10 November 2023 (case 449213, EcoDDS) annulled the subrogation clause that would have transferred producer obligations to the representative. We execute your obligations; we do not absorb them. This is a positive thing: it protects your control over your product data and your relationship with the eco-organisms.

Can I revoke the mandate?

Yes. As any civil mandate, it is revocable at any time, with notice. Practically, we hand over your registration data, your IDU numbers, and the open declarations to your next representative or to your own French entity if you incorporate one.

Are you my legal entity in France?

No. We are a French entity that represents you for EPR purposes only. We do not handle your VAT, your customs, or your corporate filings.

Pricing

How much does it cost?

€490 one-time setup per stream, and €249 per month, per stream. That is our published rate. We do not add per-tonne mark-ups, opaque adders, or eco-organism rebates kept by the representative. Eco-contributions billed by the eco-organism are passed through at cost.

Why is your pricing flat?

Because EPR work for a non-EU seller is mostly administrative: register, declare, pay, repeat. Charging by tonne or by revenue rewards the representative for nothing. A flat fee aligns our incentives with yours.

What if I sell across multiple streams?

Each stream adds €249 per month. A typical Amazon FBA seller with packaging, WEEE, and batteries pays €747 per month. A textile-only Shopify brand pays €249 per month. See the pricing page for common combos.

Are eco-contributions included?

No. Eco-contributions are set by each eco-organism (Citeo, Refashion, etc.) based on your declared volumes, materials, and eco-design criteria. We pass them through at cost on a separate invoice line. We do not mark them up.

Operations

How long does registration take?

After the mandate is signed: typically 2 to 4 weeks per stream to reach an active IDU, depending on the eco-organism workload. We start all streams in parallel.

Do you handle declarations after registration?

Yes. We file periodic declarations (typically annual, sometimes quarterly depending on the eco-organism), pay the eco-contributions, and keep you informed with a short report each cycle.

Can you talk directly to Amazon or other marketplaces?

Yes. We provide your IDU numbers in the format each marketplace requires, and we respond to compliance notices on your behalf, with you in copy.

What if my product mix changes?

Tell us. We update the scope, add the new stream if needed (€490 setup), and keep declarations consistent.

Penalties and risk

What happens if I sell into France without registering?

The French Environment Code (L. 541-9-6) provides administrative penalties up to €30,000 per non-compliant product reference. L. 541-10-9 obliges marketplaces to verify your registration and to deactivate your listings if it is missing. Repeat or aggravated cases can trigger judicial penalties under L. 541-46.

I already received an Amazon suspension notice. Can you help?

Yes. We prioritise files where Amazon has already issued a notice. We register with the relevant eco-organisms, obtain the IDU numbers, and submit them in the format Amazon Seller Central requires.

Do penalties apply retroactively?

In practice, French enforcement focuses on the current sales year. The fastest way to limit exposure is to register now and declare current-year volumes accurately.

PPWR 2026

What changes with the PPWR in August 2026?

Regulation (EU) 2025/40, known as the PPWR, applies from 12 August 2026. Article 45 requires non-EU producers placing packaging on any EU market to appoint an authorized representative in each member state where they sell. France was already requiring this; the PPWR makes it uniform across the EU.

Does the PPWR replace the French system?

No. It harmonises the obligation to appoint a representative for packaging across member states. The French system, its eco-organisms, and its other 9+ streams remain in force.