Direct-to-consumer to France? You need an EPR representative.
Shipping from a US, UK or Asian warehouse to French consumers makes you the producer for French EPR purposes. We register you with the relevant eco-organism so your shipments do not get stuck at French customs or trigger administrative action.
Cross-border D2C is a textbook EPR trigger.
Under article L. 541-10 II of the French Environment Code, the producer is whoever places the product on the French market for the first time. For a Shopify brand shipping from outside the EU directly to a French customer, that is the brand.
Unlike the traditional importer chain, where a French distributor takes the producer role, Shopify D2C bypasses any French intermediary. The obligation lands on the seller.
Most cross-border D2C operations need two or three streams.
Packaging
Required for any product sold to French consumers in packaging (boxes, polybags, fillers, bottles, jars).
WEEE
Required for any product with a plug, battery, cable or electronic component sold to French consumers.
Textile
Required for any apparel, linen or footwear product shipped to French consumers.
Furniture
Required for any item of furniture, mattress or bedding shipped to French consumers, plus most home decor.
Batteries
Required for standalone portable batteries, plus rechargeable cells embedded in any device.