Selling to France from the USA: EPR, VAT and labelling rules for non-EU sellers

The short answer

A seller not established in France appoints a representative in France for every EPR stream, and ADEME issues one IDU per stream. Triman and sorting instructions go on the product, and labels and manuals are in French. A non-EU business that owes French VAT needs an accredited fiscal representative, unless its country is on France's mutual-assistance list. The DGCCRF enforces product safety and the use of French.

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Country
France

National rules in France

RuleLocal nameBodyApplies to you when
VAT registration with no French establishmentSIEE, or your representative's SIEDGFiP: the Service des impôts des entreprises étrangères, or the Service des impôts des entreprises of your fiscal representativeYou owe French VAT and have no establishment in France: the SIEE if you are established in the EU or a state on the arrêté of 15 May 2013 (UK yes, US no); otherwise the SIE of your fiscal representative.
Fiscal representative for a non-EU businessReprésentant fiscalA French-established, VAT-registered representative, accredited by its tax officeYou are established outside the EU and owe French VAT or must file there, unless your state is on the mutual-assistance list of the arrêté of 15 May 2013.
Marketplace dutiesIDUThe marketplace, as EPR producer, outside packagingYou sell through a marketplace and hold no IDU for a stream other than packaging: the marketplace then counts as the producer for your quantities.
Packaging EPRREP emballages ménagers (stream EMPAP)ADEME; eco-organismes Citeo, Adelphe, LekoYou put goods in household packaging on the French market.
Representative established in France, in every EPR streamMandataire (L. 541-10-9-1)The person you appoint by written mandateYou are subject to EPR in any stream and are not established in France.
Sorting markTriman and sorting instructions (Info-tri)Logo fixed by decree (R. 541-12-17); sorting instruction from your eco-organisme, accepted by the environment and consumer ministers (R. 541-12-18)A product or package subject to EPR is placed on the French market for households. Household glass drinks packaging is exempt.
WEEEStream EEE (DEEE)ADEME; eco-organismes ecosystem, Ecologic, SorenYou sell electrical or electronic equipment in France.
BatteriesStream BATADEME; Batribox, ecosystem, Recycler Mon VéhiculeYou sell batteries in France.
Textiles EPRStream TLCADEME; the eco-organisme RefashionYou sell new clothing, footwear or household textiles to French consumers.
Furniture EPRStream EA (éléments d'ameublement)ADEME; Ecomaison, Valdelia, ValobatYou sell furniture, upholstered seating or bedding, or textile decoration in France.
Other EPR streamsFilières REP (AGEC law)ADEME and the environment ministryYour goods fall in one of the 21 EPR streams, such as toys, sports and leisure goods, DIY and garden goods or tyres.
Product-safety enforcerDGCCRFDGCCRFYou sell consumer products in France: the DGCCRF is the control authority under the GPSR.
Product-safety penaltyCode de la consommation L. 452-5-1You are a manufacturer or importer that fails to carry out the GPSR measures of art. 9(8) or 11(8) (corrective action, informing consumers, notifying the authorities), or a marketplace that breaches GPSR art. 22(12).
Language of labels and manualsLoi ToubonDGCCRFYou sell a good in France: its designation, offer, instructions and guarantee terms are in French, online sales included.
Website legal noticeMentions légales (LCEN)The sources address businesses established in France: a professional website shows identity, contacts, host and registration numbers. None says whether this reaches a seller established outside France.

The same as the rest of the EU:

What does not apply in France

  • There is no single French EPR number. The IDU is issued per scheme, so a seller in three streams holds three IDUs.
  • You do not register yourself in SYDEREP when you join a collective scheme. The organisation you join registers you and sends the IDU.
  • A French SIRET is not required of a company that is not established in France. ADEME accepts an intra-Community VAT number or, failing that, the identification numbers of article R. 123-221 of the Commercial Code, or for a non-resident company the registration number its tax authority issued in its own country.
  • The one-off fiscal representative (représentation fiscale ponctuelle) no longer exists. The finance law for 2024 repealed it. The tax administration tolerated it until 31 December 2025, and after that date only for operators that had started their French VAT registration before it, until they obtained their French VAT number.
  • The EUR 600,000 fine is not a general product-safety penalty. It covers failure to carry out the GPSR measures of art. 9(8) or 11(8) (corrective action, informing consumers, notifying the authorities) and, for marketplaces, a breach of art. 22(12).

France applies the EU rules and adds its own on top. The table above lists each national rule with its local name and the body that runs it. The EU rule behind each row stays in the EU guide the row links to.

The representative duty reaches every EPR stream

A seller not established in France appoints a representative established in France for every EPR stream it is subject to: packaging, electrical equipment, batteries, textiles, furniture and the rest. The duty is in article L. 541-10-9-1 of the Code de l’environnement, added by loi no. 2026-602 of 8 July 2026 (law file at the Sénat). It binds a seller from any country, EU included. The representative takes over every EPR duty named in the written mandate. The appointment is treated as made where an operator established in France, named in article L. 541-10-9, already meets the EPR duties for those products. The mandate and the representative’s role are on France packaging EPR; the EU rule is in authorised representative for EPR.

One IDU per stream, issued by ADEME

ADEME issues the IDU once you are registered in SYDEREP. A collective scheme registers you and sends it. You give the IDU to marketplaces and buyers who ask, and a producer with a website shows it there, in the same place as the notices of article 19 of the law of 21 June 2004. Without an IDU, you face an administrative fine of up to EUR 30,000, on top of up to EUR 7,500 per unit or tonne (L. 541-9-5, copy in Ineris AIDA). For the streams other than packaging, a marketplace also counts as the producer for your quantities unless it holds proof of your IDU. For packaging, no source read dates after 12 August 2026, when the EU packaging regulation began to apply, so this page does not state that rule. What each form field asks is on EPR registration number in France; what an EPR number is, in every country, is in EPR number in the EU. The five main streams and their eco-organismes are in the table above. Service-Public counts 21 streams in all, and the EU rule for each is in the EPR guide. The streams have pages of their own. Packaging is on France packaging EPR, electrical equipment on WEEE in France, and batteries on France battery EPR. Textiles are on textile EPR in France, furniture on France furniture EPR, and the rest on AGEC law and the other EPR streams.

Triman and sorting instructions go on the product or its packaging

A product subject to EPR and placed on the market for households carries the Triman logo (household glass drinks packaging is exempt, L. 541-9-3, copy in Ineris AIDA), or another sorting sign that EU or member-state law makes compulsory (the crossed-out bin on electrical equipment is one). The sorting instructions sit beside it, on the product or its packaging (Service-Public). Household packaging carries them on the packaging itself, or on a sticker on it (R. 541-12-21, copy in Ineris AIDA). The rule in full, with the deadlines and the small-product exceptions, is on Triman logo in France. The EU marks are in packaging recycling symbols.

VAT: an accredited fiscal representative

A business established outside the EU that owes French VAT appoints one accredited fiscal representative in France, unless its country has a mutual-assistance instrument with France, listed in the arrêté of 15 May 2013 (BOFiP). Its VAT number comes from the tax office (SIE) of its representative; a business on that list deals with the SIEE at Noisy-le-Grand. Without a representative, French law makes your customer liable for the VAT and penalties too, but you remain the taxpayer the tax office assesses. Other narrow routes exist: the mandataire à l’international for imports and exports, and IOSS through an intermediary. The French side is on France VAT registration. The EU side, including those routes, is in fiscal representative and EU VAT for online sellers.

Parcels of EUR 150 or less: no French small parcel tax since 1 July 2026

France taxed each item in a consignment under EUR 150 declared in the simplified H7 declaration at EUR 2 from 1 March 2026. French customs states that the tax was repealed on 1 July 2026, when the EU’s flat EUR 3 customs duty began, so a parcel imported from that date pays EU customs duty and import VAT, and no French tax, so there is none to pass on to a French buyer (French customs, 8 July 2026). The Ministry of the Economy announced it on 30 June 2026 as a suspension (press release no. 850). A consignment worth more than EUR 150 pays the ordinary tariff duty and import VAT instead of the EUR 3. Who owes the EUR 3, how it is counted per item and what changes for IOSS are on the EUR 3 customs duty.

French on the product, and the DGCCRF

French is compulsory on the designation, offer, instructions and guarantee terms of goods sold in France, online too (Ministry of Culture). The DGCCRF checks it, and is also the control authority for product safety under the GPSR. For a failure to carry out the GPSR measures of art. 9(8) or 11(8) (corrective action, informing consumers, notifying the authorities), an individual faces up to five years in prison and EUR 600,000. A company faces up to five times that fine (Ministry of Justice, Code pénal art. 131-38). The fine may rise, in proportion to the gain from the offence, to 10% of average annual turnover (L. 452-5-1). The French duty does not apply to documents such as invoices exchanged between professionals; invoices and receipts to consumers are in French. What France adds to the GPSR is on France product safety. The EU rules are in GPSR and GPSR fines. The EU rule on manuals is in user manual requirements.

A professional website run by a business established in France shows its identity, contacts, host and registration numbers, and missing notices carry up to one year in prison and EUR 75,000 for a sole trader or EUR 375,000 for a company (Ministry of the Economy). The sources address businesses established in France. None says whether the duty reaches a seller established outside France.

The facts for France, with their sources

FactValueSourceChecked
Local representativeYes, in every EPR stream. A person not established in France that is subject to EPR appoints, by written mandate, a person established in France as representative. The representative takes over every EPR duty named in the mandate. The duty counts as met for products whose EPR duties an operator established in France, named in L. 541-10-9, already fulfils.Sénat, text no. 150 (2025-2026), adopted definitively on 29 June 2026: Code de l'environnement art. L. 541-10-9-1, inserted by art. 5, 2°
Registration authorityADEME issues the unique identifier (IDU), one per EPR scheme, once you are registered in its declaration tool. In a collective scheme the producer responsibility organisation you join does the registration and sends you the IDU.ADEME, Filières REP: unique identification numbers (UIN) in EPR schemes
RegisterSYDEREP, the declaration tool for EPR schemes run by ADEME.ADEME, Filières REP: unique identification numbers (UIN) in EPR schemes
Registration authorityVAT with no establishment in France: a business established in the EU or in a state on the arrêté of 15 May 2013 deals with the Service des impôts des entreprises étrangères (SIEE), Direction des impôts des non-résidents, Noisy-le-Grand. Any other non-EU business deals with the Service des impôts des entreprises (SIE) its fiscal representative already files with, which issues its VAT number.impots.gouv.fr: registering for VAT (immatriculation à la TVA), page modified 3 March 2025
Local representativeVAT: a business established outside the EU that owes French VAT or must file returns has a VAT-registered fiscal representative established in France accredited, who does its formalities and pays the tax for it. Only one representative is allowed. Exempt: a business established in a non-EU state with which France has a mutual-assistance instrument, listed in the arrêté of 15 May 2013. Without a representative, French law makes the customer liable for the VAT and penalties too, but the business stays the taxpayer the tax office assesses.BOFiP-Impôts, BOI-TVA-DECLA-20-30-40-10 (11 February 2026): the fiscal representative, CGI art. 289 A
Enforcement bodyThe DGCCRF (Direction générale de la concurrence, de la consommation et de la répression des fraudes) is the control authority for general product safety under Regulation (EU) 2023/988.DGCCRF: product safety, what changes in 2025
PenaltyEPR (L. 541-9-5): up to EUR 1,500 (individual) or EUR 7,500 (company) per unit or tonne, and a daily penalty of up to EUR 20,000. On top, up to EUR 30,000 where the producer is not registered in SYDEREP, has not filled it in, gave wrong data, or does not show its IDU. Missing Triman and sorting instructions: up to EUR 3,000 (individual) or EUR 15,000 (company) (L. 541-9-4).Code de l'environnement, arts. L. 541-9-4 and L. 541-9-5 (copy in Ineris AIDA, Livre V, partie législative)
PenaltyProduct safety: a manufacturer or importer that fails to carry out the measures of Regulation (EU) 2023/988 art. 9(8) or 11(8) (corrective action, informing consumers, notifying the authorities), or a marketplace that breaches art. 22(12), faces up to five years in prison and EUR 600,000 for an individual (Code de la consommation L. 452-5-1). A company faces up to five times that fine (Code pénal art. 131-38). The fine may rise, in proportion to the gain, to 10% of average annual turnover over the last three known years.Sénat, legislative history table of bill no. 112 (2023-2024), adopted as the law of 22 April 2024: art. L. 452-5-1
National ruleFrench is compulsory in the designation, offer, presentation, instructions for use, and guarantee terms of a good, and in invoices and receipts to consumers (loi no. 94-665 of 4 August 1994, art. 2). It applies to imported goods and to goods offered on online sites and platforms. The DGCCRF checks it.Ministry of Culture (DGLFLF): guaranteeing the use of French
National ruleThe French version must be as understandable as the original, without a word-for-word translation. Some foreign inscriptions are allowed, such as engraved or moulded ones and common terms. The duty does not apply to documents, such as invoices, exchanged between professionals who are not consumers or end users.DGCCRF practical sheet: the use of the French language (12 October 2020)
National ruleFor the EPR streams other than packaging, a marketplace is the producer, for EPR, for the quantities it places on the market for third parties, unless it holds proof that those sellers already hold an IDU for the scheme. For packaging, no source read dates after 12 August 2026, when the EU packaging regulation began to apply, so this page does not state the rule for packaging.ADEME, Filières REP: unique identification numbers (UIN) in EPR schemes
National ruleThe sources address businesses established in France. A professional website run by such a business shows its legal notices (mentions légales): identity, address, e-mail and phone, the host, and for a commercial activity the RCS/RNE number and the intra-EU VAT number, plus general terms of sale for a selling site. No source read says whether this duty reaches a seller established outside France. Missing notices: up to one year in prison and EUR 75,000 (sole trader) or EUR 375,000 (company).Ministry of the Economy: notices your website must show

Sources

  1. Official source, opened 5 October 2026Sénat, legislative history table of the law to reduce the environmental impact of the textile industry: loi no. 2026-602 of 8 July 2026, promulgated text
  2. Official source, opened 5 October 2026Sénat, legislative file of the same law, published in the Journal officiel of 9 July 2026
  3. Official source, opened 5 October 2026Code de l'environnement, Livre V, partie législative: arts. L. 541-9-4 and L. 541-9-5 (copy in Ineris AIDA)
  4. Official source, opened 5 October 2026impots.gouv.fr: which tax office manages my business, with or without a French establishment (the SIEE address at Noisy-le-Grand; page updated 18 July 2023)
  5. Official source, opened 5 October 2026Code de l'environnement, Livre V, titre IV, chapitre I, partie réglementaire: art. R. 541-12-21 (copy in Ineris AIDA)
  6. Official source, opened 5 October 2026Ministry of Culture: legal resources on the French language, loi no. 94-665 of 4 August 1994 (loi Toubon)
  7. Official source, opened 5 October 2026Ministry of Justice, Infostat Justice 82: the criminal liability of legal persons (fine five times the fine for a natural person, Code pénal art. 131-38 and 131-41)
  8. Official source, opened 5 October 2026Regulation (EU) 2025/40 on packaging and packaging waste, final article: applies from 12 August 2026
  9. Official source, opened 5 October 2026ADEME, Filières REP: household packaging and graphic papers scheme (EMPAP)
  10. Official source, opened 5 October 2026ADEME, Filières REP: electrical and electronic equipment scheme (EEE)
  11. Official source, opened 5 October 2026ADEME, Filières REP: batteries scheme (BAT)
  12. Official source, opened 5 October 2026ADEME, Filières REP: textiles, clothing and footwear scheme (TLC)
  13. Official source, opened 5 October 2026ADEME, Filières REP: furnishing elements scheme (EA)
  14. Official source, opened 5 October 2026impots.gouv.fr: the one-stop shop for VAT (OSS-IOSS)
  15. Official source, opened 5 October 2026Service-Public Entreprendre: mandatory notices on a sole trader's website
  16. Official source, opened 5 October 2026CNIL, Commission nationale de l'informatique et des libertés
  17. Official source, opened 5 October 2026French customs (DGDDI): small parcel tax, information on its implementation (8 July 2026): the tax of article 82 of loi no. 2026-103 is repealed on 1 July 2026
  18. Official source, opened 5 October 2026Ministry of the Economy, press release no. 850 (30 June 2026): France will suspend its national small parcel tax on 1 July
  19. Official source, opened 5 October 2026Sénat, text no. 150 (2025-2026), adopted definitively on 29 June 2026: Code de l'environnement art. L. 541-10-9-1, inserted by art. 5, 2°
  20. Official source, opened 5 October 2026ADEME, Filières REP: unique identification numbers (UIN) in EPR schemes
  21. Official source, opened 5 October 2026impots.gouv.fr: registering for VAT (immatriculation à la TVA), page modified 3 March 2025
  22. Official source, opened 5 October 2026BOFiP-Impôts, BOI-TVA-DECLA-20-30-40-10 (11 February 2026): the fiscal representative, CGI art. 289 A
  23. Official source, opened 5 October 2026DGCCRF: product safety, what changes in 2025
  24. Official source, opened 5 October 2026Sénat, legislative history table of bill no. 112 (2023-2024), adopted as the law of 22 April 2024: art. L. 452-5-1
  25. Official source, opened 5 October 2026Ministry of Culture (DGLFLF): guaranteeing the use of French
  26. Official source, opened 5 October 2026DGCCRF practical sheet: the use of the French language (12 October 2020)
  27. Official source, opened 5 October 2026Ministry of the Economy: notices your website must show