France packaging EPR for non-EU sellers (Citeo, REP emballages)

If you ship packaged goods to a buyer in France, you appoint a representative in France by written mandate and join one of three eco-organismes: Citeo, Adelphe or Léko. The eco-organisme registers you with ADEME and sends you the IDU for the household packaging scheme. The representative duty has applied since 10 July 2026, and it reaches a seller in another EU country as much as one outside the EU. Under 10,000 consumer sales units a year, Citeo and Adelphe bill a flat EUR 110 excluding VAT.

The EU rule, and who counts as a producer, is in packaging EPR in the EU and PPWR. This page is only what France adds. The other French rules are on the France page.

Do this, in this order

1. Count your packaging in consumer sales units (UVC). Citeo counts the product in its pack as 1 UVC and the shipping carton as another, so a parcel is 2 UVC (Citeo guide). Adelphe’s 2027 guide counts each shipping element on its own: a carton, a tape and a filler are 3 UVC (Adelphe guide).
2. Appoint a representative in France by written mandate. It can be a person or a company established in France (L. 541-10-9-1). Who can act, and for what, is in authorised representative for EPR.
3. Join an eco-organisme from the table below. With Léko, the mandate goes to Léko and the representative signs the membership contract (Léko).
4. Receive the IDU. The eco-organisme registers you in SYDEREP and sends it (ADEME). The IDU is one per scheme: what to enter in each field, and where to show it, is on the IDU page.
5. Declare each year and pay. Citeo’s window is January and February of the following year.
6. Give the IDU to each marketplace, and put the Triman logo and the sorting instructions on the packaging (Triman page).

The representative duty has applied since 10 July 2026

Before that, French law did not require a representative. Article R. 541-174 of the Code, which let a producer designate one who took over its EPR duties, was annulled by the Conseil d’État on 10 November 2023, because no law then provided for that transfer (decision no. 449213). Since the law no. 2026-602 of 8 July 2026, a person not established in France that is subject to EPR appoints one (article L. 541-10-9-1, inserted by article 5, Sénat file). The law was published in the Journal officiel of 9 July 2026. Article 5 gives a later date only to another of its points, 1 September 2026, so this one runs from the day after publication (article 1 of the Civil Code). Léko, one of the three eco-organismes, gives the same date, 10 July 2026.

The representative takes over the EPR duties it accepts in the mandate. In a collective scheme it declares your quantities through the eco-organisme (ADEME). The article names no fee, no licence and no language for the mandate, and no official fee for a representative is set. You do not need one for products whose EPR duties a marketplace established in France already meets.

Léko lists these steps for a producer established abroad: find a representative, sign a written mandate, send it to the eco-organisme to update your membership, have the representative sign the membership contract, and Léko updates SYDEREP. Citeo runs a desk for representatives managing several clients (Citeo).

Three eco-organismes serve household packaging

All three are accredited from 1 January 2025 to 31 December 2029 (ADEME, Ministry). Their tariffs are their own documents, not law, and they change each year.

You may join an approved individual system of your own instead of an eco-organisme (Ministry). In a collective scheme the eco-organisme must cover every category of product you sell, and you may need more than one (ADEME).

What it costs

ADEME states no fee for the IDU itself. You pay the eco-organisme’s contribution, and the minimums are in the table. At Citeo, you get a provisional invoice of EUR 110 when you join. Contributions over EUR 5,000 a year are invoiced in quarterly instalments. Below that, there is one invoice a year, paid in December (Citeo).

Only a detailed declaration earns bonuses and penalties at Citeo. They move the contribution with the design of the packaging: less weight, recycled content, reuse, or features that disturb sorting (ADEME and Citeo guide). The general level of EPR fees is in EPR fees.

Deadlines

At Adelphe, packaging placed on the market in 2027 is declared from January to the end of February 2028 (Adelphe guide). Léko takes the declaration each year on its MyLéko portal, and its tariff sets no date for it (Léko).

Who counts as the producer

Since 1 January 2026 the Code does not define the producer on its own. It points to the EU regulation: a producer is any person as defined in point 15 of article 3 of Regulation (EU) 2025/40 (R. 543-43, decree no. 2025-1081). That is the producer test in packaging EPR. The Code calls packaging of products used by households, or likely to be, household packaging. Any other packaging is professional.

Citeo adds three cases for sellers abroad, which are its own reading, not law (Citeo):

• If you are based abroad and sell second-hand goods in their original packaging to French consumers, you are the first importer of that packaging and you declare it.
• Reused shipping cartons are declared, unless you can trace that they were declared when first placed on the French market.
• Goods sold fully loose, with no packaging at all, are not declared. Labels, ties, string and cling film count as packaging.

Marketplaces

For EPR products in general, a marketplace has producer status for the quantities it places on the market for third parties, unless it holds proof that you hold an IDU (ADEME). Whether Article 45 of the EU packaging regulation changed this rule for packaging is not stated by ADEME or the Ministry. The Ministry’s draft FAQ of 1 August 2022, which the Ministry still marks “en mode projet”, asks you for the IDUs of the product categories you sell, packaging included. It also lets a marketplace act as your EPR intermediary by contract (Ministry draft FAQ). The EU side is in packaging EPR.

The same scheme covers printed paper

The scheme merged household packaging and graphic papers on 1 January 2024. It covers printed paper, other than books, issued for end users in France, free of charge or not (ADEME). Citeo lists user manuals and leaflets among them, and charges nothing for under five tonnes of paper (Citeo). The same membership covers both, and the EUR 110 minimum covers both declarations.

If you do nothing

The minister notifies you of the facts and the penalty, you have one month to answer, and the minister then decides (L. 541-9-5).

All of this is article L. 541-9-5 (Code de l’environnement, copy in Ineris AIDA). A producer that joins no eco-organisme and runs no individual system gets no IDU, so the first row applies to it. The article covers a breach of any rule in its section of the Code, except the Triman and sorting-information duties, which are fined under L. 541-9-4, and the duties of eco-organismes, which are fined under L. 541-9-6. The representative article, L. 541-10-9-1, sits in the same section as L. 541-9-5, so the fines of L. 541-9-5 reach a failure to appoint a representative. No text sets a separate fine for it. The per-unit amount takes into account the gravity of the breach and what the producer gained from it. The sums are also on Service-Public, and the fine for missing Triman and sorting instructions is on the Triman page.

Packaging for business buyers is a separate scheme, in full from 1 January 2027

Catering packaging has had its own professional scheme since March 2024. From 1 January 2027 all professional packaging has one, and each producer concerned must have joined an eco-organisation. Three were accredited on 5 June 2026: Twiice, Léko Pro and Citeo Pro. Household packaging stays in the scheme on this page (ADEME).

What does not apply

• There is no registration of your own in SYDEREP when you join a collective scheme. The eco-organisme does it (ADEME).
• There is no single French EPR number. The packaging IDU does not cover electrical equipment, batteries, textiles or the other streams (IDU page).
• No quantity is too small to join. A low volume means a flat fee, not an exemption.
• A SIRET is not required of a business not established in France. What to enter instead is on the IDU page.