EPR Authorized Representative in France: What EU and Non-EU Sellers Must Know in 2026

Stricter enforcement in 2026: what has changed

French authorities have significantly intensified EPR enforcement since 2024. The DGPR (Direction Générale de la Prévention des Risques) now cross-references the SYDEREP producer registry with customs import data and marketplace sales records to identify non-compliant sellers. The Senate voted a contribution d'office mechanism in December 2025, allowing authorities to issue payment orders directly to marketplaces for non-compliant sellers.

Amazon.fr, ManoMano, and Cdiscount have tightened their verification processes. IDU numbers are checked against the ADEME SYDEREP database periodically, not just at registration. An IDU that expires due to non-payment of eco-contributions is detected automatically, triggering a new suspension process.

For foreign sellers, this means that operating in France without proper EPR representation is no longer a theoretical risk. It is an operational certainty that will result in marketplace suspension and potential fines.

The PPWR and its impact on representative requirements

The EU Packaging and Packaging Waste Regulation (PPWR, Regulation EU 2025/40) entered into force on February 11, 2025, with general application starting August 12, 2026. Article 40 of the PPWR establishes a formal EU-wide framework for authorised representatives.

Under the PPWR, producers who are not established in the Member State where they first make packaging available must designate an authorised representative in that Member State. This formalises what France already requires under its national EPR law, but extends the principle across the entire EU.

For sellers targeting multiple EU markets, this means mandatory representation in each country of sale. Your French mandataire covers France. For Germany, Spain, Italy, and other markets, additional representatives are needed. AuditREP coordinates multi-country compliance through our partner network, giving you a single point of contact for all EU markets.

The difference between EPR representative and fiscal representative

Foreign sellers often confuse the EPR representative (mandataire REP) with the fiscal representative (mandataire fiscal). These are completely separate functions.

The EPR representative handles environmental compliance: eco-organisation memberships, IDU registration with ADEME, annual declarations of products placed on market, eco-contribution payments, and regulatory authority correspondence. It operates under the French Environmental Code (Article L541-10).

The fiscal representative handles VAT obligations: VAT registration, periodic VAT declarations, and VAT payment. It operates under the French Tax Code. Non-EU sellers generally need both.

We handle EPR representation exclusively and coordinate with trusted fiscal representation partners to ensure complete coverage.

Multi-country EPR coordination through our partner network

Selling in France is often just the beginning. Most foreign sellers target several EU markets simultaneously. Each country maintains its own EPR system with different eco-organisations, different registration procedures, and different declaration formats.

Through our network of certified local partners, we coordinate your EPR compliance across the entire EU. France: we handle directly. Germany: LUCID registration plus dual system contract. Spain: Ecoembes registration plus RPP. Italy: CONAI consortium memberships. Belgium: Fost Plus. Netherlands: Afvalfonds. Austria, Poland, Czech Republic, Nordics: through local partners.

You provide your sales data once, in one format. We distribute it to each country and manage the entire process. One invoice, one reporting dashboard, one point of contact.

What we need from you to get started

To initiate your EPR representation in France, we need your company registration details (name, address, registration number from your home country), a description of the products you sell in France, estimated annual sales volumes in France by product category, and bank details for eco-contribution payments.

No French company registration is required. No physical presence in France is needed. The entire process is handled remotely, in English or Chinese, within 2-3 weeks.

Sanctions for non-compliance

Administrative fines up to 7,500 euros per unit or per tonne of undeclared products (Article L541-9-5 of the Environmental Code). A specific fine of 30,000 euros for missing IDU. Daily penalties up to 20,000 euros until regularisation. Marketplace listing suspension on Amazon.fr, ManoMano, Cdiscount, and all major French platforms. The contribution d'office mechanism allows direct payment orders to be issued to the marketplace itself.

Contact us today for a free compliance assessment.

The timeline for compliance in 2026

January to March: annual declaration period for most eco-organisations. All sales volumes from the previous calendar year must be declared. Late declarations incur penalties.

July 1, 2026: professional packaging EPR becomes operational. Companies placing professional packaging on the French market must register with Citeo Pro. This affects manufacturers and importers of pallets, industrial films, transport crates, and other B2B packaging.

August 12, 2026: PPWR general application date. New packaging design requirements begin phasing in. Documentation obligations for all packaging placed on the EU market.

Companies that start the compliance process now will have their IDU numbers within 3 weeks and be fully operational before any of these deadlines.

What data we need for annual declarations

For packaging (Citeo): total weight in kilograms per material type placed on the French market during the calendar year. Materials include glass, steel, aluminium, cardboard, paper, PET clear, PET coloured, PE, PP, PS, PVC, and other plastics. Each material has its own rate per kilogram.

For WEEE (Ecosystem): number of units placed on market per WEEE category (7 categories from large household appliances to photovoltaic panels).

For textiles (Refashion): number of items per product type (10 categories from T-shirts to footwear).

For batteries: total weight per battery chemistry type placed on market.

We collect this data from your sales records, logistics systems, or marketplace reports. We handle all format conversions and portal submissions.

Our service level commitments

24-hour response time for all enquiries. IDU numbers delivered within 2-3 weeks of mandate signature. Annual declarations filed before the March deadline every year. Quarterly compliance status reports. Proactive alerts for regulatory changes affecting your obligations. Dedicated English-speaking and Chinese-speaking account managers.

Choosing the right EPR representative

Not all mandataire services are equal. Key criteria to evaluate: coverage of all 19 French EPR categories (not just packaging), eco-contribution optimisation capability (comparing eco-organisations, claiming bonuses), response time for urgent situations (marketplace suspensions, authority inspections), language capability (English, Chinese, in addition to French), and multi-country coordination if you sell beyond France.

A mandataire that simply fills in forms without optimising your declarations costs you money every year through missed bonuses and suboptimal eco-organisation choices. The savings from proper optimisation typically cover the entire mandataire fee.