EPR France Packaging Registration: Step-by-Step Guide for Foreign Exporters

Every product sold in France triggers packaging EPR

If you sell a product to a French consumer, the packaging it comes in is subject to Extended Producer Responsibility. This applies to primary packaging (the box or container that holds the product), secondary packaging (the outer carton or sleeve), and tertiary packaging (shipping materials, fillers, tape). The legal basis is Article L541-10 of the French Environmental Code, implemented through the AGEC law of February 2020.

The obligation applies regardless of where the product was manufactured or where the company is based. A Chinese manufacturer shipping directly to French consumers bears the same packaging EPR obligation as a French factory. The trigger is not where the product is made but where it reaches the consumer.

For foreign companies without a French establishment, a mandataire REP (authorised representative) handles all packaging EPR obligations on their behalf.

Citeo: the dominant packaging eco-organisation

Citeo manages approximately 95 percent of French packaging EPR. Its competitor Léko holds the remaining market share. Both are approved eco-organisations, but Citeo is the default choice for most producers due to its established infrastructure, online tools, and sector-specific support.

Registration with Citeo requires the company name, address, SIREN number (or equivalent foreign registration), VAT identification number, and bank details for eco-contribution payments. For foreign companies, registration is handled through the mandataire who signs the Citeo contract on the producer's behalf.

The IDU (Identifiant Unique) is issued by ADEME through Citeo within 5 to 10 business days after registration. This number must be entered in all marketplace accounts (Amazon, ManoMano, Cdiscount) and included in the company's terms and conditions.

Eco-contribution rates by material (2025 tariffs)

Citeo calculates eco-contributions per kilogram per material type. The 2025 rates represent significant increases over 2024, particularly for plastics. Glass remains the cheapest material at approximately 1.5 euro cents per kilogram. Steel is approximately 5.35 cents per kilogram. Aluminium is approximately 18.65 cents per kilogram. Cardboard and paper are approximately 21.43 cents per kilogram. PET clear bottles are approximately 53.52 cents per kilogram. PE and PP rigid packaging is approximately 58.87 cents per kilogram. PS and complex plastics face dissuasive rates well above 1 euro per kilogram.

These rates are further modified by eco-modulation bonuses and penalties. A mono-material recyclable cardboard package with recycled content can benefit from 15 to 25 percent in cumulative bonuses. A multi-material non-recyclable plastic package faces penalties that can double the base rate.

The simplified flat rate for small producers

Producers placing fewer than 10,000 consumer units on the French market per year can opt for Citeo's simplified flat rate of 80 euros per year. This covers all packaging materials without detailed weight declarations. For small e-commerce sellers, this is often the most cost-effective option.

Between 10,000 and 500,000 units per year, five simplified sector-specific formulas are available. Above 500,000 units, detailed declaration by weight and material is mandatory, and eco-modulation criteria apply.

Eco-modulation: bonuses and penalties

Citeo's eco-modulation system rewards recyclable, lightweight, and recycled-content packaging while penalising problematic materials and designs. Key bonuses include the source reduction bonus of minus 8 percent for documented weight reduction or refill systems, the reuse bonus of minus 100 percent on the contribution for packaging with an operational industrial reuse scheme, the sustainable forest management bonus of minus 10 percent for certified wood-based materials exceeding 50 percent by weight, and recycled content premiums ranging from 40 to 55 euro cents per kilogram depending on the plastic type and origin.

Key penalties include plus 10 percent for non-compliant density preventing separation by flotation, plus 50 percent for glass with non-magnetic steel closure or dark rigid plastics not detectable by optical sorting, and plus 100 percent for PET with mineral charge above 4 percent or aluminium-PVC composites with density above 1.

Practical steps for a foreign company

Step 1: appoint a mandataire REP in France. Step 2: the mandataire registers with Citeo on your behalf. Step 3: receive your IDU within 5 to 10 business days. Step 4: enter the IDU in all marketplace accounts. Step 5: track your French shipments by packaging material and weight throughout the year. Step 6: the mandataire files your annual declaration in January to March based on your data.

The entire setup takes 2 to 3 weeks. Annual ongoing effort is minimal: providing sales and packaging data to your mandataire once per year.

Contact us for a free packaging EPR assessment

We analyse your product catalogue, identify your packaging materials, estimate your eco-contributions, and handle the entire registration process. Request a quote below.

Why packaging optimisation matters more in 2025-2026

Citeo's 2025 tariff increases hit plastics hardest: PET clear rose 40.3 percent, PE and PP rigid rose 40.2 percent, while acier actually decreased 6.5 percent. These differential movements create opportunities for material substitution. Switching from PP rigid to cardboard for secondary packaging saves both on material cost and eco-contribution. Our mandataire service includes packaging composition analysis to identify these savings.

The UVC component: an often-overlooked cost

The UVC (Unité de Vente Consommateur) component represents approximately 25 percent of the total Citeo contribution for 2025. It varies by sector: food and beverages, hygiene and beauty, home maintenance, DIY and gardening, and other. This component includes a reuse financing element of 0.0103 euro cents per UVC. For high-volume sellers, optimising UVC classification by sector can yield meaningful savings.

Professional packaging: the July 2026 opportunity

From July 1, 2026, professional packaging (B2B) moves to a separate EPR stream under Citeo Pro. Companies currently declaring B2B packaging under the consumer stream may benefit from reclassification to potentially lower professional rates. Our mandataire service monitors this transition and reclassifies packaging automatically when beneficial. Contact us to prepare for this change.

The 2026 professional packaging shift: an opportunity

From July 1, 2026, professional packaging (B2B) moves to a separate EPR stream under Citeo Pro. Companies currently declaring B2B packaging under the consumer packaging stream may benefit from reclassification to lower professional rates. If you ship products to French businesses in industrial-size packaging (pallets, large cartons, bulk containers), part of your packaging may qualify for professional rather than consumer rates. Our mandataire service analyses your packaging flows and reclassifies automatically when beneficial, generating immediate savings.

Why a specialised mandataire saves you more than a generalist

International compliance firms handle packaging EPR as one checkbox among many services. They register you with Citeo, file the declaration, and move on. A specialised French EPR mandataire goes further. We analyse your packaging composition material by material. We test recyclability using Citeo's TREE tool to claim bonus reductions. We compare Citeo versus Léko rates for your specific material profile. We identify recycled content premiums you may be eligible for. We segment consumer from professional packaging to optimise applicable rates. These optimisations typically reduce packaging eco-contributions by 15 to 30 percent, often covering the entire mandataire fee.

Start protecting your French market access today

Every month without EPR registration is a month of accumulated risk: potential fines, marketplace suspension, and retroactive eco-contribution liability. Our mandataire service gets you compliant in 2 to 3 weeks, with optimised declarations from day one. Request a free packaging EPR assessment below.