Who must register for packaging EPR in France, and how
Every producer placing household packaging on the French market must hold a unique identifier (Identifiant Unique, IDU) issued by ADEME and recorded in SYDEREP, and must join an approved eco-organisme and pay eco-modulated éco-contributions. There is no de-minimis for household packaging. A producer not established in France must appoint a France-established mandataire.
This is general information about Regulation (EU) 2025/40 and France's national EPR scheme, not legal advice. Thresholds, fees, penalty amounts and go-live dates come from national law and PRO schedules that change — treat every figure as needing a fresh check, and confirm anything you act on with the national authority or qualified counsel.
| Register / authority | Unique identifier (IDU) issued by ADEME, recorded in SYDEREP |
|---|---|
| PRO / compliance scheme | An approved eco-organisme — Citeo/Adelphe or Léko |
| Authorised Representative | Yes Required for non-established producers |
| De-minimis threshold | None (household packaging) |
| National instrument | the AGEC law and the Code de l'environnement |
The register and what it involves
Under the AGEC law (in force since 1 January 2022), every producer must hold a unique identifier (IDU) per EPR stream, issued by ADEME and recorded in the SYDEREP system. In the normal collective route the eco-organisme registers the producer in SYDEREP and passes back the IDU; for an approved individual system ADEME issues it directly. The IDU must appear in your terms and conditions and on your website.
You must join an approved eco-organisme and pay eco-modulated éco-contributions. For household packaging the approved eco-organismes (agrément 2025–2029) are Citeo/Adelphe and Léko — in practice the two independent choices are Citeo (including Adelphe) and Léko.
De-minimis: none for household packaging
There is no small-quantity exemption for household packaging — the obligation applies from the first unit. A separate 10,000-units/year and €10m-turnover threshold applies only to the AGEC eco-design planning duty, which is not an exemption from registration or contributions.
The mandataire rule
A producer not established in France must appoint a France-established mandataire — a French legal entity with a SIREN — that registers, obtains the IDU, files declarations and interfaces with ADEME. Since the Conseil d'État ruling of 10 November 2023 (n° 449213) the mandataire acts in the name and on behalf of the producer and cannot absorb the producer's legal liability; the old subrogation model was annulled. PPWR Article 45 reinforces this from 12 August 2026.
Reporting and penalties
Reporting is an annual declaration to the eco-organisme of prior-year packaging (units, weights, materials, plus recyclability and recycled-content data for modulation). The operative deadline is end of February (Citeo's 2026 declaration for 2025 data is 28 February 2026); the statutory backstop is 31 May.
Under Code de l'environnement art. L.541-9-5, penalties reach up to €30,000 for failing to register or join an eco-organisme, up to €7,500 per unit or tonne of non-compliant product, and a daily penalty up to €20,000/day until regularised. A separate professional/commercial packaging REP (EPRO) is phasing in — the operative start date was reportedly delayed in late June 2026, so confirm it nationally.
How onerous is it?
High. No de-minimis, a France-established mandataire required for foreign sellers, mandatory eco-organisme membership, an ADEME IDU, an annual tonnage declaration, and eco-modulated contributions that are actively tightening.
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Get my full PPWR obligations report →Frequently asked questions
What is the IDU and where do I get it?
The IDU (Identifiant Unique) is a per-stream registration number issued by ADEME and recorded in SYDEREP. In the collective route your eco-organisme registers you and passes the IDU back; for an approved individual system ADEME issues it directly. It must appear in your T&Cs and on your website.
Does France have a small-business exemption from packaging EPR?
No, not for household packaging — the obligation applies from the first unit. The 10,000-units/€10m threshold that some cite applies only to the AGEC eco-design planning duty, not to registration or contributions.
If I have no French company, can a mandataire take on my liability?
A France-established mandataire is required for non-established producers and handles registration, the IDU and declarations. But since the Conseil d'État ruling of 10 November 2023 it acts in your name and on your behalf and cannot absorb your legal liability.
Sources
- ADEME — the unique identifier (IDU) and SYDEREP — https://filieres-rep.ademe.fr/identifiant-unique
- service-public.gouv.fr — penalties under the Code de l'environnement — https://entreprendre.service-public.gouv.fr/vosdroits/F37937?lang=en
- Household-packaging EPR (filière EMPAP) and approved eco-organismes — https://filieres-rep.ademe.fr/filieres-REP/filiere-EMPAP