Who must register for packaging EPR in France, and how

Reviewed against the Code de l'environnement on 29 September 2026. 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.

The register and what it involves

Since 1 January 2022, every producer in an EPR stream must hold a unique identifier (IDU) for each 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 of sale and on your website.

You must join an approved eco-organisme and pay eco-modulated éco-contributions. For household packaging the eco-organismes approved for 1 January 2025 to 31 December 2029 are Citeo (with Adelphe, part of the same group) and Léko. Professional and commercial packaging has its own scheme, REP EPRO (décret 2025-1081), with Citeo Pro, Léko Pro and Twiice as its eco-organismes.

De-minimis: none for household packaging

There is no small-quantity exemption for household packaging: the obligation applies from the first unit. Some eco-organismes let small producers file a simplified flat-rate declaration below a threshold they set, which changes how you declare, not whether you are covered. The €10m-turnover and 10,000-units-a-year thresholds sometimes quoted decide only who must tell consumers about a product's environmental characteristics; they are not an exemption from registration or contributions.

The mandataire rule

Since 10 July 2026, Article L541-10-9-1 of the Code de l'environnement, added by Law 2026-602 of 8 July 2026, requires any producer subject to EPR in France that is not established there, EU or non-EU, to appoint a France-established mandataire by written mandate. The mandataire is subrogated in your REP obligations: it takes them over, including registration, the IDU and declarations.

This goes further than Article 45(3) PPWR, which requires a representative only from producers selling directly to end users in a country where they are not established. It also settles the question left by the Conseil d'État ruling of 10 November 2023 (no. 449213), which struck down subrogation set by decree and left mandataires acting only in the producer's name. The statute now provides for subrogation itself.

Reporting and penalties

Reporting is an annual declaration to your eco-organisme of the previous year's packaging (units, weights and materials, plus the recyclability and recycled-content data used for eco-modulation), by the deadline your eco-organisme sets.

Under the REP sanctions in the Code de l'environnement, the environment minister can impose an administrative fine of up to €30,000, for example for having no IDU, leaving it off the required documents or not contributing to an eco-organisme; a fine of up to €7,500 per unit or per tonne of product concerned for a company (€1,500 for an individual); and a daily penalty of up to €20,000 until the position is put right.

The professional-packaging REP (EPRO) has existed since 1 January 2026, but its operational start was postponed to 1 January 2027 by a ministerial communiqué of 28 July 2026. No amending text had been located in the Journal officiel, so confirm the start date before you plan around it.

How onerous is it?

High. No de-minimis for household packaging, a France-established mandataire for every producer based outside France, eco-organisme membership, an ADEME IDU per stream, an annual declaration, eco-modulated contributions, and a second scheme for professional packaging due to start operating on 1 January 2027.

Frequently asked questions