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Packaging EPR in France
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Checked 2026-09-12 · 5 sources · 4 open questions
- Register
- SYDEREP — IDU (identifiant unique)
- Authority
- ADEME
- Law
- Code de l'environnement, art. L. 541-10-13 (loi AGEC)one IDU per EPR stream; household packaging and B2B packaging (EPRO/EIC) are separate streams. The EPRO stream takes effect 1 January 2027: the 1 July 2026 operational start was postponed sine die on 26 June 2026 and refixed by ministerial announcement of 28 July 2026. Catering packaging has been covered since March 2024. Founding texts: decree 2025-1081 of 17 November 2025; scope and specifications orders of 2 December 2025. The flat fee for a small producer is the PRO's price, not a French rule: Citeo charges 80 EUR for under 10 000 UVC a year, Adelphe 110 EUR for the same tier, and Leko caps a simplified declaration under 20 000 UVC at 150 EUR. Above 10 000 UVC and up to 500 000 UVC the declaration is by product family; above that it is detailed, by material and weight.
- Who registers
- The eco-organisme registers you
- Authorised representative
- Mandatory for a producer established abroadArt. 45(3) of the regulation requires one from a producer who makes packaging available directly to end users in another member state. France is reported to go wider from 10 July 2026 — a French mandataire from EVERY producer established outside France, distance selling or not. We found that reading only at a commercial mandataire whose business is selling it, and in one French consultancy's news line; not in a French legal text. It is held here as unsettled, not as a duty we announce.
- Reporting
- Annual declarationdeclared in SYDEREP; the eco-organisme registers you and issues the IDU
- Also required
- Membership of an approved eco-organisme
- Household packaging schemes
- Citeo (incl. Adelphe, which specifically manages packaging recycling on behalf of baking, wine, spirits and pharmaceutical companies), and Léko
- Industrial packaging schemes
- Citeo Pro, TWIICE, Léko
What is not settled
- Authorised representative Sources disagreeFrance is reported to require a French mandataire for EVERY producer established outside France from 10 July 2026 — wider than PPWR Art. 45(3), which covers only sales direct to end users. Treat as unsettled.
- Penalties Not established at sourceA fine of up to EUR 30 000 under Environmental Code L541-9-5 is cited by one source only.
- Who registers Not established at sourceFor the EPRO stream the authority points to the producer definition in Art. 3(15) of Regulation (EU) 2025/40 and states that guidance on how it is to be interpreted is still to come. In the catering stream the producer is the party that packs the goods, not the packaging manufacturer.
- Authorised representative Sources disagreeThe authorised-representative duty is under review. On 10 December 2025 the Commission published COM(2025) 982, part of the Omnibus VIII environmental simplification package, whose Article 2 would suspend Art. 45(3) until 1 January 2035; COM(2025) 983 proposes the same for the Single-Use Plastics Directive. The suspension as drafted covers producers ESTABLISHED IN THE UNION selling cross-border directly to end users. Producers established in third countries are not covered — member states may still require a representative or ensure traceability by other means. European Parliament committee reports of May 2026 would narrow the relief to micro and small enterprises. PROPOSAL, AND NOW LARGELY STOPPED: on 24 June 2026 the Council decided not to proceed with the suspension, opposed by a large majority of member states. A Parliament committee vote is expected around October 2026, and even the Parliament's narrower approach would keep the framework for producers outside the EU. Article 45(3) applies as written today, and for a producer established in a third country nothing in this proposal ever applied.
The same in every EU country
- PPWR Art. 44 — registration is a precondition for placing packaging on that market
- PPWR Art. 45(3) — a producer under Art. 3(1)(15)(c)/(d), i.e. one making packaging available in another Member State DIRECTLY TO END USERS, must appoint an authorised representative there. From 12 Aug 2026.
- set nationally, Art. 68; national rules due by 12 Feb 2027
- Art. 44(14) implementing act still pending; central EU register not before 1 Jan 2029
Sources
Countries with the same answer
We do not register you, we are not your authorised representative, and we do not pay a scheme. This is public information gathered in one place and checked on the date shown. Confirm with the national authority before acting.
Tarafex
The number these registers ask for is kilograms by material for one year of deliveries. If your shipments are recorded as they go out, that number already exists.
See what Tarafex does →
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