EPR authorised representative in France

The short answer

A company that sells products under French extended producer responsibility (EPR) and is not established in France must appoint, by written mandate, an authorised representative established in France. The rule covers every EPR category and has applied since 10 July 2026 (Article L. 541-10-9-1 of the French Environmental Code). France REP acts as that representative for €590 excl. VAT per year for the first EPR category.

France REP is a private service published by GABEM SAS, Nice. It is independent of the French State, of the French Agency for Ecological Transition (ADEME) and of the producer responsibility organisations. Glossary links on this page lead to our French glossary.

Who must appoint a French EPR representative?

You must appoint one if you are not established in France and you are an EPR “producer” in France. Three kinds of seller are covered.

• Non-EU sellers (China, United States, United Kingdom, Switzerland and others) selling to French customers through their own website or a marketplace.
• Sellers established in another Member State of the European Union (EU) (Germany, Italy, Spain, Poland and others) selling at a distance to customers in France.
• Non-French marketplaces that facilitate sales of EPR products in France on behalf of third parties.

Sellers established in France do not need a representative: they register in their own name.

In plain English: the producer appoints, in writing, an individual or a company established in France as its representative. The article was created by Article 5, I, 2° of Law No. 2026-602 of 8 July 2026, published in Journal officiel No. 0159 on 9 July 2026 (Légifrance, checked on 1 November 2026). It lists no EPR categories and needs no implementing decree.

The representative is “subrogé” in the producer’s EPR obligations: it steps into them, within the scope of the mandate it accepts.

The marketplace exception

The obligation is “deemed satisfied” for products for which a marketplace established in France already ensures EPR compliance (second paragraph of the same article). The text does not require a written confirmation from the platform, and it speaks of “products”, not of a sales channel. Our reading: products sold through that platform are covered for those sales, and the same products sold on your own website or to a French retailer are not.

No official guidance confirms this reading yet. [À VÉRIFIER : doctrine administrative sur l’exception plateforme (écrit, périmètre par produit ou par canal) ; aucune trouvée au 01/11/2026.]

If you rely on this exception, keep a written statement from the platform as evidence. A marketplace’s pay-on-behalf service is not a mandate: it only covers sales made on that marketplace. [À VÉRIFIER : entité contractante et lieu d’établissement d’Amazon.fr, de TikTok Shop France et de Fnac Darty Marketplace au sens du second alinéa de L. 541-10-9-1 ; Cdiscount est une SA immatriculée à Bordeaux selon ses CGMAD.]

Cases that depend on your contracts

An EU manufacturer that sells only to a French distributor is usually not the producer for packaging: the distributor that first makes the goods available in France is. This follows from the definition of “producer” in Article 3(1)(15) of Regulation (EU) 2025/40, which applies the cross-border rule only to sales made “directly to end users”. For other EPR categories (electrical equipment, textiles, furniture, building products), the answer turns on each category’s definition, on delivery terms and on who owns the goods when they enter France.

[À VÉRIFIER : définition du producteur filière par filière pour un fournisseur UE livrant un distributeur français.]

A French subsidiary of your group can act as your representative: the text only asks for a person “established in France” appointed by written mandate. If that subsidiary buys and resells the goods itself, it is usually the producer in its own right for those sales.

What the EU packaging regulation adds

For packaging, Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) has applied since 12 August 2026 (Article 71). Its Article 45(3) requires a producer that sells packaging or packaged products directly to end users in another Member State to appoint an EPR authorised representative in each such Member State.

Article 44 requires registration in the producer register of each Member State where packaging is first made available. Article 45(4) requires online platforms to collect the producer’s registration number before admitting it. [À VÉRIFIER : désignation par la France du registre national au sens de l’article 44 et possibilité d’enregistrement par le mandataire ; acte d’exécution de l’article 44, par. 14, non adopté à notre connaissance au 01/11/2026.]

Do not confuse this with the Article 17 authorised representative. Article 17 is optional: a manufacturer may appoint someone in the EU to hold its declaration of conformity and technical documentation for market surveillance authorities. That is a product compliance role, and our mandate does not cover it.

Open point: the EU omnibus proposal

On 10 December 2025 the European Commission proposed suspending Article 45(3) in full until 1 January 2035 (proposal COM(2025) 982, procedure 2025/0395(COD), EUR-Lex, checked on 1 November 2026). Member States could then still require a representative from non-EU producers, or use other means.

On 20 October 2026 the European Parliament adopted its position, by 616 votes to 9 with 39 abstentions, and referred the file back to committee for negotiations with the Council (press release). Its version only exempts EU-based small and micro enterprises, until 2035 or until a circular economy act is adopted. The first reading is not closed: the Legislative Observatory still shows “Awaiting Parliament’s position in 1st reading”.

On 21 October 2026 the Council agreed its negotiating mandate (ST 14765/26). It exempts an EU-based producer in each other Member State where it places less than 1 tonne of packaging a year, until 1 January 2032, subject to a review by 31 December 2030. It drops batteries, lets a national authority order a non-compliant exempted producer to appoint a representative, and leaves Article 45(3) unchanged for non-EU producers.

Nothing has been adopted. [À VÉRIFIER : calendrier des trilogues et texte final.]

As of 1 November 2026, no version of the proposal amends Article L. 541-10-9-1, which rests on French law and covers every EPR category. A twin proposal, the directive COM(2025) 983 (textiles, electrical equipment, single-use plastics), says in its recital 9 that Member States “should not” make the appointment of a representative mandatory under national law for EU-based producers. [À VÉRIFIER : effet de COM(2025) 983 sur L. 541-10-9-1 pour les vendeurs établis dans l’UE ; position du Conseil sur 2025/0396(COD).]

What the mandate covers

The Mandat REP includes six services for each EPR category you subscribe to.

• A written mandate between your company and GABEM SAS, established in Nice, France.
• Membership of the producer responsibility organisation (PRO; “éco-organisme” in French) for each EPR category, signed by us as your representative.
• Your UIN, the French EPR registration number (UIN; “identifiant unique” or IDU in French), for each EPR category, issued through ADEME’s producer register.
• The annual declaration of quantities placed on the French market, prepared from data you validate.
• Upload of your UINs to the marketplaces where you sell.
• Tracking of declaration and renewal deadlines.

What the mandate does not cover

• Eco-contributions. You pay them to the PRO. The amount depends on the PRO’s tariff and your volumes.
• Packaging conformity. Under Articles 5 to 12 and 15 of the PPWR, the manufacturer of the packaging or packaged product is responsible for it. A representative does not take it over.
• The Article 17 product compliance role described above.
• Other EU countries. The mandate covers France only. Each Member State requires its own representative under Article 45(3).
• Legal advice. We prepare and file; we do not give legal opinions on your situation.
• The accuracy of your data. We declare what you provide and validate.

Price

Prices are fixed, published and exclude VAT. They do not include eco-contributions or PRO fees.

Renewal costs the same as the first year because the mandate is the obligation itself: it runs for as long as you sell in France.

Example: a seller of small electrical appliances in cardboard boxes needs two EPR categories, household packaging and electrical and electronic equipment (WEEE). The mandate costs €880 € HT excl. VAT per year.

The suspended account option is for a seller whose marketplace has blocked listings or started charging on its behalf. It adds priority handling, a UIN requested within the PRO’s shortest lead time and a file ready to send to the marketplace.

Payment is online, by card or bank transfer, with an automatic invoice.

Market prices we observed

These are ranges observed on 1 November 2026, not a price list. In France, published entry prices per EPR category per year run from €190 to €590: €190 excl. VAT at EPR Representative, €49 a month at AuditREP, and €590 with no VAT charged at REP·Pro (a VAT-exempt small business under Article 293 B of the French General Tax Code).

Where set-up fees are shown, they run from €290 to €300, and EPR Representative also asks for a refundable deposit. EPR EU Rep publishes “France from €190” per country per year, VAT not stated, and Eldris publishes £285 to £495 per EPR category per year. Entry prices near €190 apply to one EPR category under a PRO’s flat-fee regime.

Our price sits above the entry level. One mandate covers every EPR category your products fall under, where some providers cover only part of them, and the suspended account option targets the UIN lead time, which is what unblocks an account.

PRO fees, for budgeting

Figures observed on 1 November 2026 in each PRO’s published tariff; not a quote.

[À VÉRIFIER : barèmes officiels 2027 de Citeo et de Léko pour les emballages ménagers.]

Who pays the PRO

By default, you pay the PRO directly. We file your declarations and deal with the PRO for you; we do not carry the cash flow of your eco-contributions.

[À VÉRIFIER : qualification du portage pour compte au regard de l’article L. 314-1 du code monétaire et financier (services de paiement) ; tant que ce point n’est pas tranché, le paragraphe suivant n’est pas publié et seule la règle ci-dessus s’applique.] If you ask us to pay a PRO for you, you pay us in advance. We charge the exact amount back to you at cost, with no margin, on a separate invoice line.

Lead times by PRO

The UIN is issued after membership: the PRO registers you with ADEME and sends the number. ADEME states that a producer cannot register on its own, and that each UIN covers one EPR category (ADEME, checked on 1 November 2026).

[À VÉRIFIER : délai de délivrance de l’IDU chez Citeo (emballages ménagers), Adelphe, Refashion, Ecologic, Valobat, Twiice et Citeo Pro (emballages professionnels).] [À VÉRIFIER : délai de bout en bout de France REP, de la commande au chargement de l’IDU, à fixer avec Ben ; absent de content/data/offre.yaml.]

How it works, in five steps

1. Scope. You order online or book a 20-minute call. We list the EPR categories that apply to your products and their packaging.
2. Documents and mandate. You send the documents listed below and sign the mandate.
3. Membership. We apply to each PRO as your representative. You pay the membership fees and eco-contributions to the PRO directly.
4. UIN and marketplaces. The PRO registers you with ADEME and issues the UIN. We upload it to each marketplace where you sell.
5. Declaration and renewal. We prepare the annual declaration from your validated data, track the deadlines and renew the mandate each year.

Documents to provide

• Company registration extract from your home country, or its equivalent: a Chinese business licence, a US certificate of incorporation, a UK Companies House extract or a German Handelsregisterauszug, for example.
• VAT number, or failing that your tax identification number in your country of residence: ADEME requires one of these to register a foreign company.
• The signed mandate.
• Product and volume list: your products by EPR category, with quantities sold in France (units, pieces or weight, depending on the category).
• Sales history in France, if you sold there before joining: Ecomaison, for example, asks late members to declare the three previous calendar years within 21 days.
• Existing UINs and marketplace seller IDs, if any.
• Identity and contact details of the signatory.

[À VÉRIFIER : relecture avocat du modèle de mandat et couverture explicite de l’activité de mandataire par la RC Pro avant la première commande.]

Check your situation

The check asks four to ten questions and answers on screen, with no account and no email: yes, no, or “it depends on your contracts”. It runs in your browser from versioned rules (content/data/simulateurs/mandataire-obligatoire.yaml, version 0.1.0), tested against 21 reference cases.

It always works in the same order. A company established in France gets “no”; a branch or office in France gets “it depends”, because the Code does not define “established in France”. Direct sales give “yes”; each marketplace is assessed separately, and only one established in France that confirms in writing that it fulfils your obligations gives “no”.

One channel at “yes” makes the answer “yes”. The check then lists the EPR categories to cover, the lead times each PRO publishes (it never fills a gap with an estimate) and the price of the mandate. It does not read your contracts or your marketplaces’ terms.

Marketplace questions

Other questions

Who is legally responsible

The producer remains the legally responsible person. The representative acts on the producer’s behalf, within the limits of the mandate and of the data the producer provides. [À VÉRIFIER : portée de la subrogation prévue par L. 541-10-9-1 (« subrogé dans toutes les obligations ») au regard de cette mention, et exposition du mandataire aux sanctions ; relecture avocat avant publication.]

Order or talk to us

€590 excl. VAT per year for the first EPR category, €290 for each additional one. You pay eco-contributions directly to the PRO.

Ordering online shows the exact price for your EPR categories before you sign anything. The call is free and commits you to nothing.

Related pages (in French)

• Mandataire REP : le texte, les dates et les cas limites
• L’offre mandataire en français
• Je vends sur Amazon.fr depuis l’étranger : dois-je désigner un mandataire REP ?
• L’identifiant unique (IDU)
• L’omnibus PPWR ne dispense pas du mandataire REP en France
• Vérifier un IDU dans le registre