Check whether you need an EPR representative in France

The short answer

If your company is not established in France and sells products covered by French extended producer responsibility (EPR), you must appoint a representative established in France. The rule has applied since 10 July 2026 and covers every EPR category. It is treated as met for products whose EPR obligations a marketplace established in France already fulfils.

Answer four to ten questions and get the result on screen, with no account and no email: yes, no, or “it depends on your contracts”. The result names the rule applied, the EPR categories to cover, the lead times the producer responsibility organisations (PROs) publish and the price of our service.

Who has to appoint a representative?

Any person not established in France that is subject to French EPR. Sellers based in another EU Member State are covered as much as sellers based outside the EU, and no EPR category is excluded.

In plain English: the producer appoints, in writing, an individual or a company established in France. The article was created by Article 5, I, 2° of Law No. 2026-602 of 8 July 2026 (Journal officiel of 9 July 2026) and needs no implementing decree.

The representative steps into (“est subrogé dans”) the EPR obligations the mandate covers. Your sales channel decides the rest:

• direct sales to French customers, through your own website or other distance selling: the obligation applies;
• marketplace sales: the obligation applies, unless the marketplace is established in France and fulfils your EPR obligations for those products;
• sales to a French distributor: it depends on who imports the products or first offers them for sale in France, which your contract and delivery terms show.

What difference does a marketplace make?

The exception covers “les produits” (the products) that a marketplace established in France takes care of. The same products sold through other channels remain covered by the obligation.

The law does not require written confirmation from the marketplace. The check still asks for it, because a document is the only way to show the marketplace fulfils your obligations; without one, the answer is “it depends”.

A marketplace that does not hold your UIN, the French EPR registration number (identifiant unique), becomes liable for your EPR obligations on the sales it handles. Holding the UIN “est réputée valoir conformité du tiers”: it counts as proof of the seller’s compliance (Article L. 541-10-9, para. 2, in force since 1 January 2022). Several marketplaces then pay the eco-contribution for you and charge it back, for their own sales only.

What about EU rules?

For packaging, Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) also requires a representative in each Member State where a producer sells directly to end users. This has applied since 12 August 2026 (Article 71).

On 10 December 2025 the Commission proposed suspending this requirement until 1 January 2035 (COM(2025) 982). The European Parliament adopted its position on 20 October 2026 and referred the file back to committee for negotiations; its first reading is not closed (procedure file 2025/0395(COD)). Its version only exempts EU-based small and micro enterprises.

On 21 October 2026 the Council agreed its mandate (ST 14765/26): EU producers placing less than 1 tonne of packaging a year in another Member State would be exempt there until 1 January 2032. As of 1 November 2026 nothing has been adopted, and no version amends the French obligation. [À VÉRIFIER : calendrier des trilogues et texte final.]

How the answer is worked out

Everything runs in your browser, and nothing you enter is stored unless you ask for a callback. The rules are versioned data (content/data/simulateurs/mandataire-obligatoire.yaml, version 0.1.0), tested against 21 reference cases. The engine always takes the same four steps.

1. Entry checks. A company established in France gets “no”. Products outside every EPR category get “no”. A branch or office in France gets “it depends”, because the Code does not define “established in France”. If you do not know your EPR categories yet, the check first sends you to the French category finder.
2. One verdict per channel. Direct sales give “yes”. Each marketplace is assessed on its own: one that does not fulfil your obligations, or is not established in France, gives “yes”; one established in France that fulfils them and has said so in writing gives “no”; an unknown answer or no written confirmation gives “it depends”. For a distributor, the verdict follows whoever imports or first offers the products for sale.
3. Combining. One channel at “yes” makes the answer “yes”. Otherwise, one channel at “it depends” makes it “it depends”. Otherwise the answer is “no”.
4. Notes. The engine adds notes that never change the answer: the EU packaging rule, a subsidiary that can act as representative, marketplaces paying on your behalf.

Each answer carries a confidence level. “Direct reading of the text” means the rule is written in plain terms. “Reading of the text, no published official position” flags an interpretation: no official guidance on Article L. 541-10-9-1 had been published as of 1 November 2026.

EPR categories to cover. These are the categories you select, or those the category finder rates “certain” or “probable”. Categories rated “to be checked” are listed separately, and a category with no approved PRO is not counted.

Lead time. The check shows, category by category, the time each PRO says it takes to issue the UIN. As of 1 November 2026, Léko says “en quelques jours” (within a few days) and Citeo Pro says 5 days after joining, for catering packaging only; the others publish no duration. The check never fills a missing figure with an estimate.

Price. The price comes from our EPR representative service: €590 excl. VAT per year for the first EPR category, then €290 excl. VAT for each additional one. Restricted listings add the suspended account option (€290 excl. VAT). Eco-contributions are not included: you pay them directly to the PRO.

What the check does not do

• It does not read your contracts or your marketplaces’ terms.
• It does not know which products go through which channel: it counts every EPR category you declare.
• It does not work out EU obligations country by country; it flags them for packaging.
• It says nothing about your company’s current compliance. It states what the texts require in the situation you describe.
• It does not cover the compliance of the packaging itself, which falls on the manufacturer (Regulation (EU) 2025/40, Article 15).

Sources

Checked on 1 November 2026.

• French Environmental Code, Article L. 541-10-9-1, in force since 10 July 2026.
• French Environmental Code, Article L. 541-10-9, in force since 1 January 2022.
• French Environmental Code, Article L. 541-10, definition of producer.
• Law No. 2026-602 of 8 July 2026, Article 5.
• Regulation (EU) 2025/40, Articles 3, 15, 17, 45 and 71.
• Proposal COM(2025) 982, procedure file 2025/0395(COD) and Council mandate ST 14765/26.
• Léko, producers page and article on the representative obligation, 21 July 2026.
• Citeo Pro UIN sheet; ecosystem, unique identifier; Ecomaison, membership terms, January 2026; Valdelia, members’ guide 2025; Ecominéro, joining guide.

Related pages

• French version of this check: Mandataire obligatoire ?
• Glossary (French): mandataire, producteur non établi, subrogation.