France EPR Packaging Labeling Requirements Guide

Selling packaged goods in France comes with a specific set of legal requirements — and most businesses don’t realise how detailed they are until an audit or marketplace suspension lands. This EPR guide walks through what’s required right now: which symbols to put on your boxes, which recycling codes to use, how household packaging is defined, and what the PPWR adds from August 2026.

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What is EPR France — your EPR guide to key facts

France has been running producer responsibility schemes since the early 1990s — long before most EU countries got started. The core idea behind extended producer responsibility hasn’t changed: if you put a product on the market, you’re on the hook for dealing with the waste it generates. What has changed is the scope. Today it covers almost everything.

The legal framework rests on Decree 92-377, updated by the AGEC Law (Law 2020-105) and a 2024 Packaging Order. Taken together, EPR France is now probably the most wide-ranging producer responsibility scheme in the EU. The 2025 expansion added industrial and commercial B2B flows — so it’s not just about consumer goods anymore.

Day-to-day EPR compliance runs through approved Producer Responsibility Organisations. CITEO handles most household packaging. Adelphe covers wine and spirits. Léko offers an alternative. ADEME oversees the system.

Ready to register your company for France’s EPR packaging scheme? Let us handle your EPR registration — we’ll take care of the paperwork so you can focus on your business.

What is EPR compliance and what does it actually require

A lot of businesses ask what is EPR compliance exactly — and the short answer is that it’s three things at once. You register with a PRO and pay eco-fees based on what you put on the market. You put the right label on every packaging component. And every year you file a declaration covering every packaging type you’ve sold into France.

Getting registered is just the start. I’ve seen companies with valid CITEO membership still get flagged because they hadn’t put the Triman on their boxes — that’s what EPR compliance actually looks like in practice. PROs field questions about what is EPR compliance from new registrants constantly, and the answer always comes back to the same three-part picture.

Currently mandatory labels — what French law requires now

Four symbols are legally required on packaging sold in France. Each carries its own rules on placement, size, and permanence. This EPR guide section covers all four in detail.

Label / Symbol

What It Does and Where It Must Go

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Triman logo
[ MANDATORY ]

France’s own recycling symbol — unique in the EU. The Triman signals that the item belongs in the sorting stream. It must appear on the product, the packaging, or the product page for online sellers. Applies to packaging, electronics, textiles, and batteries.

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Info-tri sorting instruction
[ MANDATORY ]

Displayed alongside the Triman. Tells consumers which bin to use for each component. Must be in French. E-commerce sellers must also display it on product pages.

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Material recycling code (e.g. PAP 20)
[ MANDATORY ]

Numeric codes that identify what a packaging component is made of. PAP 20 is corrugated cardboard. PET 1 is standard plastic bottles. Each separable component needs its own code. Full list in Section 3.

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Crossed-out wheeled bin
[ MANDATORY — EEE & Batteries ]

Required on all electrical equipment and batteries. Signals separate collection at end of life. Since August 18, 2025, must cover at least 3% of the battery’s largest side. Cap: 5 × 5 cm.

Triman and info-tri — placement rules

Both symbols must be permanent. Print them on the box or engrave them on the product. For e-commerce, the product listing page is a valid alternative. A sticker that peels off does not satisfy the indelibility rule.

Multi-component packs need separate treatment. A cardboard box with a plastic insert needs the Triman and a recycling code on each part. CITEO’s technical guidelines specify minimum symbol sizes for different surface areas.

Penalty exposure: Missing Triman: up to €15,000 per infraction plus €20,000 per day until corrected. Failure to register with a PRO: up to €100,000.

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Have questions about France’s packaging labeling requirements or the Triman logo? Book a free demo and our experts will walk you through everything you need to know.

Material recycling codes — complete reference

Recycling codes identify what a packaging material is made of. They must appear on every component. Accurate coding also feeds into your annual PRO declaration — wrong codes trigger ADEME audits.

Paper and cardboard (PAP)

Code

Code and Material

Typical Uses

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PAP 20 — Corrugated cardboard

Shipping boxes, e-commerce outer packaging

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PAP 21 — Paperboard

Folding cartons, cereal boxes, product boxes

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PAP 22 — Paper

Bags, wrapping paper, tissue paper, leaflets

Plastics

Annual declarations require breakdown by polymer type. Marking everything as “plastic” without a specific code is not acceptable under EPR France rules.

Code

Code and Material

Typical Uses

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PET 1 — Polyethylene terephthalate

Drink bottles, food trays, blister packs

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HDPE 2 — High-density polyethylene

Detergent bottles, milk jugs, caps

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PVC 3 — Polyvinyl chloride

Cling film, rigid packaging (restrictions apply)

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LDPE 4 — Low-density polyethylene

Plastic bags, shrink wrap, squeezable bottles

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PP 5 — Polypropylene

Yoghurt pots, bottle caps, margarine tubs

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PS 6 — Polystyrene

Food containers, cups (recyclability concerns)

OTHER 7

Other / mixed plastics

Multi-layer, composite plastics

Glass, metals, and composites

Code

Code and Material

Typical Uses

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GL 70 — Clear glass

Bottles, jars

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GL 71 — Green glass

Wine bottles, glass jars

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GL 72 — Brown / amber glass

Beer bottles, medicine bottles

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ALU 41 — Aluminium

Cans, foil lids, aerosols

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FE 40 — Steel

Metal tins, food cans, steel aerosols

C/PAP 80-84

Paper / cardboard composite

Drink cartons (Tetra Pak-type)

EPR France registration and extended producer responsibility — who must comply

Extended producer responsibility means the cost and organisation of end-of-life waste management falls on the business that first put the product into circulation — not on taxpayers or local councils. France takes this seriously. Registration isn’t something you sort out after your first few sales; it has to happen before you ship anything at all.

There’s no minimum order size — one parcel to one French customer is enough to trigger the rules. That surprises people. The scope of extended producer responsibility is intentionally wide. Once you’re registered, EPR France registration gives you an IDU — a membership number you’ll need to share with every French marketplace and trading partner. Amazon and Zalando both check for it. No IDU, no listing.

Business Type

PRO to join

Key obligation

French manufacturers

CITEO (main household), LEKO (alternative), Adelphe (wine/spirits)

Register, declare packaging weight and materials annually

EU importers

CITEO or LEKO

Same obligations as French manufacturers

Non-EU distance sellers / e-commerce

CITEO or LEKO (via authorised rep)

May appoint an authorised representative in France

Online marketplaces

Not a producer (unless own-brand)

Must verify seller compliance

Household packaging vs professional packaging

When French EPR launched, household packaging was basically the whole story — anything a consumer takes home and eventually throws out. Since January 2025, there’s a second stream for B2B flows, and from July 2026 it comes with its own green levies. Two separate systems, two separate declarations.

The practical problem is that many businesses sell both ways. A pallet going to a retailer and the same product mailed directly to a home need to sit in different declaration buckets. Mixing them up is by far the most common error we see in multi-channel accounts.

Annual data reporting — what you must declare

Data reporting isn’t optional and it isn’t a formality. Every year by 31 May you file a declaration with your PRO covering the total weight of every packaging type you placed on the French market, split by material. Your eco-fees are calculated directly from those numbers. Get them wrong — whether by accident or otherwise — and you’re looking at an ADEME audit. Deliberate underreporting has ended PRO contracts before.

Non-EU sellers — deadline approaching: Appointing a French authorised representative is voluntary until August 12, 2026. After that date, the PPWR makes it mandatory. The representative holds a French SIREN number and manages all registration, reporting, and eco-fee payments.

PPWR — what the EU packaging regulation changes

New rules by packaging type — August 2026 obligations

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Regulation EU 2025/40 came into force on February 11, 2025, and it starts applying in full across all EU member states on August 12, 2026 — France included. Unlike a directive, it doesn’t need to be transposed into national law; it just applies directly. It replaces the old Directive 94/62/EC that’s been governing packaging rules since 1994. French EPR rules don’t disappear — they stay, and the PPWR sits on top of them.

New Obligation (from Aug 12, 2026)

What It Means in Practice

Declaration of Conformity (DoC)

Every packaging type needs a signed EU Declaration of Conformity and a technical file. The brand owner or importer signs it. Request documentation from your supplier now — no grace period after August 12.

PFAS ban — food-contact packaging

Per- and polyfluoroalkyl substances banned above specified limits in any food-contact packaging. Check grease-resistant papers and food wrappers immediately.

Heavy metal limits

Lead, cadmium, mercury, and hexavalent chromium must stay below 100 mg/kg combined. Request test certificates from your manufacturer.

Packaging minimisation

Packaging must be as small and light as technically possible. Excess empty space is restricted. Document justifications for current dimensions.

EPR fee modulation

CITEO and Léko must adjust fees based on recyclability, recycled content, and reusability. Poorly designed packaging will cost more.

Full compliance timeline

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Now (2026)

Triman + Info-tri + material codes required
EPR registration with CITEO, Léko, or Adelphe is mandatory. Share your IDU with all French platforms.

June 14, 2026

Sell-off deadline for pre-PPWR labelled stock
Packaging placed on the market or labelled before June 14, 2026 may generally continue to be sold until stocks are exhausted under sell-off rules.

Aug 12, 2026

PPWR core obligations — DoC, PFAS ban, minimisation
Declaration of Conformity mandatory for every packaging type. PFAS ban. Heavy metal limits. Minimisation obligations. Authorised representative mandatory for non-EU businesses.

Aug 18, 2026

Battery QR codes mandatory
All batteries must carry a QR code. For industrial batteries (>2 kWh) and EV batteries this links to the Digital Battery Passport from February 2027.

Sep 27, 2026

Stricter green claims rules
Vague environmental claims (‘eco-friendly’, ‘sustainable’, ‘planet-friendly’) prohibited unless substantiated. Eco-labels must meet defined criteria and be certified by an independent third party.

2027

Producer registers + refill rules
National producer registers must be operational in each EU member state. Mandatory refill options for takeaway packaging types.

Aug 12, 2028

Harmonised EU sorting pictograms mandatory
Standardised EU-wide material composition pictograms replace fragmented national labels. Same symbols appear on packaging and public waste bins across all 27 EU countries. Triman to be superseded (exact French transition date TBC).

2030

All packaging must be recyclable
Minimum recyclability grades enforced. Minimum recycled content targets for plastic packaging. EPR eco-fees modulated against recyclability grades.

Triman vs the future EU harmonised label

No other EU country has its own mandatory recycling symbol — France is the outlier here. The Triman has been compulsory since 2015, and it’s worked well. The problem is that in 2028 the EU is rolling out a single harmonised set of sorting pictograms for all 27 member states, and at that point France’s symbol becomes redundant. The exact cutover date hasn’t been published yet, but the direction of travel is clear.

Period

France requirement

EU PPWR requirement

Now to Aug 2026

Triman + Info-tri mandatory. Material codes mandatory.

PPWR not yet in force for labelling. Prepare DoC.

Aug 2026 to Aug 2028

Triman + Info-tri still mandatory. Material codes required.

DoC, chemical limits, minimisation in force. Commission publishes harmonised pictogram specs.

Aug 2028 onward

Transition to harmonised EU labels (exact date TBC by French authorities).

Mandatory EU-wide sorting pictograms. Same symbols across all 27 member states. One label for the whole EU.

The practical advice: if you’re reprinting packaging artwork anyway, leave room for both the Triman and the incoming EU pictogram. The Commission has until August 2026 to publish the harmonised specs, so you’ll have enough lead time to update designs before the 2028 deadline.

Action checklist — before the deadlines

Immediate priority

  • Complete EPR France registration with CITEO, Léko, or Adelphe — obtain your IDU number
  • Confirm Triman logo and Info-tri appear on every component reaching French consumers
  • Apply the correct recycling codes to all components — PAP, PET, ALU, and plastic codes
  • Request Declaration of Conformity documents from your packaging supplier for every packaging type
  • Audit food-contact packaging for PFAS; request heavy metal test certificates
  • Share your IDU with every French marketplace — Amazon, Zalando, and others require it
  • If based outside France, appoint an authorised representative now
  • Register separately for the professional packaging EPR stream if supplying B2B packaging in France

Near-Term (2026–2028)

  • Allocate QR code space in packaging artwork — mandatory for batteries from August 2026
  • Track EU harmonised pictogram specifications — expected publication August 2026
  • Keep household packaging and professional packaging data separate throughout the year
  • Submit annual EPR declaration to your PRO by 31 May each year

The EU Packaging and Packaging Waste Regulation (PPWR) is coming. Get your company PPWR-ready with our authorized representative service — so you’re ahead of the curve, not scrambling at the deadline.


Frequently asked questions

Yes, and this catches a lot of small businesses off guard. There's no minimum volume under French EPR law — send one parcel to one French address and the rules apply to you. EPR France registration has to be in place before you start selling into France, not after the fact. If your IDU is missing when a marketplace checks, you're looking at suspension. Non-compliance fines can reach €100,000.


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