France
Extended producer responsibility (EPR) for packaging in France
France embedded EPR for household packaging into the Environmental Code as early as 1992 (Arts. L541-10 & R543-42), then overhauled it through the 2020 Anti-Waste & Circular-Economy Act (AGEC) and the new 2024 Packaging Order. From 1 January 2025 its scope widens to industrial & commercial (B2B) packaging, making EPR France the broadest scheme in Europe. Oversight sits with the Agence de la transition écologique (ADEME); day-to-day compliance runs through approved producer-responsibility organisations (PROs) such as Citeo, Adelphe and Léko.Who must register packaging EPR in France
ny entity that first places packaging on the French market—regardless of location—must comply, including:
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French manufacturers/packers
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Importers or intra-EU acquirers
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Marketplace or distance-selling companies with no French establishment (via an authorised representative)
What the package includes
All household and, from 2025, professional packaging of every material:- paper/cardboard
- plastics (PET, HDPE, films, bioplastics)
- glass, metals (steel, aluminium)
- wood
- composites
- “other” materials
Threshold
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No de-minimis for registration – a single pack triggers EPR registration France
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Reuse & eco-design duties apply only when you exceed 10 000 units / year and €10 million turnover (AGEC Art. 72)
Mandatory Triman label for EPR products in France
If your product falls under French EPR regulations, it must display the Triman logo. This label informs consumers about sorting and recycling requirements, and failure to include it may result in penalties.
An example of what a label looks like on packaging for France
This box includes standard packaging labeling elements used across the EU as part of EPR (Extended Producer Responsibility) requirements.
On this example, we can see the PAP 20 recycling code.
However, paper packaging materials may also be labeled under other PAP categories, such as PAP 21 or PAP 22, depending on the type of cardboard or paper used.
PAP 20 — Corrugated cardboard
The PAP 20 recycling code indicates that the packaging is made of corrugated fibreboard (commonly used for shipping boxes) and should be disposed of as paper packaging.
📎 Download the official label for PAP 20:
PAP 21 — Non-corrugated cardboard
The PAP 21 code is used for non-corrugated fibreboard, such as folding cartons and product boxes.
📎 Download the official label for PAP 21 :
PAP 22 — Paper
The PAP 22 code is used for paper-based packaging materials, such as paper bags, wrapping paper, and paper inserts.
📎 Download the official label for PAP 22 :
Triman logo — Mandatory in France
The Triman symbol is an mandatory label in France showing that the packaging must be sorted and recycled through the national EPR system.
📎Download the Triman Logo from Lappa:
Triman + Info-tri sorting instruction
In France, producers must also display an Info-tri label (sorting guidance) next to the Triman logo to help consumers dispose of packaging correctly.
📎Download the Triman+Info-tri
EPR registration procedure in France
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Choose an approved PRO (Citeo covers >95 % of market). Sign the membership contract and pay the one-off joining fee
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The PRO transmits your data to ADEME, which issues the Unique Identification Number (UID) you must display on invoices, websites and general terms
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Declare annual packaging weights by material via the PRO portal and pay eco-contributions (tarifs 2025 just published)
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Keep all weight calculations, invoices and proof of payment for six years for ADEME audits
Authorized representative
A non-French producer that sells packaged goods directly to French end-users must appoint an autorité mandataire established in France (Art. R541-174). The AR signs the PRO contract, receives the UID, files declarations and pays fees—ensuring full ADEME EPR compliance.Never miss reporting deadline
Annual declaration of packaging placed on market (year N-1) is due to your PRO by 28 February. Late filing incurs default surcharges and can block your UID renewal.Who assumes responsibility
France – allocation of responsibility (text format)
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French manufacturers / packers bear full responsibility for their packaging from the moment a product is first placed on the French market
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Importers / distributors assume full liability at customs clearance or intra-EU arrival—unless an upstream licence already covers the packaging
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Foreign distance sellers become liable—through a French-based authorised representative—when they make a direct B2C sale to a customer in France
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Producer Responsibility Organisations (e.g., Citeo, Léko) handle the operational tasks of collection, recycling and mandatory data transfer
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ADEME / DGPR oversee enforcement and registry functions: issuing UIDs, conducting audits and imposing fines for non-compliance
Duties of each group
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Producers / importers: obtain UID, join a PRO, pay eco-contributions, file annual data, display the Triman logo & sorting info, draft a five-year prevention/eco-design plan (if >10 000 units)
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Authorised representative: hold French SIREN, keep mandate on file, submit declarations & payments, act as contact during ADEME inspections
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PROs: finance nationwide collection, meet material-specific recycling targets (65 % overall today, 70 % by 2030), audit member data, and transmit statistics to ADEME
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ADEME / DGPR: approve PROs, run the SYDEREP database, publish compliant-producer lists, and levy fines up to €100 000 plus daily penalties for non-compliance (Env. Code L541-9-5)