France EPR
What is France Packaging EPR
France Packaging EPR (“Responsabilité Élargie du Producteur”) is a legal framework under French environmental law requiring companies that place packaged products on the French market to finance the collection, sorting, and recycling of packaging waste. The system is overseen by public authorities and implemented through approved Producer Responsibility Organizations (PROs).
Does this apply to e-commerce & online sales?
Yes. Packaging EPR fully applies to e-commerce and online sales. Companies selling packaged goods online to customers in France are considered to be placing packaging on the French market, regardless of where the company is established or from where goods are shipped.
Who is the “producer” under France Packaging EPR?
The “producer” is the entity that first places packaged products on the French market. This is typically the manufacturer established in France, the importer, or a foreign distance seller selling directly to French customers. Manufacturing the product is not required to be considered the producer.
Who must register for Packaging EPR in France
Any company that places packaged products on the French market must comply with Packaging EPR registration obligations. This includes French companies, EU and non-EU exporters, online retailers, importers, and distance sellers selling directly to France. Businesses that fall within scope can use Lappa's EPR registration service to manage registrations across multiple European markets.
France Packaging EPR registration threshold
EPR packaging thresholds in Europe and France does not provide a general exemption threshold for packaging EPR. All companies placing packaging on the French market are subject to the obligation, regardless of volume, although simplified reporting options may exist for very small producers.
Register online
EPR and PPWR for France
Two separate legal frameworks govern packaging in France, and they run on different tracks. The national system—anchored in the AGEC Law—requires producers to register with an eco-organisme (typically Citeo), pay fees based on packaging weight and material type, and participate in France's collection and recycling infrastructure. That system has existed for years and will continue unchanged.Usage of EPR and PPWR compliance software from Lappa can make a compliance my easier
PPWR compliance is something else entirely. It's a performance mandate: packaging must be designed to recycle, cannot contain harmful substances above specific thresholds, must incorporate recycled materials, and must be labeled in a standardised way across the EU. PPWR doesn't care which eco-organisme you use or what fees you pay. It only cares whether your packaging works in a circular economy.
The tension emerges because France's historical approach treats recovery broadly—reuse matters as much as recycling, incineration with energy recovery counts, even landfill diversion gets credit. PPWR narrows that lens. From 2030 onward, recycling becomes the dominant pathway. Packaging designed to burn in an incinerator won't face the same fee benefits it once did; it may eventually be prohibited outright. Companies need to anticipate this gradual reorientation, not just react when rules change.
Non-resident producers must hire a French-based representative to handle eco-organisme relationships. This is a national requirement that predates PPWR and persists. PPWR formalizes it EU-wide from August 2026, but France already enforced it.
PPWR Labels for France
France currently mandates the Triman logo—a black triangular arrow—on all consumer packaging, accompanied by "Info-Tri" sorting instructions. This has been required since 2022 and violations cost up to €30,000. The placement rules depend on package size; larger items get prominent placement, smaller ones follow scaled rules.
Starting 12 August 2028, PPWR imposes a completely different labeling regime: harmonised EU pictograms that show what material the packaging is made from, whether it's recyclable, and how much recycled content it contains. These are not Triman; they're a fresh EU system.Get a Fee Quote for Lappa for PPWR services.
For roughly two years (2028–2030), packaging will likely need both: Triman to stay compliant with French national law, plus PPWR pictograms to meet EU requirements. This is administratively messy and drives up design and printing costs. The European Commission is suing France over Triman, claiming it restricts cross-border trade. If the Commission wins, Triman could disappear, which would simplify things—but that outcome remains uncertain. Businesses should design for both until clarity emerges.
For a broader overview of the upcoming EU system, see our guide to PPWR labelling requirements
PPWR Product Rules for France
Four concrete rules take effect between now and 2030, each with operational bite.
Immediate (August 2026): Packaging inks, coatings, and barrier layers cannot exceed 25–250 ppb of PFAS (per- and polyfluoroalkyl substances), depending on the specific chemical and application. This catches many food-contact surfaces, water-repellent finishes, and grease-resistant treatments. A single non-compliant batch shuts you out of the French market.
January 2030: Packaging must be engineered to actually recycle in French sorting facilities. That means material choice, adhesive compatibility, label removability, and closure design all matter. A beautiful design that contaminates the recycling stream fails PPWR. Proof comes via technical testing or third-party certification against PPWR's criteria—something most suppliers have not yet done.
January 2030: Plastic packaging must be at least 30% recycled content; paper/cardboard 90%; glass 40%; aluminium 50%. These are non-negotiable minimums. The recycled material must be traceable. It's not enough to claim you're using scrap; you need documentation proving origin.
January 2030: Oversized packaging gets scrutinised. Air-filled boxes, excessive padding, and non-functional material face enforcement. There's no universal formula yet—thresholds vary by product category—but the intent is clear: use what you need, nothing more. ADEME (France's environment agency) is publishing category-specific guidance, but early compliance requires engagement with suppliers and design teams now.
Packaging covered (and excluded)
Covered packaging includes primary packaging, secondary packaging, tertiary/shipping packaging, household packaging, and commercial/industrial packaging. Excluded packaging may include packaging that does not reach the French market or packaging already declared by another obligated party upstream.
Producer Responsibility Organization (PRO)
Producers must comply with Packaging EPR obligations by joining an approved Producer Responsibility Organization (PRO) or, in rare cases, by establishing an individual compliance system. In France, producers must join an approved PRO, such as:
- CITEO (main household packaging PRO)
- LEKO (alternative compliance scheme)
- Adelphe (for wines/spirits)
PROs manage reporting, fee collection, and recycling obligations on behalf of producers.
Packaging EPR registration in France
Registration generally involves identifying producer obligations, joining a PRO, obtaining a membership number, registering in national databases if required, and submitting regular packaging declarations.
Authorized representative
Foreign producers selling directly into France may appoint an authorized representative to handle registration, reporting, and communication with authorities and PROs. The appointment of a representative does not transfer legal responsibility away from the producer.
What data must be reported
Producers must report packaging data requirements to be placed on the French market, including sales units, packaging weight, material breakdown, household versus commercial classification, and information on reuse if applicable.
First reporting period
The first reporting period usually corresponds to the first calendar year in which the company places packaging on the French market. In many cases, previous periods must be declared before access to future reporting periods is granted.
Packaging EPR reporting deadlines
Reporting deadlines are set by PROs and national rules, typically requiring annual declarations in the year following the reporting period.
Labels & marketing claims
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.
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
PAP 20 — Corrugated Cardboard
PAP 20 is the material identification code for corrugated cardboard packaging (e.g. shipping boxes). It indicates that the packaging is made primarily of paper fibers and should be sorted for paper/cardboard recycling. 📎 Download the PAP 20 symbol from Lappa:
Eco-fees & eco-modulation
Eco-fees are calculated based on packaging weight, material type, and recyclability. France applies eco-modulation mechanisms that reward recyclable packaging and penalize disruptive materials. You can estimate potential compliance costs using the EPR fee calculator For registration and ongoing compliance costs, see our EPR pricing overview.
Risks, penalties & common mistakes
Non-compliance may result in administrative fines, contract termination by PROs, or market surveillance actions. Common mistakes include incorrect material classification, underreporting packaging, or missing reporting periods.
What e-commerce sellers should do now
E-commerce sellers should confirm their producer status, register for Packaging EPR, collect packaging data, submit required declarations, and ensure labeling compliance.
Easy to use EPR Software to calculate Eco-fee
FAQ
- Do I need EPR if I sell from abroad?
Frequently asked questions typically relate to producer identification, inclusion of shipping packaging, reporting methods, and treatment of small volumes.
Yes, if you sell directly to France.
- Can I declare detailed even if small?
Yes, detailed is always allowed.
- Must I declare shipping boxes?
Yes, e-commerce shipping packaging is included.
- Do I need to declare 2024 before 2025?
Often yes — LEKO commonly requires prior-year completion.