EPR Obligations EU → Authorized representative → 🇫🇷 France
Authorized Representative in France 2026:
The Mandataire Duty Explained
France goes further than the EU: since 10 July 2026 every producer subject to French EPR that is not established in France has to appoint a France-established representative, the mandataire — for all product streams, not only packaging.
Last reviewed: · Sources linked below
Short answer: if your company is not established in France and your products fall under French extended producer responsibility, you need a mandataire: a person or company established in France, appointed by written mandate. According to law-firm analyses and a French producer responsibility organisation, this has applied since 10 July 2026, to EU and non-EU companies alike and to all EPR streams. The duty is treated as met where a France-established marketplace handles your compliance.
Authorized representative in France at a glance
- Legal basis
- Art. L. 541-10-9-1 Code de l'environnement, inserted by Loi n° 2026-602 of 8 July 2026 (published in the Journal officiel on 9 July 2026).
- Applies since
- 10 July 2026.
- Who
- Every producer subject to EPR in France that is not established in France — companies from other EU member states and from outside the EU.
- Which products
- All EPR streams, not only packaging. France has around 20 EPR streams (filières REP).
- Form
- Written mandate; the mandataire must be established in France.
- Exception
- The duty is treated as met where a France-established marketplace handles compliance under Art. L. 541-10-9.
- Separate duty
- A unique identification number (UIN) per EPR stream, issued by ADEME via SYDEREP. The mandataire does not replace it.
- Implementing decree
- In our review, none had been published as of 3 November 2026.
Do I need a mandataire in France?
The test is simple: is your company established in France? If not, and your products fall under a French EPR stream, you need a mandataire. Unlike the EU packaging rule, the duty is not limited to direct sales to end users, and it applies whether or not your company sits in the EU.
| Your situation | Mandataire required? |
|---|---|
| Company established in France | No |
| Company in another EU member state (for example Germany, Poland, Italy) placing EPR products on the French market | Yes, since 10 July 2026 |
| Company outside the EU (for example China, UK, US) placing EPR products on the French market | Yes, since 10 July 2026 |
| You sell only through a France-established marketplace that handles EPR compliance for your products under Art. L. 541-10-9 | Duty treated as met. Check that the marketplace actually handles it for all your products and streams. |
| You sell through such a marketplace and through your own web shop | Check: the exception concerns the products for which the marketplace handles compliance. |
Not sure whether your products fall under a French EPR stream? Ask for a free check.
Why France goes further than the EU
The mandataire duty comes from a French law, not from Brussels. It was introduced by Loi n° 2026-602 of 8 July 2026 — the law on the environmental impact of the textile industry, often called the fast-fashion law — which inserted Art. L. 541-10-9-1 into the Code de l'environnement. According to the legal analyses we rely on, the article covers any person not established in France that is subject to EPR, across all streams.
The logic is the same as elsewhere: a party on French territory answers for the foreign producer's obligations towards the producer responsibility organisations (éco-organismes) and the authorities. France applies it across all streams — packaging, electrical equipment, batteries, textiles and the others — instead of product by product.
Mandataire and PPWR representative: the differences
The French duty and the EU packaging duty overlap, but they are not the same rule.
| French mandataire | PPWR authorized representative | |
|---|---|---|
| Legal basis | Art. L. 541-10-9-1 Code de l'environnement (national law) | Art. 45 of Regulation (EU) 2025/40 (EU law) |
| Applies since | 10 July 2026 | 12 August 2026 |
| Products | All EPR streams | Packaging |
| Who | Every producer subject to French EPR that is not established in France | Producers that sell packaged products directly to end users in another member state; for other non-EU producers, member states may require one |
| Marketplace | Duty treated as met where a France-established marketplace handles compliance | No comparable exception in the sources we reviewed |
The mandataire does not replace the UIN
Independently of the mandataire, every producer needs a unique identification number (identifiant unique, UIN) for each EPR stream. ADEME issues it via the SYDEREP register; it has been mandatory since 1 January 2022 and must appear in your general terms and conditions and on your website.
Marketplaces are affected directly: they count as the producer for third-party goods unless they hold proof of the seller's UIN. That is why marketplaces ask sellers for their French numbers.
Streams, UIN and labelling in full: EPR in France.
What happens without a mandataire
We do not quote a specific penalty for a missing mandataire: in our review, no implementing decree for the new article had been published as of 3 November 2026.
What is documented: according to ADEME, breaches of the UIN duty can be fined up to €30,000, plus a daily penalty of up to €20,000 per day. Marketplaces count as the producer for your goods unless they hold proof of your UIN, so they check: Amazon names France among its EU packaging EPR countries and says it "may need to stop selling your non-compliant products".
Would the proposed EU exemption remove the French duty?
That is open. The EU proposal concerns the representative duty in EU law. The French mandataire duty rests on French national law and covers all EPR streams. How the two would interact if the EU exemption is adopted has not been settled.
Proposal – not yet law EU exemption for small EU-established producers. The European Commission's Environmental Omnibus of 10 December 2025 proposes suspending the authorized-representative duty for producers established in the EU. The European Parliament adopted its position on 20 October 2026 (as reported: an exemption for EU micro and small enterprises until 2035). The Council's negotiating mandate of 21 October 2026 covers packaging only: EU-established producers placing less than 1 tonne of packaging per year in another member state would not need a representative there until 1 January 2032. It does not cover batteries. Trilogue negotiations follow. None of this is law yet, and none of it helps sellers established outside the EU — until a final text is adopted, the current duty applies.
Dates that matter for France
| Date | What applies |
|---|---|
| 1 Jan 2022 | UIN mandatory for each EPR stream |
| 1 Jan 2026 | EPR stream for professional (industrial and commercial) packaging started |
| 10 Jul 2026 | Mandataire duty for producers not established in France |
| 12 Aug 2026 | PPWR applies: authorized representative for packaging distance sellers (Art. 45) |
| 20–21 Oct 2026 | Parliament and Council positions on the EU exemption; trilogue next Proposal – not yet law |
| 12 Feb 2027 | Member states must have PPWR penalty rules in place |
Full calendar: EPR deadlines 2026–2027.
How Certify helps
- Free obligation check. Tell us what you sell into France, through which channels (Amazon, eBay, your own shop) and where your company is established. We tell you which representative duties apply to you — and which do not.
- Registration and representation. Certify prepares the registrations and, where the law requires it, acts as your authorized representative. Certify offers an authorized representative in all EU member states.
- Ongoing compliance. Certify supports the recurring declarations and reports, so your registration numbers stay valid for marketplaces and authorities.
This page explains the obligation. If you already know that you need a representative, the practical steps are on our sister site: appointing an EPR authorized representative (register-epr.com).
FAQ: authorized representative (mandataire) in France
Who needs a mandataire in France?
Every producer that is subject to extended producer responsibility in France and is not established in France. According to law-firm analyses, the duty follows from Art. L. 541-10-9-1 of the Code de l'environnement and has applied since 10 July 2026.
Does the mandataire duty apply to companies from other EU countries?
Yes. The duty applies to producers not established in France, whether they are established in another EU member state or outside the EU.
Is the mandataire only required for packaging?
No. The duty covers all French EPR streams. France has around 20 of them, including packaging, electrical equipment, batteries and textiles.
I only sell through a marketplace. Do I still need a mandataire?
The duty is treated as met where a France-established marketplace handles EPR compliance for you under Art. L. 541-10-9. Check that the marketplace actually handles it for all your products and streams.
Does the mandataire replace the UIN?
No. Each EPR stream still needs its own unique identification number, issued by ADEME via the SYDEREP register. The UIN has been mandatory since 1 January 2022 and must appear in the general terms and conditions and on the website.
Would the proposed EU exemption for small producers remove the French mandataire duty?
That is open. The exemption under negotiation concerns the representative duty in EU law and is not law yet. The French mandataire duty rests on French national law and covers all EPR streams.
- Légifrance: Loi n° 2026-602 du 8 juillet 2026 (Journal officiel)
- Gossement Avocats: analysis of Loi n° 2026-602
- Léko: mandataire duty for producers established outside France
- ADEME: unique identification number (UIN)
- EUR-Lex: Regulation (EU) 2025/40 (PPWR), Art. 45
- Council of the EU: negotiating mandate of 21 October 2026 (document 14765/26)
- Amazon Global Selling: EU packaging EPR notice (25 March 2026)
This page is general information, not legal advice. Last reviewed 5 November 2026.
Related guides
Representative rules differ from country to country and from product to product:
Check whether you need a mandataire in France
Tell us what you sell to French customers and where your company is established. You receive a structured answer on which EPR streams, which UINs and which mandate apply to you. Your message is delivered directly to Certify — specialists in EU-wide producer responsibility compliance. Free first consultation, no obligation.