Passed as a fast fashion law, France’s latest EPR law reaches every EPR stream. Since 10 July 2026, a producer that sells into France without being established there must, in principle, appoint a representative established in France under a written mandate.
If you provide EPR services to online sellers and have no French entity, many of your clients are now caught by this rule, and you cannot act as their representative yourself.
J&P Accountants has an establishment in France and acts as French Authorised Representative, alongside its wider EPR compliance support.
What Law 2026-602 Changed
Law no. 2026-602 of 8 July 2026 is known as the French “fast fashion” law. Most of its provisions target ultra fast fashion, but Article 5 did something much broader. It created Article L541-10-9-1 of the French Environmental Code, in the general chapter on Extended Producer Responsibility. It sits in the general EPR chapter, not in the textile rules.
Under that article, every producer subject to French EPR and not established in France must appoint, by written mandate, a representative established in France to carry its EPR obligations.
Until now, most foreign sellers joined the eco-organisations directly and a local representative was optional. It is now a legal requirement.
For sellers outside the EU, the idea will be familiar. French VAT already requires many of them to appoint a fiscal representative in France, and French EPR now requires an authorised representative in France in the same way. The difference is that the EPR rule also covers sellers established elsewhere in the EU.
This is not a countdown. The obligation has applied since 10 July 2026, and no transition period has been announced.
Key Dates for the French Representative Rule
| Date | What happens |
|---|---|
| 8 July 2026 | Law 2026-602 is enacted. It is published in the Journal Officiel on 9 July. |
| 10 July 2026 | The representative obligation applies. |
| 21 July 2026 | Léko sets out the steps for producers based outside France. The other eco-organisations are following. |
| 12 August 2026 | Separately, the EU Packaging and Packaging Waste Regulation (PPWR) starts to apply, with its own representative rules for packaging. It does not replace the French duty. |
Which of Your Clients Are Affected
In principle, every client not established in France. In EPR terms, a producer is any company that first places a product on the French market: manufacturers, importers and online sellers alike.
- Every EPR stream. Household and professional packaging, electrical and electronic equipment, batteries, furniture and the other EPR streams are all concerned.
- EU and UK clients too. Being established in Germany, the UK, China, the US or anywhere else outside France is not enough.
- Clients already registered. Their registrations and French IDU are not cancelled, but their setup must be updated.
There is one narrow exception. Products whose French EPR obligations are already fully handled by an online marketplace established in France need no separate representative. Producers established in France are not affected.
Why EPR Service Providers Without a French Entity Are Exposed
Only a business established in France can act as the representative. If your company is based elsewhere, you cannot sign the mandate for your clients as their representative, however well you know their EPR setup.
The representative is also legally subrogated into the obligations it accepts, so eco-organisations and the French authorities expect a real French firm, not a letterbox address.
That leaves your clients needing a French representative that you cannot provide on your own.
The Opportunity for EPR Service Providers
Every affected client needs a written mandate with a representative established in France. A provider that can arrange one keeps that client’s French EPR work in one place.
There are two ways to offer it: set up a French entity, or work with a representative already established in France. Working with one adds the service to your offer without building a French operation.
Bundling a French representative into your service keeps your clients trading in France.
How J&P Supports EPR Service Providers
J&P Accountants has an establishment in France and handles the French side for your clients, as one provider with the representative included.
- French Authorised Representative: written mandates drafted to meet Article L541-10-9-1, covering every stream your clients are in.
- You sign for your clients: you sign J&P’s mandate on your clients’ behalf, under the authority they have already given you.
- End to end paperwork: mandate transmission to each eco-organisation, re-signing of the membership, and follow-up until each scheme completes the SYDEREP update.
- Gap audit: we review your clients’ French registrations and memberships and list which streams still need a mandate.
- Everything else in one place: registration support, IDU management, declarations and eco-contribution invoices, handled by the same team.
Is a Citeo or Léko Membership Still Enough?
No, not on its own. Paying an eco-organisation and holding a French IDU no longer satisfies the rule. A written mandate with a representative established in France must now sit behind the membership, and the membership contract is re-signed by that representative.
The stakes are real. The representative is legally subrogated into the obligations it accepts, meaning the producer’s French EPR duties transfer to it. Serious representatives will check their clients, and each one needs to be genuinely established in France and able to carry those obligations, not a letterbox.
Who Does What in French EPR
These are the parties your clients deal with in French EPR.
| Who | What they do |
|---|---|
| ADEME | The government agency in charge of extended producer responsibility in France. |
| SYDEREP | The platform dedicated to EPR, where each producer’s registration data is held. |
| Eco-organisations | Companies such as Citeo and Léko, accredited to collect contributions for each EPR stream (filière). |
| Authorised representative (mandataire) | A service provider that acts as the intermediary between the eco-organisations and the producer. Since July 2026, every producer not established in France must, in principle, appoint one established in France. |
How to Comply: The Five Step Path
Léko described the path in its notice of 21 July 2026. The other schemes follow the same logic, and exact mechanics are confirmed with each scheme.
- Identify: choose a representative established in France.
- Mandate: sign the written mandate. One contract can cover several streams.
- Transmit: send the mandate to each eco-organisation concerned.
- Re-sign the membership: the representative re-signs the membership contract.
- SYDEREP: the scheme updates the producer’s registration data on SYDEREP, the platform dedicated to EPR.
Checklist: Is Your Client’s French EPR Setup Still Compliant?
Run through these with each client selling into France.
- The client knows whether it is established in France, and which EPR streams it sells into France.
- It has a written mandate with a representative established in France.
- The mandate has been transmitted to each of its eco-organisations.
- The representative has re-signed the membership contract.
- SYDEREP has been updated with the representative.
- Or: it sells into France only through a marketplace established in France that fully covers its EPR obligations.
If any of these is missing, the client’s French EPR setup no longer meets the rule.
What the Rule Means for Marketplaces and Platforms
A platform that is not established in France, facilitates third party sales and carries EPR duties for those products must designate its own French representative.
A marketplace becomes liable for a seller’s EPR obligations when that seller does not hold a valid IDU. The platform does not choose whether to cover them, and it cannot charge a seller that holds a valid IDU a fee for covering its EPR obligations.
Marketplace cover is also narrower than an IDU. A valid IDU covers all of a producer’s sales into France, while the fee a marketplace charges only covers the sales made through that marketplace. For a seller on several marketplaces, its own IDU is the only thing that covers every sale.
J&P can act as French Authorised Representative for platforms too, with one contact across every stream they carry.
How the Rule Fits With the AGEC Law and the EU PPWR
The rule sits inside the EPR framework France rebuilt under the AGEC anti waste law of 2020, which introduced the unique identification number (IDU) and made marketplaces liable for the EPR obligations of any seller without a valid IDU. The new law adds a French representative on top of that framework.
The PPWR is a separate EU regime covering packaging only. It applies from 12 August 2026, with its own representative rules that EU simplification proposals may still change.
France moved first and further: the French rule covers every stream. Complying with one does not dispense you from the other. Our guide to the EU PPWR covers the packaging side.
What Happens If Your Clients Do Nothing?
Unless their products are already fully covered by a marketplace established in France, they fall out of French EPR compliance, and the authorities now expect a French entity they can hold accountable.
Each affected client needs a French representative, whether arranged through you or found elsewhere.
Quick Answers for EPR Service Providers
Can an EPR service provider act as a French representative?
Only if it is established in France. If it is not, it can work with a representative established in France, such as J&P, and sign that representative’s mandate on its clients’ behalf, under the authority they have already given it.
What does “subrogated” mean for my clients?
The representative takes on the French EPR obligations it accepts under the mandate. That is why it must be genuinely established in France and able to carry them.
Does one mandate cover all of a client’s EPR streams?
One written mandate can cover several streams. It still has to be sent to each eco-organisation the client belongs to.
What is SYDEREP?
SYDEREP is the platform dedicated to EPR in France, under ADEME, the government agency in charge of extended producer responsibility. Once the representative is in place, the eco-organisation updates the producer’s record there.
Offer Your Clients a French Representative
J&P Accountants acts as French Authorised Representative for your clients and handles the whole chain with you. In 20 minutes, we review your clients’ setup and tell you exactly which streams need a mandate.
- A written mandate drafted to meet Article L541-10-9-1, covering every stream your clients are in
- Transmission to each eco-organisation, re-signing of the membership and SYDEREP follow-up
- You sign J&P’s mandate on your clients’ behalf, under the authority they have already given you
Selling into France yourself? The same service is available direct, through the same call.
