Your clients selling into France now need a French Authorised Representative.
Since 10 July 2026, every producer subject to French EPR and not established in France must, in principle, appoint a representative established in France under a written mandate. Every EPR stream. EU sellers included.
If you provide EPR services without a French entity, you cannot act as that representative yourself. J&P Accountants has an establishment in France and acts as French Authorised Representative for your clients.
Selling into France yourself? The same service is available direct, through the same call.
Date | What happens |
8 July 2026 | Law 2026-602 enacted, published in the Journal officiel on 9 July. |
10 July 2026 | The obligation applies. No transition period has been announced. |
21 July 2026 | Léko sets out the steps for producers based outside France. The other eco-organisations are following. |
12 Aug 2026 | Separately, the EU PPWR starts to apply, with its own packaging representative rules. It does not replace the French duty. |
Not a countdown: the obligation is already live.
What changed
Passed as a fast-fashion law, it reaches every EPR stream.
Article 5 of Law 2026-602 created Article L541-10-9-1 of the French Environmental Code. It sits in the general EPR chapter, not in the textile rules.
For sellers outside the EU, it works much like the fiscal representative many of them already appoint for French VAT. The difference is that the EPR rule also covers sellers established elsewhere in the EU.
A French representative is now mandatory
Until now, most foreign sellers joined the eco-organisations directly and a local representative was optional. A written mandate with a representative established in France is now a legal requirement.
Every EPR stream is covered
Household and professional packaging, electrical and electronic equipment, batteries, furniture and the other EPR streams are all concerned.
Being in the EU is not enough
The rule covers every producer not established in France, whether it is based in Germany, the UK, China or the US.
Foreign marketplaces are in scope
Platforms not established in France that facilitate third-party sales and carry EPR duties for those products must also designate a representative.
The representative carries the liability
The representative is legally subrogated into the obligations it accepts. Choose an established French firm able to carry them, not a letterbox.
One narrow exception
Products whose French EPR obligations are already fully handled by an online marketplace established in France need no separate representative. That cover only applies to sales made through that marketplace.
Already paying Citeo or Léko? Membership is no longer enough.
Your clients’ registrations and French IDU are not cancelled, but a written mandate with a French representative must now sit behind them, and each membership has to be re-signed by that representative.
Who is affected
In principle, every foreign seller in the French EPR system.
| You are | What it means for you |
| An EPR service provider without a French entity | Every client not established in France is caught by the rule, and you cannot act as their representative yourself. Bundling a French representative into your service keeps your clients trading in France. |
| A non-EU seller already registered in France | Your registrations and IDU stay valid, but your setup must be updated: written mandate signed, transmitted to each eco-organisation, membership re-signed by the representative. |
| An EU-established seller selling into France | You are newly captured. Being established elsewhere in the EU does not exempt you from the French rule. |
| A marketplace or platform not established in France | If you carry EPR duties for third-party sales, you must designate your own French representative. You are also liable for the EPR obligations of any seller without a valid IDU. |
Not affected: producers established in France, and products already fully covered by a marketplace established in France, for sales made through that marketplace.
How to get compliant
Five steps, and we handle them with you.
01
Identify
Choose a representative established in France.
02
Mandate
Sign the written mandate. One contract can cover several streams.
03
Transmit
Send the mandate to each eco-organisation concerned.
04
Re-sign the membership
The representative re-signs the membership contract.
05
SYDEREP
The scheme updates the registration data on SYDEREP, the platform dedicated to EPR.
Path as described by Léko in its notice of 21 July 2026. The other eco-organisations follow the same logic; exact mechanics are confirmed with each scheme.
What J&P does
One provider for your clients’ French EPR, 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.
For EPR service providers and platforms
Add a French representative to your service.
If you provide EPR services without a French entity, J&P acts as French Authorised Representative for your clients. You sign J&P’s mandate on their behalf, under the authority they have already given you.
J&P can act for platforms too, with one contact across every stream they carry.
- Transfer of existing accounts included
- Terms built around your client volumes, set out on the call
- One contact for all your clients and streams
CHECKLIST
What each client needs in place since 10 July 2026.
For a client not established in France, a compliant French EPR setup has five parts:
01
Streams
A clear view of which EPR streams the client sells into France.
02
Mandate
A written mandate with a representative established in France.
03
Transmission
The mandate sent to each of the client’s eco-organisations.
04
Membership
Each membership re-signed by the representative.
05
SYDEREP
The client’s registration data updated with the representative.
The one exception: a client that sells into France only through a marketplace established in France that fully covers its EPR obligations. That cover only applies to sales made through that marketplace, so a client also selling on its own website still needs a representative.
Not sure which of these your clients have? Our gap audit reviews their French registrations and memberships and lists which streams still need a mandate. We then put the rest in place with you.
Questions we hear every week.
Can an EPR service provider act as the 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.
Is this only for fast-fashion or textile companies?
No. The textile law was only the vehicle. Article L541-10-9-1 sits in the general EPR chapter of the French Environmental Code and covers every EPR stream and, in principle, every producer not established in France.
My client already pays Citeo or Léko and has a French IDU. Is it compliant?
Its registrations and IDU are not cancelled, but its setup must be updated: a written mandate with a representative established in France, transmitted to each eco-organisation, membership re-signed by the representative and SYDEREP updated by the scheme.
My client is established in another EU country. Does the rule apply?
Yes. The French rule covers every producer not established in France, inside or outside the EU.
My client sells through marketplaces. Is that enough?
Only in part. A marketplace is liable for a seller’s EPR obligations when the seller has no valid IDU, and the platform does not choose whether to cover them. Its cover, and any fee it charges, only applies to sales made through that marketplace. A valid IDU covers every sale into France.
Who does what in French EPR?
ADEME is the government agency in charge of extended producer responsibility in France. SYDEREP is the platform dedicated to EPR. Eco-organisations such as Citeo and Léko are accredited to collect contributions for each EPR stream. The authorised representative acts as the intermediary between the eco-organisations and the producer.
How does this relate to the EU PPWR?
It is separate and came first. The French rule has applied since 10 July 2026 and covers all streams. The PPWR packaging representative rules apply from 12 August 2026, and EU simplification proposals may still change them. Complying with one does not dispense you from the other. Our guide to the EU PPWR covers the packaging side.
What happens if my 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.
Get your clients' French representative in place.
20 minutes to review your clients’ setup and tell you exactly which streams need a mandate.
We are always happy to hear from you!
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