Do You Need a French EPR Authorized Representative for Packaging?

France Packaging EPR: Citeo, Léko and the French EPR Authorized Representative

For international companies selling products in France, Packaging EPR is often one of the first French EPR obligations they need to address.

Many companies already know that they need a French IDU and may already work with Citeo or Léko. But one question is becoming increasingly important:

If I already have a Packaging EPR IDU, am I fully compliant in France?

The answer is: not necessarily.

1. What Is Packaging EPR in France?

France’s Packaging EPR system requires producers, importers and certain e-commerce businesses to take responsibility for the environmental management of packaging placed on the French market.

For international companies, common types of packaging may include:

• Product packaging

• Cardboard and shipping boxes

• Plastic packaging

• Paper packaging

• Other materials used to package products

Therefore, even if a company is not established in France, selling products to French customers may create French Packaging EPR obligations.

2. What Are Citeo and Léko?

Citeo and Léko are two eco-organizations that companies may work with under the French Packaging EPR system.

Depending on the business model, products and applicable EPR scheme, companies need to determine the appropriate compliance solution.

Working with an eco-organization may involve:

• EPR registration

• Obtaining an IDU

• Packaging data reporting

• Environmental contributions

• Annual declarations and payments

• Ongoing EPR compliance management

However, joining Citeo or Léko does not automatically mean that all French EPR obligations have been fulfilled.

3. IDU and Authorized Representative Are Not the Same

This is one of the most common points of confusion for foreign companies.

An IDU (Identifiant Unique) is the unique identifier assigned to a producer registered under a French EPR scheme.

A French EPR Authorized Representative (AR) is a natural or legal person established in France and appointed by a foreign producer through a written mandate to take on the EPR obligations covered by that mandate.

Since 10 July 2026, French law requires producers established outside France and subject to French EPR obligations to appoint a France-based Authorized Representative.

In French legislation, this representative is referred to as a “mandataire REP.”

Therefore:

Having an IDU does not automatically mean that you have appointed an EPR Authorized Representative in France.

These are two separate compliance requirements that foreign producers should check.

4. I Already Have a Citeo or Léko IDU. Do I Still Need an Authorized Representative?

For companies established outside France, this is an important question to verify.

If your company:

• Is established outside France;

• Sells products to the French market;

• Is subject to French Packaging EPR; and

• Already has a Citeo or Léko IDU;

you should also check whether your existing EPR account meets the French Authorized Representative requirement.

This is particularly important for businesses selling through Amazon, Shopify, independent e-commerce stores or other cross-border sales channels.

Having an IDU alone should not be treated as confirmation that all French EPR requirements have been fulfilled.

5. How Can Foreign Companies Complete Packaging EPR Compliance?

Foreign producers can review their Packaging EPR compliance through the following steps:

Step 1: Identify your products and packaging

Prepare a list of the products sold in France and the types of packaging and materials used.

Step 2: Confirm your EPR obligations

Determine whether your business is subject to French Packaging EPR and whether other EPR categories also apply.

Step 3: Check your IDU

Review your existing Citeo, Léko or other relevant EPR registrations and IDUs.

Step 4: Check your Authorized Representative

If your company is not established in France, verify whether you have appointed a France-based EPR Authorized Representative through a written mandate.

Step 5: Maintain ongoing compliance

Continue to manage packaging data reporting, environmental contributions and other EPR obligations as required.

6. Don't Look Only at Whether You Have an IDU

For foreign companies, French EPR compliance is no longer simply about asking:

“Do I have an IDU?”

The more important question is:

“Are my EPR registration, reporting, environmental contributions and French Authorized Representative arrangements all properly in place?”

This becomes even more important when a company sells products covered by several EPR categories, such as packaging, electrical and electronic equipment, batteries or textiles.

Need a French EPR Authorized Representative?

LINK GREEN INTERNATIONAL is a France-based EPR compliance company supporting international businesses with their French EPR obligations.

Our services include:

• French Packaging EPR registration

• IDU application and management

• Communication with Citeo, Léko and other eco-organizations

• EPR data reporting

• Environmental contribution management

• French EPR Authorized Representative (AR) / Mandataire REP services

If you already have a French EPR IDU but are unsure whether you also need a French Authorized Representative, LINK GREEN INTERNATIONAL can help review your existing EPR setup and identify the requirements that apply to your business.