France EPR 2026: Why Do Foreign Producers Need a French Authorized Representative?

7/15/20262 min read

If your company is based outside France but sells products covered by French Extended Producer Responsibility (EPR) schemes, a new requirement is now important to understand.
Since 10 July 2026, foreign producers subject to French EPR rules are required to appoint a France-based Authorized Representative (AR), also known as a Mandataire REP, by written mandate.
But what does this mean for your business?
What is a French EPR Authorized Representative?
A French EPR Authorized Representative is a natural or legal person established in France who acts on behalf of a producer that is not established in France.
Under the new French rules, the representative can take responsibility for the EPR obligations covered by the written mandate.
This is particularly relevant for international companies selling products directly to customers in France without having a French legal entity.
Who needs a French EPR Representative?
The requirement applies to producers established outside France who are subject to French EPR obligations.
Depending on the products they sell, this can include companies operating in areas such as:
  • Packaging and graphic paper
  • Batteries
  • Textiles and footwear
  • Tyres
  • Electrical and electronic equipment
  • Furniture
  • Toys
  • Sports and leisure products
  • DIY and garden products
  • Other French EPR categories
The exact compliance process can vary depending on the EPR category and the relevant Producer Responsibility Organisation (PRO).
Does having an EPR IDU mean you already have an Authorized Representative?
Not necessarily.
An IDU (Identifiant Unique) confirms that a producer is registered within the relevant French EPR system. It does not automatically mean that a France-based Authorized Representative has been appointed.
For foreign producers, these are separate aspects of EPR compliance that may need to be addressed:
EPR registration → IDU → PRO membership → reporting → eco-contributions → French Authorized Representative
Your existing EPR registration therefore does not necessarily remove the need to appoint a French AR.
What does the Authorized Representative do?
The exact responsibilities depend on the written mandate.
Depending on the scope of the service, a French EPR representative may assist with:
  • EPR registration and account management
  • Communication with French PROs
  • EPR declarations and reporting
  • Eco-contribution administration
  • EPR documentation
  • Ongoing compliance with French EPR requirements
The representative's responsibilities should always be clearly defined in the written mandate.
What should foreign producers do now?
If your company is established outside France and sells EPR-covered products in the French market, we recommend checking:
  1. Which French EPR schemes apply to your products?
  2. Do you already have the relevant French EPR registrations and IDUs?
  3. Do you have a France-based Authorized Representative?
  4. Is there a written mandate defining the representative's responsibilities?
  5. Are your EPR declarations and PRO obligations being properly managed?
The new French AR requirement does not replace your other EPR obligations. Instead, it adds another important element to the compliance structure for foreign producers.
Need a French EPR Authorized Representative?
LINK GREEN INTERNATIONAL is a France-based EPR compliance partner supporting international producers with their French EPR obligations.
We can assist with French EPR registration, IDU management, PRO communication, reporting and Authorized Representative (Mandataire REP) services for non-French producers.
If your company sells EPR-covered products in France but does not have a French entity, we can help you understand what needs to be done and manage the French EPR compliance process.

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