PPWR and French EPR: Key Differences and What Foreign Companies Need to Know

With the EU Packaging and Packaging Waste Regulation (PPWR) now applying, foreign companies selling packaged products in France and other EU markets are facing an important question:

What is the difference between PPWR and French EPR? If PPWR is an EU-wide regulation, do companies still need to comply with French Packaging EPR?

The short answer is:

PPWR and French EPR are closely related, but they are not the same.

PPWR sets EU-level rules for packaging, while French EPR applies specific producer responsibility requirements in France.

1. What Is PPWR?

PPWR (Packaging and Packaging Waste Regulation) is an EU regulation covering packaging and packaging waste across the European Union.

It addresses areas such as:

• Packaging design and recyclability;

• Recycled content;

• Packaging reduction;

• Reuse and refill;

• Packaging waste prevention and management;

• Producer responsibility related to packaging.

The regulation aims to create more harmonised packaging requirements across the EU.

PPWR entered into force on 11 February 2025 and has generally applied since 12 August 2026.

For foreign companies selling packaged products in Europe, PPWR is therefore an important part of EU packaging compliance.

2. What Is French EPR?

EPR (Extended Producer Responsibility) is a producer responsibility system implemented at national level in EU Member States.

In France, packaging is covered by REP Emballages (French Packaging EPR).

For companies placing packaged products on the French market, French Packaging EPR may involve:

• EPR registration;

• Obtaining an IDU (Unique Identification Number);

• Joining an approved éco-organisme / PRO;

• Reporting packaging data;

• Paying EPR fees or éco-contributions;

• Meeting French-specific EPR obligations.

Therefore, French EPR is not simply another name for PPWR.

It is the French national implementation of producer responsibility requirements that apply to relevant products placed on the French market.

3. What Is the Connection Between PPWR and French EPR?

PPWR and French EPR are connected because both concern packaging and packaging waste, but they operate at different levels.

A simple way to understand the relationship is:

PPWR
↓
EU-level packaging requirements
↓
Packaging design, recyclability, recycled content, reuse, etc.
↓
National Packaging EPR Systems
↓
France: REP Emballages
↓
Registration, reporting, IDU, eco-contributions, etc.

In simple terms:

PPWR sets the common EU framework for packaging, while French EPR establishes the producer responsibility obligations that apply in France.

4. PPWR vs French EPR: What Is the Difference?

The key point is:

PPWR compliance does not automatically mean that a company has completed its French EPR obligations.

Likewise, French EPR compliance does not automatically mean that all PPWR requirements have been met.

Foreign companies need to assess both.

5. Does PPWR Replace French Packaging EPR?

No. PPWR does not simply replace French Packaging EPR.

Even after PPWR becomes applicable, companies placing packaged products on the French market may still need to comply with REP Emballages and its related French requirements.

For example, a foreign company may need to determine:

• Whether its products are subject to French Packaging EPR;

• Whether it must register for French EPR;

• Whether it needs an IDU;

• Which French éco-organisme / PRO it should join;

• How packaging data must be reported;

• What EPR fees or eco-contributions apply;

• Whether a French EPR Authorized Representative (Mandataire REP) is required.

Therefore:

PPWR ≠ French EPR

and

PPWR + French EPR = two levels of packaging compliance that foreign companies need to consider.

6. Where Does the French EPR Authorized Representative Fit In?

The French EPR Authorized Representative (AR), or Mandataire REP, is not a replacement for PPWR or French EPR.

It is a compliance representation mechanism for eligible foreign producers that are subject to French EPR obligations.

For certain foreign companies not established in France, a French-established natural or legal person may need to be appointed to act as their Mandataire REP.

France introduced a broader legal framework for the Mandataire REP from 10 July 2026.

This means the three concepts can be understood as follows:

PPWR
→ EU packaging rules

French EPR / REP Emballages
→ French producer responsibility requirements

French EPR Authorized Representative / Mandataire REP
→ A representation mechanism that may apply to eligible foreign producers

They are related, but they are not interchangeable.

7. What Should Foreign Companies Do?

If your company sells packaged products in France, it is important to assess compliance from both the EU and French perspectives.

You should check:

1. Whether your packaging is subject to PPWR;

2. Whether your products are subject to French Packaging EPR;

3. Whether you need a French EPR registration and IDU;

4. Which éco-organisme / PRO applies to your business;

5. Your packaging reporting and eco-contribution obligations;

6. Whether you need a French EPR Authorized Representative / Mandataire REP.

Need Help With French EPR Compliance?

LINK GREEN INTERNATIONAL helps foreign companies manage their French EPR compliance, including:

• French EPR registration;

• IDU application and management;

• Eco-organism / PRO communication;

• EPR data reporting;

• EPR fee and eco-contribution management;

• French EPR Authorized Representative / Mandataire REP services.

If your company is selling packaged products in France or the EU and you are unsure about the relationship between PPWR and French EPR, LINK GREEN INTERNATIONAL can help you identify the requirements that apply to your business.