French EPR Mandataire: New Rules for Foreign Sellers

Law no. 2026-602 of 8 July 2026 created Article L541-10-9-1 of the French Environmental Code. The provision has been in force since 10 July 2026. It requires a person not established in France, when subject to French EPR under Articles L541-10 or L541-10-9, to designate a person or company established in France as mandataire by written mandate.

The official text is concise but significant. It states that the mandataire is subrogated into all EPR obligations covered by the mandate. This goes further than a consultant completing forms. The French representative legally assumes the accepted obligations.

You can read Article L541-10-9-1 on Légifrance and the published Law no. 2026-602 in the official French legal database.

The trigger is establishment outside France, not outside the EU. An EU company selling into France can therefore be in scope just like a company established in the United Kingdom, United States, China or another non-EU country.

The provision sits in the general EPR chapter and refers to the general producer and marketplace duties. It is not limited to fashion or textiles even though it was enacted through a law focused on the environmental impact of the textile industry.

A foreign company still needs to establish whether it is the producer for each French EPR scheme. Manufacturers, importers, distributors and distance sellers can be producers depending on how the product enters the French market.

The law contains one express exception. The appointment obligation is deemed satisfied for products whose French EPR obligations are already ensured by a person or company covered by Article L541-10-9 and established in France.

Article L541-10-9 concerns electronic interfaces such as marketplaces that facilitate distance sales or delivery for third parties. A marketplace can avoid taking on the producer duties only when it holds evidence that the third-party producer has already complied.

This exception should be tested product by product and sales flow by sales flow. The mere fact that goods are listed on a marketplace does not automatically prove that a France-established platform is carrying the EPR obligations.

The new article does not state that existing UINs or producer responsibility organisation memberships are cancelled. It changes who must stand behind the French EPR obligations. Foreign producers should therefore treat the change as a mandate and account-structure review, not as an instruction to discard valid registrations.

Operational procedures can vary between producer responsibility organisations and product streams. Confirm how the written mandate, membership authority, declarations and SYDEREP information must be updated for each scheme before assuming that an existing account is complete.

ADEME explains that a UIN is issued for one EPR scheme and provides proof of registration in SYDEREP. Its official UIN guidance remains the reference for obtaining and communicating French identifiers.

The French mandataire rule and the EU Packaging and Packaging Waste Regulation are separate obligations. The French rule has applied since 10 July 2026, concerns French EPR generally and uses establishment outside France as the trigger.

The PPWR generally applies from 12 August 2026 and concerns packaging. It requires EU-established cross-border distance sellers to appoint an EPR authorised representative in each relevant destination Member State. For producers established outside the EU, each Member State may decide whether representation is mandatory.

A business selling packaged products into France may therefore need to analyse both regimes. Compliance with the French rule does not remove country-specific PPWR duties elsewhere. Our PPWR 2026 guide explains the EU-wide changes.

The safest approach is to review the whole French EPR setup, because one business may hold several UINs across packaging, electronics, batteries, textiles and other schemes.

VAT EPR EXPERT FRANCE provides authorised representation in France alongside registration, UIN management and ongoing declarations. Contact our team with your company country, product categories and existing French identifiers for an initial gap review.