French EPR Authorised Representative: New 2026 Rules

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 authorised representative by written mandate.

The official text is concise but significant. It states that the authorised representative 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.

Short answer for a producer that already holds French UINs: keep them. Nothing in Article L541-10-9-1 cancels an existing registration or an eco-organisation membership. The rule adds an authorised representative established in France who accepts, by written mandate, the obligations listed in it; the scheme records and the SYDEREP producer record are then updated to show that mandate.

What changes is who must stand behind the French EPR obligations. Treat the rule 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.

Before the intake, confirm which identifiers are actually held. The UIN checker reads the public ADEME register, and the UIN and IDU guide explains how an identifier is matched to the producer entity and displayed.

A representation file for a producer that already holds French registrations is short when these seven items arrive together. A missing item is the usual reason a mandate stalls, because the authorised representative cannot accept obligations it cannot see.

Article L541-10-9-1 subrogates the authorised representative into the EPR obligations for which it accepts the mandate. The mandate therefore defines the scope, and a mandate that only names an address settles nothing. Agree each line below for each stream before signature and keep the evidence column with the mandate.

Three roles are regularly confused in intake calls. The French EPR authorised representative is the person or company established in France that, by written mandate under Article L541-10-9-1, accepts the producer's EPR obligations. It is a French role, agreed stream by stream.

The registration is separate: membership of an eco-organisation or an approved individual system, entry in SYDEREP and the UIN issued for each stream. The authorised representative does not replace it and does not hold the identifier in its own name; the identifier stays attached to the producer's registration, as the registration guide for foreign sellers explains.

Product-safety representation is a third thing. Since 13 December 2024 the EU General Product Safety Regulation requires an economic operator established in the Union to be responsible for each consumer product placed on the market (Article 16), and harmonised products have the equivalent rule in Regulation (EU) 2019/1020. That responsible person deals with product safety and market surveillance, not with EPR declarations or eco-contributions. One provider may hold both roles, but one mandate does not create the other.

The French authorised representative 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.