# /news-insights/france-epr-agec-citeo-refashion-uin-marketplace-sellers-2026  —  France EPR for marketplace sellers in 2026: AGEC, Citeo, Refashion and the UIN every seller needs
# https://o1.eu/news-insights/france-epr-agec-citeo-refashion-uin-marketplace-sellers-2026
# Operator One — Merchant of Record for European marketplaces.

## Metadata
- Canonical URL: https://o1.eu/news-insights/france-epr-agec-citeo-refashion-uin-marketplace-sellers-2026
- Published: 2026-06-14
- Updated: 2026-09-13
- Publisher: Operator One (https://o1.eu)

## Summary
France's AGEC EPR regime needs one ADEME UIN per scheme, and since 10 July 2026 every producer not established in France must appoint a mandataire.

## Full article
By Operator One Editorial — 2026-06-14

## Key takeaways

- ADEME issues a French EPR unique identifier (UIN, or IDU) to a producer for a single scheme, so a producer holds one UIN per scheme its products fall under. The count includes packaging, so a battery-powered device sold in household packaging needs three: electrical and electronic equipment, batteries, and household packaging and graphic papers.
- Since 10 July 2026, Article L541-10-9-1 of the French Code de l'environnement (created by Law n° 2026-602 of 8 July 2026) requires every EPR producer not established in France, whether in the EU or outside it, to appoint a mandataire established in France by written mandate.
- Under Article L541-10-9 of the Code de l'environnement, a marketplace selling EPR products for third-party sellers in France must record each seller's ADEME identifier in a register or take over that seller's EPR obligations itself.
- Under Article L541-9-5 of the Code de l'environnement, the French environment minister can impose a fine of up to 7,500 euros per unit or tonne, a daily penalty of up to 20,000 euros and a supplementary fine of up to 30,000 euros.
- French household packaging has three approved eco-organismes (Adelphe, Citeo and Léko, until 31 December 2029). Batteries have three (ecosystem, Batribox and Recycler Mon Véhicule, until 31 December 2030). Textiles have only Refashion (until 31 December 2028).
- Regulation (EU) 2025/40 (PPWR) applies from 12 August 2026. It requires packaging producers to register in each member state, and producers selling directly to end users in another member state must appoint an authorised representative there.

France runs one of the most extensive Extended Producer Responsibility (EPR) regimes in the European Union. ADEME, the French ecological transition agency, lists 19 EPR schemes ("filières"). If you sell physical goods to French consumers through Amazon.fr, Cdiscount, Fnac, ManoMano, Zalando or any other platform, the AGEC law (Loi anti-gaspillage pour une économie circulaire) and the Code de l'environnement can make you the producer for the products and packaging you place on the French market. That status brings registration duties, declaration duties, contributions to an approved eco-organisme, and a unique identifier that the marketplace needs.

This guide is written for sellers who already operate cross-border in the EU and want a clean picture of what France requires in 2026, scheme by scheme, including the changes made by French Law n° 2026-602 of 8 July 2026 and by the EU Packaging and Packaging Waste Regulation.

## What AGEC changed, and why marketplaces care

For a marketplace seller, the AGEC reform of French EPR matters in three ways:

- It applies the producer obligation to whoever places EPR products on the French market, including sellers based abroad who ship directly to French consumers.
- It created new EPR schemes on top of the existing ones. Examples are sports and leisure articles (Ecologic accredited from 31 January 2022), DIY and garden articles (from 24 February 2022), toys (Ecomaison accredited from 21 April 2022), building products and professional packaging.
- It put a verification duty on marketplaces. Under Article L541-10-9 of the Code de l'environnement, in force since 1 January 2022, a marketplace that facilitates distance sales of EPR products for a third-party seller is exempt from those EPR obligations only if it holds proof that the seller has complied. That proof is recorded in a register referred to in Article R541-167. The French ministry's FAQ states that an ADEME-issued unique identifier satisfies the proof requirement. If the seller cannot provide it, the marketplace must fulfil the EPR obligation in the seller's place, including joining an eco-organisme and paying the eco-contribution.

The practical result: in France, EPR is not only a back-office tax exercise. In Operator One's experience, the large French marketplaces ask for the relevant identifiers before or shortly after a listing goes live. They may also invoice the eco-contribution themselves where a seller cannot show one.

## The schemes, and which eco-organismes are approved for each

France splits EPR into product schemes, each served by one or more eco-organismes approved by the State. A multi-category brand typically touches several schemes at once. The table below reflects the accreditations published by ADEME as of September 2026.

| French EPR scheme | Approved eco-organismes | Accreditation period |
| Household packaging and graphic papers (EMPAP) | Adelphe, Citeo, Léko | 1 January 2025 to 31 December 2029 |
| Textiles, household linen and footwear (TLC) | Refashion (sole approved body) | 1 January 2023 to 31 December 2028 |
| Batteries (BAT) | ecosystem and Batribox (categories 1 to 5); Recycler Mon Véhicule (category 5, electric vehicle batteries, only) | 18 August 2025 to 31 December 2030 |
| Electrical and electronic equipment (EEE), household | ecosystem, Ecologic; Soren (category 7, photovoltaic panels, only) | Until 31 December 2027 |
| Furnishing (EA) | Ecomaison, Valdelia, Valobat | 1 January 2024 to 31 December 2029 |
| Toys (JOUET) | Ecomaison | 21 April 2022 to 31 December 2027 |
| Sports and leisure articles (ASL) | Ecologic | 31 January 2022 to 31 December 2027 |
| DIY and garden articles (ABJ) | EcoDDS (painting and decorating tools), Ecologic (combustion-engine machines), Ecomaison and Valobat (DIY goods, garden products and equipment) | From 24 February 2022 (Ecomaison from 21 April 2022, Valobat from 1 January 2024) to 31 December 2027 |
| Chemical products (PCHIM) | EcoDDS (categories 3 to 10), Pyreo (pyrotechnics), Ecopae (fire extinguishers) | Until 31 December 2027 |
| Professional packaging (EPRO) | Citeo Pro (catering packaging, since March 2024); Citeo Pro, Leko Pro and Twiice for all professional packaging from 1 January 2027 | New accreditations granted 5 June 2026, for 2026 to 2031 |

A few points the table does not show:

- Household packaging is not a Citeo monopoly. Adelphe, Citeo and Léko are all approved for French household packaging and graphic papers until 31 December 2029, with OCAPEM as the coordinating body. A seller chooses one.
- The French batteries scheme changed in 2025. According to ADEME, Corepile and ecosystem merged in summer 2025, and the approved bodies are now ecosystem, Batribox and Recycler Mon Véhicule. Since 18 August 2025 the scheme has covered five battery categories, aligned with Regulation (EU) 2023/1542. A product containing a battery, such as a Bluetooth speaker, an electric toothbrush or a toy with a built-in cell, falls under the batteries scheme separately from WEEE or toys.
- Textiles are Refashion only. Refashion is the single approved French eco-organisme for clothing, household linen and footwear until 31 December 2028.
- Other French schemes exist. ADEME's 19 schemes also include building products, lubricants, tyres, vehicles, sport and recreational boats, single-use sanitary textiles, tobacco, medical devices and unused medicines. Check each one against your catalogue.

A mid-market apparel brand selling lounge sets in a branded mailer to French consumers therefore contributes to Refashion for the garment and to Adelphe, Citeo or Léko for the mailer and tissue paper. If the box also contains a battery-powered accessory, it contributes to the batteries scheme and the EEE scheme too.

### Textiles: the ultra fast fashion penalty from 1 September 2026

French Law n° 2026-602 of 8 July 2026 on the environmental impact of the textile industry adds penalties to the eco-modulation of textile products linked to ultra fast fashion practices. The penalty ranges from 0.25 to 12 euros per product in 2026 and rises each year to 2 to 20 euros per product from 2030. This part of the law applies from 1 September 2026. On the producer's reasoned request, the eco-organisme must cap the penalty at 50% of the product's pre-tax sale price. The same law bans advertising for ultra fast fashion products from 1 January 2027.

## The Identifiant Unique (UIN), and why marketplaces ask for it

ADEME runs SYDEREP, the declaration system for French EPR schemes. When a producer joins an approved eco-organisme, that eco-organisme registers the producer in SYDEREP and passes on the unique identifier (identifiant unique, IDU, often written UIN in English). ADEME states that the identifier has been mandatory since 2022 and proves that the producer is registered for that scheme. ADEME cites Article L541-10-13 of the Code de l'environnement as the legal basis for the identifier, and publishes the list of registered producers and their identifiers as open data.

Two operational points matter:

- You get one UIN per scheme, not one per company. ADEME issues each identifier for a single scheme, so a producer holds as many as there are schemes covering its products. A consumer-electronics seller typically holds three: household packaging, EEE and batteries. They are not interchangeable.
- The UIN is what the marketplace records. Under Article L541-10-9 and the register required by Article R541-167, the marketplace keeps each third-party seller's ADEME identifier for the product categories it sells, including packaging. If the seller is not itself the producer, the French ministry's FAQ says the seller's supplier must provide the identifier on request (Article L541-10-10).

In practice this means the EPR registration calendar drives the listing calendar. A seller that has not yet received its household packaging identifier is not ready to launch in France.

## Producers not established in France: the mandataire and the PPWR representative

Since 10 July 2026, Article L541-10-9-1 of the Code de l'environnement has applied to every EPR producer not established in France. It was created by Article 5 of Law n° 2026-602 of 8 July 2026, published in the Journal officiel on 9 July 2026. The producer must designate, by written mandate, a natural or legal person established in France as its mandataire. The mandataire is subrogated into all the EPR obligations covered by the mandate it accepts.

This rule covers producers established in other EU member states as well as UK, US, Swiss and Asian brands. The earlier idea that only non-EU brands need a French representative is no longer correct.

Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation (PPWR), adds an EU-level layer from 12 August 2026 (Article 71). Article 44 requires packaging producers to register in the national producer register of each member state where they first make packaging or packaged products available. Article 45(3) requires a producer, whether established in a member state or in a third country, that makes packaging or packaged products available directly to end users in another member state to appoint, by written mandate, an authorised representative for extended producer responsibility there. Member states may also require producers established in third countries to appoint one whenever they first make packaging or packaged products available on their territory. Under Article 44(1), each member state must set up its national register within 18 months of the entry into force of the Commission's first implementing act on registration. Under Article 45(4), online platforms must obtain producers' registration details before letting them offer packaged products to EU consumers. PPWR does not replace French eco-organisme membership or the French UIN.

## Triman and info-tri labelling

French Decree n° 2021-835 of 29 June 2021 implements the sorting-information rule. Products placed on the market for household use and subject to a French EPR scheme must carry the Triman logo and the "info-tri" sorting instructions. Glass beverage packaging is exempt. The sorting instructions are drawn up by the eco-organismes, so a product can meet its contribution obligations and still breach French labelling rules if the packaging artwork is not updated.

## What happens if you skip a scheme

The cost of French EPR non-compliance sits in three layers:

- Marketplace action. Under Article L541-10-9, a marketplace that cannot record a valid identifier must take over the seller's EPR obligations. Platforms therefore either request the identifier, restrict the listing or charge the eco-contribution. The exact response depends on each platform's own terms.
- Administrative sanctions. Under Article L541-9-5 of the Code de l'environnement, sanctions are imposed by the French environment minister, not by ADEME, and follow a formal notice that goes unanswered. They include an administrative fine of up to 7,500 euros per unit or per tonne of product and a daily penalty of up to 20,000 euros until the breach is remedied. A supplementary fine of up to 30,000 euros applies for failing to register in SYDEREP, supplying incorrect data, or omitting the unique identifier where it must appear.
- Scheme-specific penalties. For textiles linked to ultra fast fashion practices, Law n° 2026-602 adds penalties per product of 0.25 to 12 euros in 2026, rising to 2 to 20 euros from 2030.

In Operator One's experience, the schemes sellers most often overlook are batteries (because the battery is built into another product), toys, and DIY and garden goods. The last two have been separate French EPR schemes since 2022.

## How to register for French EPR, step by step

- Map your products to French schemes. Check every product, accessory, embedded battery and packaging element against ADEME's 19 EPR schemes before building listings.
- Appoint a French mandataire if you are not established in France. Since 10 July 2026, Article L541-10-9-1 of the Code de l'environnement requires a written mandate to a person established in France, for EU and non-EU producers alike.
- Join an approved eco-organisme for each scheme. For example, choose Adelphe, Citeo or Léko for household packaging, Refashion for textiles, ecosystem or Batribox for batteries, and ecosystem or Ecologic for electrical and electronic equipment.
- Obtain one unique identifier per scheme. The eco-organisme registers you in ADEME's SYDEREP system and passes on the identifier (UIN) for that scheme.
- Give the identifiers to each marketplace and update packaging. Enter every applicable UIN in each platform's compliance settings, and add the Triman logo and info-tri instructions required by Decree n° 2021-835.
- Declare quantities and pay contributions. Report quantities placed on the French market to each eco-organisme on its contract schedule, and complete PPWR producer registration under Regulation (EU) 2025/40 once the national register is live.

## Frequently asked questions

### Do I need a UIN to sell to French consumers through a marketplace?

Yes, in practice. Under Article L541-10-9 of the French Code de l'environnement, a marketplace that facilitates sales of EPR products for a third-party seller must either record that seller's ADEME unique identifier in a register or take over the seller's EPR obligations itself. Taking over means joining an eco-organisme and paying the contributions. The French ministry's FAQ states that an ADEME-issued identifier is what proves the seller's compliance.

### How many UINs does one company need in France?

One per EPR scheme, not one per company. ADEME issues each unique identifier for a single French scheme, so a producer holds as many identifiers as there are schemes covering its products. ADEME counts packaging too, so a battery-powered device sold in household packaging falls under electrical and electronic equipment, batteries, and household packaging and graphic papers. That means three separate identifiers, which are not interchangeable on marketplaces.

### Does an EU company need a French mandataire for EPR?

Yes, since 10 July 2026. Article 5 of French Law n° 2026-602 of 8 July 2026 created Article L541-10-9-1 of the Code de l'environnement. Any person not established in France who is subject to extended producer responsibility must designate, by written mandate, a person established in France as mandataire. The mandataire is subrogated into the EPR obligations it accepts. The rule covers EU and non-EU producers alike.

### What is the fine for not complying with EPR in France?

Under Article L541-9-5 of the French Code de l'environnement, the environment minister can act after a formal notice goes unanswered. The minister can impose an administrative fine of up to 7,500 euros per unit or per tonne of product and a daily penalty of up to 20,000 euros. A supplementary fine of up to 30,000 euros applies for failing to register in ADEME's SYDEREP register, supplying incorrect data or omitting the unique identifier.

### Which eco-organisme covers packaging and textiles in France?

French household packaging and graphic papers can go through Adelphe, Citeo or Léko, all accredited from 1 January 2025 to 31 December 2029. Clothing, household linen and footwear go through Refashion, the only approved French textiles eco-organisme, accredited until 31 December 2028. A garment shipped in a branded mailer therefore triggers two separate French EPR registrations and two identifiers.

### Which French EPR schemes are easy to overlook?

Batteries, toys, and DIY and garden goods. A battery built into a speaker or toy falls under the French batteries scheme separately from WEEE. That scheme runs through ecosystem, Batribox or, for electric vehicle batteries only, Recycler Mon Véhicule, all approved from 18 August 2025 to 31 December 2030. Toys have their own scheme through Ecomaison (since April 2022). DIY and garden goods go through EcoDDS, Ecologic, Ecomaison or Valobat.

### Does PPWR replace French EPR registration in 2026?

No. Regulation (EU) 2025/40 (PPWR) applies from 12 August 2026, but extended producer responsibility stays national. Article 44 requires packaging producers to register in each member state where they first make packaging available. Article 45(3) requires producers selling directly to end users in another member state to appoint an authorised representative there. In France you still join Adelphe, Citeo or Léko and hold a French UIN.

### Who carries French EPR obligations when a Merchant of Record is the seller?

In France, EPR obligations sit with the party that places the products on the French market, and a marketplace relies on that seller's ADEME identifier. When a Merchant of Record sells the goods in its own name, it carries the EPR producer obligations for those sales and needs identifiers in its own name. A Merchant of Record not established in France must also appoint a French mandataire under Article L541-10-9-1.

## Where a Merchant of Record carries the obligation

When Operator One acts as Merchant of Record (https://o1.eu/merchant-of-record), it is the legal seller to the French consumer. Where it imports the goods into the EU, it is also the EU importer. For those sales, Operator One is the party placing the goods on the French market, so the French EPR obligations and unique identifiers for those sales sit with Operator One's own legal entity. Listings show the client as the brand and Operator One as the seller.

French EPR registrations are per scheme and do not transfer between legal entities. A brand that also sells into France through its own entity keeps its own registrations for those sales. Where a market requires a locally established representative, Operator One commonly arranges one as part of onboarding, though not in every market. CE marking, the conformity assessment, the technical file and the EU Declaration of Conformity remain with the manufacturer. Working definitions of each scheme are kept in the compliance glossary (https://o1.eu/compliance-glossary).

Sources: Law n° 2026-602 of 8 July 2026 (Légifrance) (https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000054399113); Law n° 2026-602 consolidated text (AIDA, INERIS) (https://aida.ineris.fr/reglementation/loi-ndeg-2026-602-080726-visant-a-reduire-limpact-environnemental-lindustrie-textile); Article L541-10-9, Code de l'environnement (https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000031052684/); French ministry FAQ on marketplaces and Article L541-10-9 (https://www.ecologie.gouv.fr/sites/default/files/documents/FAQ%20place%20de%20march%C3%A9%20L541-10-9_anglais.pdf); French ministry, general EPR framework and sanctions (https://www.ecologie.gouv.fr/politiques-publiques/cadre-general-filieres-responsabilite-elargie-producteurs); ADEME, unique identifier (IDU) (https://filieres-rep.ademe.fr/en/identifiant-unique); ADEME, household packaging scheme (https://filieres-rep.ademe.fr/en/filieres-REP/filiere-EMPAP); ADEME, batteries scheme (https://filieres-rep.ademe.fr/en/filieres-REP/filiere-BAT); ADEME, textiles scheme (https://filieres-rep.ademe.fr/en/filieres-REP/filiere-TLC); ADEME, list of French EPR schemes (https://filieres-rep.ademe.fr/en/filieres-REP); Decree n° 2021-835 of 29 June 2021 (Triman and info-tri) (https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000043714227); Regulation (EU) 2025/40 (PPWR), EUR-Lex (https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng).

## FAQ (structured)
Q: Do I need a UIN to sell to French consumers through a marketplace?
A: Yes, in practice. Under Article L541-10-9 of the French Code de l'environnement, a marketplace that facilitates sales of EPR products for a third-party seller must either record that seller's ADEME unique identifier in a register or take over the seller's EPR obligations itself. Taking over means joining an eco-organisme and paying the contributions. The French ministry's FAQ states that an ADEME-issued identifier is what proves the seller's compliance.

Q: How many UINs does one company need in France?
A: One per EPR scheme, not one per company. ADEME issues each unique identifier for a single French scheme, so a producer holds as many identifiers as there are schemes covering its products. ADEME counts packaging too, so a battery-powered device sold in household packaging falls under electrical and electronic equipment, batteries, and household packaging and graphic papers. That means three separate identifiers, which are not interchangeable on marketplaces.

Q: Does an EU company need a French mandataire for EPR?
A: Yes, since 10 July 2026. Article 5 of French Law n° 2026-602 of 8 July 2026 created Article L541-10-9-1 of the Code de l'environnement. Any person not established in France who is subject to extended producer responsibility must designate, by written mandate, a person established in France as mandataire. The mandataire is subrogated into the EPR obligations it accepts. The rule covers EU and non-EU producers alike.

Q: What is the fine for not complying with EPR in France?
A: Under Article L541-9-5 of the French Code de l'environnement, the environment minister can act after a formal notice goes unanswered. The minister can impose an administrative fine of up to 7,500 euros per unit or per tonne of product and a daily penalty of up to 20,000 euros. A supplementary fine of up to 30,000 euros applies for failing to register in ADEME's SYDEREP register, supplying incorrect data or omitting the unique identifier.

Q: Which eco-organisme covers packaging and textiles in France?
A: French household packaging and graphic papers can go through Adelphe, Citeo or Léko, all accredited from 1 January 2025 to 31 December 2029. Clothing, household linen and footwear go through Refashion, the only approved French textiles eco-organisme, accredited until 31 December 2028. A garment shipped in a branded mailer therefore triggers two separate French EPR registrations and two identifiers.

Q: Which French EPR schemes are easy to overlook?
A: Batteries, toys, and DIY and garden goods. A battery built into a speaker or toy falls under the French batteries scheme separately from WEEE. That scheme runs through ecosystem, Batribox or, for electric vehicle batteries only, Recycler Mon Véhicule, all approved from 18 August 2025 to 31 December 2030. Toys have their own scheme through Ecomaison (since April 2022). DIY and garden goods go through EcoDDS, Ecologic, Ecomaison or Valobat.

Q: Does PPWR replace French EPR registration in 2026?
A: No. Regulation (EU) 2025/40 (PPWR) applies from 12 August 2026, but extended producer responsibility stays national. Article 44 requires packaging producers to register in each member state where they first make packaging available. Article 45(3) requires producers selling directly to end users in another member state to appoint an authorised representative there. In France you still join Adelphe, Citeo or Léko and hold a French UIN.

Q: Who carries French EPR obligations when a Merchant of Record is the seller?
A: In France, EPR obligations sit with the party that places the products on the French market, and a marketplace relies on that seller's ADEME identifier. When a Merchant of Record sells the goods in its own name, it carries the EPR producer obligations for those sales and needs identifiers in its own name. A Merchant of Record not established in France must also appoint a French mandataire under Article L541-10-9-1.

## Steps (structured)
1. Map your products to French schemes: Check every product, accessory, embedded battery and packaging element against ADEME's 19 EPR schemes before building listings.
2. Appoint a French mandataire if you are not established in France: Since 10 July 2026, Article L541-10-9-1 of the Code de l'environnement requires a written mandate to a person established in France, for EU and non-EU producers alike.
3. Join an approved eco-organisme for each scheme: For example, choose Adelphe, Citeo or Léko for household packaging, Refashion for textiles, ecosystem or Batribox for batteries, and ecosystem or Ecologic for electrical and electronic equipment.
4. Obtain one unique identifier per scheme: The eco-organisme registers you in ADEME's SYDEREP system and passes on the identifier (UIN) for that scheme.
5. Give the identifiers to each marketplace and update packaging: Enter every applicable UIN in each platform's compliance settings, and add the Triman logo and info-tri instructions required by Decree n° 2021-835.
6. Declare quantities and pay contributions: Report quantities placed on the French market to each eco-organisme on its contract schedule, and complete PPWR producer registration under Regulation (EU) 2025/40 once the national register is live.