French EPR for online sellers: unique identifiers, the Triman logo and the 2026 mandataire rule

How French EPR works

France organises extended producer responsibility (responsabilité élargie du producteur, REP) into separate streams by product category. Each stream is run by state-approved eco-organisations (éco-organismes). A producer joins the eco-organisation for its category, declares the quantities it places on the French market and pays eco-contributions. Once the eco-organisation records the producer in ADEME’s SYDEREP register, the producer receives a unique identifier (identifiant unique, IDU) for that category.

• One IDU per category. Selling clothing and shipping it in boxes means two IDUs.
• The IDU must appear in your general terms of sale, other contract documents or on your website (Code de l’environnement L.541-10-13).
• A missing IDU can be fined up to €30,000.

Categories that affect online stores

Eco-organisations are approved for fixed periods and the list changes. Check the current approvals when you sign up.

The 2026 rule: a French authorised representative

Law no. 2026-602 of 8 July 2026, titled as a law on the environmental impact of the textile industry but covering every REP category, added Article L.541-10-9-1 to the Environmental Code. A company not established in France that has REP obligations must appoint, in writing, an authorised representative (mandataire) established in France, which takes over all of its REP obligations.

The obligation is treated as met where an operator established in France, such as a marketplace, already fulfils it for the product. A store selling directly to French consumers has no such operator and needs its own representative.

Public reporting dates the rule from 10 July 2026; we could not open the official Légifrance text directly to confirm the date.

Marketplace sellers versus your own store

Since 2022, online marketplaces must check sellers’ IDUs and declare and pay on their behalf when a seller has none (L.541-10-9). That only covers sales made through the marketplace. Sales from your own store to French consumers are yours to declare, through your representative.

Steps

1. List everything you sell into France and map it to REP categories. Nearly every seller has packaging.
2. Appoint a French authorised representative in writing.
3. Join the eco-organisation for each category and declare quantities each year.
4. Publish each category’s IDU in your terms of sale or product information.
5. Add the Triman logo and sorting instructions (Info-tri) to products or packaging.
6. Declare quantities and pay eco-contributions as each eco-organisation requires.

The Triman logo and Info-tri

Household products in a REP stream must carry the Triman logo together with sorting instructions (Info-tri) on the product, its packaging or accompanying documents (L.541-9-3). Companies face fines of up to €15,000 for breaches (L.541-9-4). For toys and DIY products the requirement has applied since 6 December 2023.

Penalties

Failing to meet REP obligations can lead to administrative fines of up to €7,500 per unit or per tonne, daily penalties of up to €20,000, and fines of up to €30,000 in specific cases such as a missing IDU (L.541-9-5).