France's professional packaging EPR: are you affected in 2027?

A stretch-wrapped pallet arriving at a warehouse carries at least 3 packaging items: the pallet itself, the stretch film that holds the load and the grouping cartons. Until now, the company that discards the packaging has paid for its end of life through its waste collection contract. From 1 January 2027, part of that cost shifts to the companies that place the packaging on the market.

Companies have known of the principle since France's Anti-Waste and Circular Economy Act of 2020 (the AGEC law), but after 2 postponements many have stopped following the scheme. The start date has now been set at 1 January 2027, and ADEME (the French Agency for Ecological Transition) asks companies to join a producer responsibility organisation (PRO, éco-organisme in French) before 31 December 2026.

1How professional packaging EPR works, and how its start date has moved

Extended producer responsibility (EPR, REP in French) rests on a simple principle: whoever places a product on the market finances its end of life. It does so by paying an EPR fee (éco-contribution) to a PRO, an organisation approved by the State that organises or supports collection, sorting and recycling. The system has existed since the early 1990s for household packaging, and more than twenty EPR schemes now operate in France, covering everything from textiles and bedding (in French) to furniture and electrical equipment.

The AGEC law of 2020 extended this principle to professional (B2B) packaging, also called industrial and commercial packaging. This is a change of scale: according to the French Ministry of Ecological Transition, the volume is around 7 million tonnes a year, more than half of the packaging discarded in France.

Who pays whom

The money does not follow the packaging: the producer pays the PRO, which passes on support payments to the collection and sorting operators, and the waste holder (the company that discards its packaging) has those payments deducted from its collection bill, provided it sorts at source. There is therefore no free take-back: the collection bill goes down but remains payable.

2 postponements and a new start date

The law provided for a start on 1 January 2025, and the implementing texts then moved it to 1 July 2026. At the end of June 2026, the government announced a further postponement, before setting 1 January 2027 in a press release of 28 July. The ministerial order that confirms this date was put out for consultation in August and had still not been published in the Journal officiel (the French official gazette) as of 6 October 2026, but Citeo Pro has already published its 2027 fee schedule on that basis. Since June 2026, 3 PROs have been approved: Citeo Pro, Léko Pro and Twiice.

2Professional or household packaging: anything that is not household is professional

Any packaging that is not household packaging is professional packaging, meaning packaging that does not end up in a private individual's bin. A ministerial order of December 2025 expressly places the following in this category:

• Pallets and everything used to palletise a load: stretch film, strapping, top covers and layer pads.
• Large containers: big bags, bulk containers, drums, jerrycans, cans and buckets of more than 29 litres, crates of more than 15 litres.
• Transport and grouped packaging that travels between businesses, such as delivery cartons sent to shops.
• Packaging for products reserved for professionals, whatever its size, and point-of-sale advertising that serves as packaging.

Cases that catch companies out

Most mistakes come down to 3 situations. An e-commerce parcel delivered to a private individual is household packaging, even if it looks like a transport carton. A service packaging item filled at the point of sale, such as a tray at a deli counter, is household packaging too. Conversely, catering has been covered by an EPR scheme since 2023: its packaging falls under Citeo Pro, the only PRO approved for this scope.

Reusable packaging does not pay on each rotation but only once, when it is first placed on the market. The large rental pallet pools (Euro Pool System, International Pallet Pool and La Palette Rouge) have also been approved as individual compliance schemes and handle the end of life of their own pallet fleets.

What stays outside the scheme

A few types of packaging are excluded because they are already covered by another EPR scheme or an earlier agreement: packaging for oils, for certain chemical products, for construction products and materials and for agricultural supplies. Packaging for other hazardous products remains in scope, with a specific rate.

3Who pays the EPR fee: the producer, which is not necessarily the packaging manufacturer

The legislation refers to the producer, a misleading term because it does not necessarily mean the company that makes the packaging. The rule depends on the type of packaging:

• For sales and grouped packaging, it is the company that packs its products or has them made under its brand, including retailers' own brands.
• For transport and service packaging, it is in principle whoever manufactures, imports or distributes the packaging.
• An importer is a producer for what it brings onto French territory, unless it is the end user.
• A micro-business that buys its packaging from a supplier established in France is exempt, as explained in our article for micro-businesses.

Take a manufacturer of fasteners that sells its products in 5 kg cartons to industrial customers, delivered on stretch-wrapped pallets: the cartons are its sales packaging and it declares them. For the pallet and the film, Citeo Pro's guide to its 2027 fee schedule defines the producer of transport packaging as the company that first makes the packaging available in France. If the manufacturer buys pallets and film from a supplier established in France, in principle that supplier declares them; if it imports them itself, the manufacturer does. This is the first question to settle with your PRO, before even discussing fees.

If you sell in France from another country, there is one more requirement: since July 2026, you must appoint an authorised representative established in France to carry your EPR obligations on French territory. In addition, the Packaging and Packaging Waste Regulation (PPWR) has made EPR mandatory for all packaging in every EU country since 12 August 2026, with a national register of producers in each, as explained in our article on the companies affected by the PPWR.

4How much professional packaging EPR costs, and why plastic drives the bill

Citeo Pro published its 2027 fee schedule on 5 October 2026, ahead of the start on 1 January. It is the scheme's first annual fee schedule (barème) and is markedly higher than the schedule for the second half of 2026, which was published for a start on 1 July and then lapsed with the postponement. Per tonne of packaging placed on the market, excl. VAT:

• Plastic: €281.84 per tonne, against €217.90 in the schedule for the second half of 2026, an increase of nearly 30%.
• Paper and cardboard: €35.47 per tonne, against €34.70 in the second half of 2026.
• Wood and cork: €9 per tonne; steel: €8.90; aluminium and other materials (glass, ceramics, stoneware): €8.
• Small volumes: for up to 4 tonnes a year, a flat annual fee of €240 excl. VAT replaces the calculation by weight, and no tonnage has to be declared. It follows the flat fee of €125 excl. VAT for 2 tonnes or less in the second half of 2026.

The Citeo Pro 2027 fee guide adds a minimum invoice of €240 excl. VAT, payable even if the calculation by weight comes to less. New reusable packaging benefits from a 50% bonus on its fee, and reused packaging on later rotations is exempt, provided it can be shown that it contributed when first made available. As of 6 October 2026, Léko Pro and Twiice had not published a 2027 fee schedule: their schedules for the second half of 2026 were close to Citeo Pro's, with Léko Pro at around €218 per tonne of plastic, but nothing guarantees that the gap will stay the same in 2027.

Consider an SME that places 12 tonnes of cardboard and 3 tonnes of plastic film on the market. At the 2027 Citeo Pro rates it will pay around €1,270 excl. VAT per year: €426 for the cardboard (12 × €35.47) and €846 for the plastic (3 × €281.84). At the rates for the second half of 2026, the same bill over a full year would have been around €1,070. Plastic accounts for 20% of the tonnage and about two thirds of the bill, so that is where the savings lie: reduction, a change of material, use of recycled plastic or reuse.

Beyond the fee, the scheme sets targets that will shape future fee schedules: in 2030, 85% recycling for paper and cardboard, 55% for plastic and 30% for wood. The PPWR adds a reuse target: from 2030, transport packaging exchanged between 2 sites of the same group, or delivered to another company in France, must be reusable. Article 29 of the regulation excludes cardboard boxes, packaging for dangerous goods, made-to-measure packaging for large machinery or equipment and flexible formats in direct contact with food or animal feed from this target; these exclusions are detailed in our article on reuse targets.

Our article on packaging eco-design sets out the levers within a broader eco-design approach.

5What to do before 1 January 2027, from tonnage estimates to PRO membership

ADEME asks the companies in scope to join before 31 December 2026. The timetable is short, especially if your tonnage data is not ready; our PPWR support can take on these steps.

• List your professional packaging and estimate your 2026 tonnages by material: plastic, paper and cardboard, wood, metal. Your suppliers' data sheets and your packaging purchases are enough for a first estimate. If you have carried out a Bilan Carbone® assessment (the French carbon accounting method), these purchases normally already appear in its scope 3 (in French).
• Settle who the producer is for each type of packaging, in particular for pallets and transport film.
• Choose a PRO from Citeo Pro, Léko Pro and Twiice. Compare their 2027 fee schedules (Citeo Pro's is published, those of Léko Pro and Twiice are awaited), their flat fees for small volumes and their services.
• Join and obtain your unique identifier (identifiant unique, or IDU, also known as unique identification number or UIN) from ADEME, then show this EPR registration number in your general terms and conditions of sale (CGV in French) and on your website.
• Prepare the first declaration, expected in early 2027 on the basis of your estimated volumes, and organise sorting at source on your own sites to benefit from the support payments.

Twiice reports longer lead times for obtaining the unique identifier because of the influx of applications: it is better not to wait until December. If you import packaged products or sell from abroad, our EPR authorised representative checker tells you in 3 questions whether an appointment is also required.

6What you risk by doing nothing: penalties and commercial pressure

The French Environmental Code provides for heavy administrative penalties for a producer that does not meet its EPR obligations: a fine of up to €7,500 per tonne of packaging for a company, a periodic penalty payment of up to €20,000 per day, and up to a further €30,000 where there is no unique identifier or no entry in the register.

The most immediate risk is commercial: large customers will ask for your unique identifier in their tenders and contracts, to make sure they are not carrying your obligation; public buyers, who already score bids on the environmental criterion (in French), will follow. Online marketplaces are liable for the EPR obligations of the sellers they host when those sellers are not compliant, and already block accounts without an identifier. At European level, the PPWR makes registration in the register of producers a condition of placing on the market in each country.

7Key takeaways

• The scheme starts on 1 January 2027, with 3 approved PROs: Citeo Pro, Léko Pro and Twiice.
• Any packaging that is not household packaging is professional packaging: pallets, films, large containers, transport packaging and packaging for products reserved for professionals.
• The producer pays: the brand owner for its sales packaging; for transport packaging, the manufacturer, importer or distributor that first makes it available in France.
• The 2027 Citeo Pro fee schedule is published: €281.84/t for plastic (nearly 30% more than in the second half of 2026), €35.47/t for cardboard, and a flat fee of €240 excl. VAT for up to 4 tonnes a year.
• Join a PRO before 31 December 2026, obtain the unique identifier and state it in your terms of sale.

To see how EPR fits into the full set of packaging obligations, our complete guide to the PPWR sets out the European regulation, the PPWR timeline its deadlines and the list of banned packaging formats what leaves the market in 2030.

Further resources

Frequently asked questions

1Is the 1 January 2027 start date confirmed?

That is the date announced by the government on 28 July 2026 and adopted by ADEME and the PROs; Citeo Pro published its 2027 fee schedule on that basis on 5 October 2026. The ministerial order that sets it was put out for consultation in August 2026 and had still not been published in the Journal officiel on 6 October 2026. Prepare for that date: ADEME asks companies to join before 31 December 2026.

2What does EPRO mean?

EPRO is the abbreviation for France's EPR scheme for professional packaging. It is used by ADEME on its scheme page and by most professionals, and it distinguishes the scheme from the older household packaging scheme. If a customer or a PRO talks to you about EPRO membership or an EPRO identifier, they are therefore referring to this scheme, and your unique identifier for professional packaging will be separate from the one for your household packaging.

3Do I have to join a PRO if I only sell to businesses?

Yes, if you place on the market packaged products intended for professionals, or if you manufacture, import or distribute transport packaging. Only micro-businesses that buy their packaging from a French supplier are exempt.

4Which PRO should I choose: Citeo Pro, Léko Pro or Twiice?

The 3 approved PROs (Citeo Pro, Léko Pro and Twiice) cover the same scope, except catering, which is reserved for Citeo Pro. Compare their 2027 fee schedules: Citeo Pro published its own on 5 October 2026 (€281.84 excl. VAT per tonne of plastic, €35.47 for paper and cardboard and a flat fee of €240 excl. VAT for up to 4 tonnes a year), while Léko Pro and Twiice had not yet done so at that date. Also compare flat fees for small volumes, how easy the declaration is and the services offered. It is still possible to change PRO later, depending on the terms of the contract.

5Is packaging waste collection free under professional packaging EPR?

No: the final texts do not provide for free take-back. The PRO pays support to the collection and sorting operators, who deduct it from your bill if you sort your waste at source. You therefore still pay for collection, at a reduced rate.

6Are returnable or rented pallets covered by professional packaging EPR?

A reusable pallet pays only once, when it is first placed on the market, not on each rotation. The large rental pallet pools have been approved as individual compliance schemes and manage their own fleets. If you rent your pallets, check with the rental company who declares them.

7What happens if I do not join a PRO in time?

You face an administrative fine of up to €7,500 per tonne of packaging, a periodic penalty payment per day and commercial difficulties: customers and online marketplaces increasingly require the unique identifier. It is still possible to join late, but contributions cover all packaging placed on the market since 1 January 2027.

8Who declares the pallets and stretch film I buy from a French supplier?

In principle, your supplier does. For transport packaging, the producer is the company that first makes the packaging available in France, according to the definition used in Citeo Pro's 2027 fee guide. You remain the producer of your sales and grouped packaging: the bag, the carton, the big bag and the label. Two checks are needed. First, confirm that your pallet and film supplier is established in France and belongs to a PRO: ask it for proof of membership, then for its unique identifier as soon as it is issued. Second, confirm that you do not import any of these pallets or films yourself, in which case you become their producer. A pallet rented from a pool is in principle declared by the pool, which is approved as an individual compliance scheme.

9Does one PRO membership cover all the subsidiaries of a group?

No. Each legal entity that places packaging on the market is a producer: it joins in its own name, with its own unique identifier, and declares its own tonnages. To our knowledge, no PRO offers a group rate. What can be pooled is the method: the packaging inventory by entity, the choice of PRO, training for the staff responsible and, for sales outside France, the authorised representative provider, negotiated once for all the subsidiaries. Our article on the EPR authorised representative covers this last point in detail.

10Does the PPWR reuse obligation also apply to my transport packaging?

Yes, and it is separate from EPR. From 1 January 2030, pallets, crates, drums and other transport packaging used to deliver to another company in the same country, or exchanged between your sites and those of related companies, must be reusable within a reuse system; for other flows, including deliveries to other EU countries, the target is 40%. Cardboard boxes, packaging for dangerous goods, made-to-measure packaging for large machinery and flexible formats in contact with food are excluded (Article 29 of Regulation (EU) 2025/40). EPR pays for the end of life of packaging, whereas reuse obligations change the type of packaging used: the calculation rules are detailed in our article on reuse targets.

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