EPR in France: Citeo, IDU & the Triman Label

Selling into France requires three things: an Identifiant Unique (IDU) issued by ADEME and quoted on your filings, the Triman sorting logo printed on your packaging, and per-stream declarations lodged in the SYDEREP register. The IDU has been mandatory since 1 January 2022, France sets no minimum threshold, and selling without the number risks penalties of up to €30,000.

France runs the widest Extended Producer Responsibility (EPR) system in Europe - sixteen product categories, or filières, fifteen of them operating, all routed through SYDEREP and kept by the environment agency ADEME. For an online seller the practical test is not where your company sits but whether your products, or the packaging around them, fall under a French filière.

France's proof burden is what sets it apart. Where some markets ask only that you pay a fee, France asks you to carry an identifier, print a sorting label, and file per-stream declarations - a paper trail that runs from your registration certificate through to the print on the packaging a French household eventually recycles.

The IDU: the number that has to be on your filings and your site

The document everything else hangs off is the Identifiant Unique (IDU). It is a 15-character code beginning FR, issued by ADEME, and has been mandatory since 1 January 2022. You get one per producer per filière, so a seller placing both packaging and, say, electricals on the market carries more than one. This is the exact EPR number marketplaces demand before they let you sell.

The mechanics catch foreign sellers out because they run backwards compared with, for example, EPR in Germany, where you register yourself with the authority first. In France you cannot log into SYDEREP and enrol. Instead:

1. You affiliate with an approved éco-organisme (producer responsibility organisation) for each waste stream your products touch.
2. The éco-organisme registers you in the SYDEREP national register on ADEME's behalf and obtains your IDU.
3. ADEME charges nothing for the register itself; the cost sits in the éco-contribution you pay the éco-organisme.

Once issued, the IDU is not a certificate you file away. It has to appear in your terms of sale and on your website, and each filière you sell into needs its own unique identifier issued by ADEME. Getting the number, in other words, is only the start of the obligation.

Who owes French EPR, and the mandataire question for foreign sellers

France applies no de minimis threshold to packaging. A manufacturer, importer or distance seller shipping to French consumers is an obligated producer from the first parcel, with no free tonnage below which the rules do not bite. A store dispatching cookware from Poland to French homes places packaging on the market, and possibly a product filière too, so it owes éco-contributions even without a French entity.

Marketplaces are pulled in alongside the seller. Since 1 January 2022, article L541-10-9 of the Code de l'environnement makes a platform liable for its third-party sellers' EPR duties unless the seller proves compliance, which is why Amazon, eBay and the rest ask for your IDU before your listings go live. If you also run your own storefront on Shopify or WooCommerce and ship directly to French buyers, no marketplace is covering those sales; you carry the obligation yourself.

One point genuinely remains unsettled, and it is worth knowing before you rely on a workaround. France's rule letting a foreign seller appoint a mandataire (an authorised representative) to take on its obligations was struck down by the Conseil d'État on 10 November 2023 (decision n°449213), which annulled the article allowing a mandataire to be subrogated into all of a producer's duties. The codified position has not been fully consolidated since, so treat any "we'll be your French representative" offer with care and check the current state of the rule.

Citeo, éco-contributions and how eco-modulation works

For household packaging, the dominant éco-organisme is Citeo, alongside Léko and Adelphe. Other filières route through their own bodies - textiles through Refashion (France launched Europe's first textile EPR scheme back in 2007), furniture and toys through Ecomaison, sports and leisure goods through Ecologic. When you affiliate with Citeo membership and registration, you transfer your physical waste-management obligation to it in exchange for a financial contribution that funds municipal sorting and recycling.

Your bill is not a flat fee. The éco-contribution is built from the weight and unit count of the packaging you declare, priced by material fraction (clear PET, cardboard, aluminium and so on), then adjusted by an eco-modulation factor and a sector coefficient. Declarations are made annually, more often for high-volume sellers.

Eco-modulation is where design choices show up in the Citeo rates for household packaging:

• Bonus: highly recyclable mono-material packaging, or a high share of post-consumer recycled content, earns a discount.
• Malus: hard-to-recycle formats - dark opaque plastics, multi-layer composite pouches, elements that disrupt sorting lines - attract a penalty that pushes the cost per kilogram up sharply.

Working out the exact weights and material fractions across cross-border orders is the tedious part. Gramta turns your real e-commerce sales into filing-ready packaging reports mapped to the Citeo material fractions and eco-modulation rules. See Gramta in action.

Triman and Info-tri: the labels that must be on the box

France is one of the few markets where the label on the packaging is itself a legal obligation, not just good practice. It is unlawful to place household packaging on the French market without telling the consumer how to sort it, and that is done through the Triman pictogram - a human figure beside three arrows - signalling that the packaging is subject to sorting rules.

The logo alone no longer satisfies the rule. It has to be shown with Info-tri sorting instructions. The Info-tri sorting guidelines require you to break the packaging into its components and assign each to the right bin: in France the yellow bin (bac jaune) takes recyclable packaging, the green bin (bac vert) takes glass. A cardboard box with plastic void fill has to instruct the buyer to separate the two.

The Triman and its Info-tri instructions must be printed on the packaging or applied by sticker - you cannot move them to your website and ship a blank box into France - and they must be legible and contrast with the background. Get the marking wrong and French market-surveillance authorities can hold shipments and issue administrative fines.

Fines and enforcement under the Code de l'environnement

Enforcement runs on administrative penalties rather than criminal prosecution. Under article L541-9-5 of the Code de l'environnement, missing registration or a missing IDU can cost up to €30,000, with per-unit or per-tonne penalties of up to €1,500 for an individual and €7,500 for a company. Authorities can layer a recurring daily penalty (astreinte) on top until you bring yourself into compliance. The ceilings are rarely applied at their maximum, but they are written into the code and the marketplace-liability rule gives platforms a strong incentive to police them for you by suspending non-compliant listings.

France has no national bottle-deposit scheme

Unlike a growing number of EU markets, France operates no national deposit-return system for drinks containers, and this sits outside EPR rather than being part of it. A 2023 decision shelved the idea in favour of continuing with fee modulation. The debate reopened in May 2026 and became more contentious rather than less, with local-authority, recycler and NGO representatives walking out of a June 2026 consultation, but nothing has been decided. For now there is no consigne to join, and your packaging obligations run entirely through the éco-contribution and labelling rules above.

Key dates for French packaging EPR

The French system is old at its core and still moving at the edges. The milestones that matter to a seller today, in present-tense terms:

Two changes are worth watching. The PPWR, Regulation (EU) 2025/40, is directly binding and introduces a harmonised EU sorting label that will, over time, sit alongside and eventually reshape national marks like the Triman. Professional-packaging EPR (EPRO) has its schemes approved but its launch postponed with no replacement date, so B2B sellers should treat EPRO as pending rather than live.

The PPWR and EPRO both leave the French fundamentals intact: an active IDU, an éco-organisme affiliation, and eco-modulated fees on the packaging you ship into France. If you sell across several markets, our EPR by country in Europe overview shows how differently each one is wired.

Sources:

• ADEME - SYDEREP national register
• ADEME - Identifiant Unique (IDU)
• Citeo - Membership and registration
• Citeo - Rates for household packaging and paper
• Citeo - Info-tri sorting guidelines
• Légifrance - Code de l'environnement article L541-9-5
• Légifrance - Decree 2025-775 (fishing gear)
• EUR-Lex - Packaging and Packaging Waste Regulation (EU) 2025/40