Effective July 10, 2026, a new requirement applies to all Extended Producer Responsibility (EPR) sectors. From now on, producers based outside French territory—whether in another European Union member state or in a third country—must appoint an authorized representative based in France to ensure compliance with their regulatory obligations.
Law No. 2026-602 of July 8, 2026, aimed at reducing the environmental impact of the textile industry—known as “fast fashion”—introduced a new requirement that applies to all extended producer responsibility (EPR) sectors: Producers established outside French territory are required to appoint an authorized representative responsible for ensuring compliance with the obligations related to extended producer responsibility.
This new provision is codified in Article L. 541-10-9-1 of the Environmental Code, and this requirement took effect on July 10, 2026.
This requirement applies to all producers not established in France, regardless of whether they are established within the European Union. It also applies to online intermediation platforms(marketplaces) that facilitate distance sales or the delivery of products on behalf of third-party sellers and are required to provide for or contribute to the management of EPR waste resulting from such sales when they are not established in France.
This requirement applies to all EPR sectors, including the household packaging and paper sector and the commercial packaging sector.
Terms of the Mandate
The authorized representative must be a natural person or legal entity established in France;
The agent is appointed by written authorization;
The agent is subrogated to all obligations arising from the principle of liability under which the agent accepts the mandate: this legal subrogation thus entails a transfer of the principal’s extended producer liability to the agent.
Purpose of the measure
This requirement to designate an authorized representative reflects the authorities’ desire to exercise jurisdiction over any producerthat makes products subject to the Extended Producer Responsibility (EPR) system available on French territory, so that they may, if necessary, conduct inspections or initiate legal proceedings in the event of noncompliance with these obligations.
European Context
The EPR schemes for household and commercial packaging are also subject to the new requirements introduced byRegulation No. 2025/40 on packaging and packaging waste, known as the “PPWR.”
Article 45 of the PPWR provides that a producer shall designate, by written mandate, an authorized representative for the extended producer responsibility system in each Member State in which it makes packaging available for the first time, other than the Member State in which it is established. It also specifies that Member States may require producers established in third countries to designate, by written mandate, an authorized representative for the extended producer responsibility system when they make packaged products available on their territory for the first time.
However, this requirement could be suspended through a legislative proposal included inthe Omnibus Simplification Package, which is currently under discussion in the European Parliament and the Council of the EU.
With regard to the placing of products on the market in France, this requirement is now expressly provided for by law.
What are the next steps to ensure compliance?
As a reminder, this new requirement does not apply to producers based in France.
For producers based abroad (EU/non-EU), the steps are as follows:
Identification of a representative to ensure compliance with the relevant EPRs;
Execution of a written agency agreement;
Submit the agency agreement to the eco-organization toupdate your membership;
Signing of the membership agreement by the authorized representative with Léko for household packaging and paper, and with Léko Pro for commercial packaging;
Updating membership data via Léko/Léko Pro on SYDEREP.