Do I need an EPR representative?
You may need an EPR representative if you want to entrust all or part of your EPR obligations to a professional acting on your behalf. In some cases, regulations may also require you to appoint an authorised representative.
To determine whether you need an EPR representative, consider your situation, your products and packaging, how you sell them and the relevant EPR schemes.
Questions to ask yourself
To find out whether you need an EPR representative, first check:
- Do you have a business establishment in France?
- Do you sell products to customers in France??
- Do your products or packaging fall under one or more EPR schemes?
- Do you sell directly, through a distributor, via a marketplace or online?
- Do you already have a contact in France who manages your EPR obligations?
- Do you need to obtain a Unique Identification Number (UIN) for one or more EPR schemes?
If you do not have a business establishment in France and place products or packaging subject to Extended Producer Responsibility (EPR) on the French market, you may need to appoint an authorised representative, depending on the relevant EPR scheme, the products concerned and how you sell them.
Marketplaces and online sales
If you sell through a marketplace, you may be required to provide evidence of EPR compliance.
Article L.541-10-9 of the French Environmental Code provides that an electronic interface, such as a marketplace, may be required to contribute to the prevention and management of waste from products sold on behalf of third parties, unless it has evidence that the seller has already fulfilled its EPR obligations.
In this context, the UIN can provide important evidence that you are properly registered for the relevant EPR scheme. Obtaining a UIN can also help prevent your marketplace listings from being suspended.
How do I find the right EPR representative?
To choose an EPR representative that is right for you, consider:
- The EPR schemes covered;
- Their experience with your products, packaging or industry;
- Their ability to manage several EPR schemes at the same time;
- The working languages offered;
- Their geographic coverage and the services offered
- Their EPR reporting processes;
- The clarity and scope of the proposed mandate;
- Billing arrangements and administrative follow-up.
Eco-Op, in partnership with Twiice, aims to make this search easier through My EPR Journey by providing structured, clear and neutral information to help you identify EPR representatives based on practical criteria, without directing you towards any particular provider. You can also browse the EPR representative directory.
Key Takeaways
Whether you need an EPR representative depends on your situation, your products and packaging, the relevant EPR schemes and, in some cases, how you sell your products. Before choosing a representative, check the services offered, the EPR schemes covered and the proposed scope of support.
Find an EPR representative
Have you determined that you need an EPR representative?
The My EPR Journey directory allows you to search for an EPR representative based on the EPR schemes covered, countries served and languages spoken.
