If you ship from another EU country straight to consumers in France, the French AGEC law (Law No 2020-105) treats you as the producer: you need an EPR unique identifier (IDU) in your terms and on your website, the Triman logo and Info-tri sorting instructions on the product or packaging, a repairability or durability score next to the price for some appliances — and you may not print “biodégradable” or “respectueux de l’environnement” on products or packaging. Here is what applies, to whom, and where it depends on how you sell.
Who is the “producer” when you ship from abroad
The French Environment Code calls anyone who “develops, manufactures, handles, processes, sells or imports” waste-generating products a producer (Article L541-10). For the repairability and durability scores, the “importer” is expressly whoever places equipment on the French market from another Member State or a third country (Article R541-217). For packaging, the definition in the Packaging Regulation (EU) 2025/40 (PPWR, Article 3(15)) has applied directly in France too since 12 August 2026: a business established in another Member State or outside the EU that makes packaged products available directly to end users in France is the producer there.
In practice it depends on your sales channel:
- you sell directly to French consumers (your own shop, Amazon.fr, Cdiscount, eBay.fr…): you are in principle the producer for France, even if the goods ship from Germany;
- you sell to a French distributor or importer who resells in France: they usually place the product on the French market and carry the EPR duties — agree this in your contract;
- your stock sits in a French warehouse (for example in a pan-European fulfilment programme): you are still the one selling to the consumer, so the same question applies.
Since Law No 2026-602 of 8 July 2026, a business not established in France that is subject to EPR must appoint, by written mandate, a mandataire established in France (Article L541-10-9-1). This counts as done for products where a marketplace established in France already fulfils the EPR duties. For packaging, the PPWR separately requires an authorised representative in every Member State where a producer sells at a distance without being established there, since 12 August 2026 (Article 45(3)). A Commission proposal of December 2025 to suspend this for EU‑based producers had not been adopted when this guide was written.
EPR schemes and the unique identifier (IDU)
Each EPR stream has its own producer responsibility organisation (éco-organisme): household packaging, electrical and electronic equipment, batteries, clothing, footwear and household linen, furniture, toys, sports and leisure goods, DIY and garden products and more (list in Article L541-10-1). The producer joins an approved organisation, pays the eco-contribution and receives a unique identifier per stream, recorded in ADEME’s SYDEREP register (Article L541-10-13).
- the IDU goes into your general terms and conditions or, if you have none, into another contractual document given to the buyer (Article R541-173);
- if you have a website, the IDU is shown there in the same way as the legal notice required by Article 19 of the French LCEN (Article R541-173);
- every seller must give the producer’s IDU to a buyer who asks for it (Article L541-10-10);
- failing to show the IDU among your mandatory information can lead to an administrative fine of up to €30,000 (Article L541-9-5).
Marketplaces must take on EPR for their sellers unless the seller proves compliance, and holding an IDU counts as proof (Article L541-10-9). Amazon therefore asks for your IDUs per category and, if you provide none, enrols you in “Pay on Behalf”: Amazon reports and pays the eco-contributions for your Amazon sales and charges them back to you plus a service fee. It covers Amazon sales only — your own shop needs your own IDUs.
Triman and Info-tri
Every household product in an EPR stream (except glass beverage packaging) carries the Triman logo next to the Info-tri, which tells the consumer how to sort the waste, component by component where needed (Articles L541-9-3 and R541-12-17 to R541-12-24). The Info-tri is designed by the stream’s éco-organisme: for household packaging, use your organisation’s template (Citeo, for example) rather than a home-made icon.
- where: on the product or its packaging, otherwise in other documents supplied with the product; for household packaging, on the packaging; stickers are allowed (R541-12-21);
- digital only for very small surfaces: under 10 cm² on the largest side (logo and Info-tri) or 10–20 cm² (Info-tri only), in the first case only if no other document comes with the product;
- mutual recognition: Triman can be replaced by another Member State’s sorting mark if that mark is mandatory and also tells consumers the product is subject to sorting rules (R541-12-20) — a generic recycling symbol is not enough;
- fine: up to €15,000 for a company (Article L541-9-4).
The law does not require the Triman in the online listing itself: the duty applies to the product and packaging the customer receives. From 12 August 2028 at the earliest, the PPWR will require a harmonised EU label on packaging whose information must also be available before an online purchase (Article 12).
Repairability and durability scores
For some new electrical and electronic equipment, the seller — including anyone selling online in France — must show a score out of 10 at the point of purchase (Article L541-9-2). According to the French Ministry of Ecological Transition, the repairability index covers laptops, electric lawnmowers, dishwashers, vacuum cleaners and high-pressure cleaners; the durability index replaced it for televisions on 8 January 2025 and for front- and top-loading washing machines on 8 April 2025. Smartphones are no longer on the list: an order of 26 June 2025 repealed the one that set their criteria.
- online, the score appears on every page where the product can be bought, close to the price, visibly and legibly (Articles R541-213 and R541-220) — not tucked away in an image gallery;
- for the durability index, the detailed scoring table must be reachable directly from the same page (R541-220); for the repairability index, the scoring parameters must be made available by any appropriate means (R541-213);
- the producer or importer calculates the score and passes it to sellers free of charge (R541-212 and R541-218): if you bring the appliance into France yourself from another country, that is your job;
- fine: up to €15,000 for a company (Article L541-9-4).
Environmental wording: what is banned and what is regulated
Article L541-9-1 of the Environment Code (Article 13 of the AGEC law) and Article R541-230 ban the words “biodégradable”, “respectueux de l’environnement” (environmentally friendly) and any equivalent claim on new consumer products and their packaging. The same article regulates other wording:
| Instead of | Write |
|---|---|
| « emballage respectueux de l’environnement » | « emballage comportant au moins 80 % de matières recyclées » (if true and documented) |
| « sachet biodégradable » | remove it; for home-compostable plastic: « compostable » plus « Ne pas jeter dans la nature » |
| « fabriqué en matériaux recyclés » | state the percentage of recycled material actually used |
| « neutre en carbone » | remove it unless you publish an emissions balance and reduction path (Article L229-68) — and offsetting alone no longer works under EU law |
Plastic that only composts in industrial facilities may not be labelled “compostable”. These French bans cover the product and packaging; your online listings are additionally caught by Directive (EU) 2024/825, which Member States had to apply from 27 September 2026 (see our guide to the green claims ban). France had not finished transposing it when this guide was written, but misleading commercial practices are still punishable.
The “product sheet on environmental qualities and characteristics” (Articles R541-227 to R541-229, introduced by Decree 2022-748 and now in the version of Decree 2024-316) is only mandatory above €10 million turnover and 10,000 units placed on the French market per year for the products concerned. Below that, if you choose to print such information on the packaging, it must follow the decree’s wording. For clothing, footwear and household linen sold online, Law No 2026-602 also requires the places of manufacture to be shown next to the price, in the same font size (Article L541-9-1-2).
Toubon law: the listing in French
Law No 94-665 of 4 August 1994 (the Toubon law, Article 2) requires French in the name, offer, presentation, instructions for use and warranty description of a product, including on websites and online marketplaces; the French consumer authority DGCCRF also checks e-commerce. Other languages may be added, but French must be there. The safety warnings required by the GPSR also have to be in French (see GPSR in online listings).
Unreviewed machine translation shows on Amazon.fr: wrong technical terms, unconverted units, truncated legal information. Our guide to machine-translated listings covers the usual mistakes.
Checklist and listing check
- Producer for France identified (you, your importer or the marketplace), and a mandataire or authorised representative appointed if you are not established in France.
- IDU for each stream (packaging and product), in your terms and on your website; IDUs or “Pay on Behalf” sorted out on Amazon.
- The éco-organisme’s Triman and Info-tri on the product or packaging.
- Repairability or durability score next to the price, with the scoring table, where the appliance is covered.
- No “biodégradable”, “respectueux de l’environnement”, “écologique” or “neutre en carbone” on the packaging or in the listing; a percentage for any recycled-content claim.
- Listing, instructions and warnings in French.
The free listing check finds banned environmental claims in your text — “respectueux de l’environnement”, “biodégradable”, “neutre en carbone” — along with misleading CE and test wording, in all six languages. It does not check your IDU or your packaging: those are handled in your account and your production.