EPR in France: from what volume must I register (IDU)?

The registration rules (France)

• Producer = any company placing an EPR-covered product on the French market (manufacturer, importer, distributor)
• No tonnage or volume threshold to be a producer — the obligation starts at the first unit
• One IDU per EPR stream — a company has as many IDUs as streams its products fall under
• You cannot self-register in the collective system: your éco-organisme registers you on SYDEREP and issues the IDU
• Mandatory since 1 January 2022 (Art. L.541-10-13 Code de l'environnement)

You must display your IDU(s) in your terms of sale (CGV) and on your website (not required on invoices). Marketplaces have had to verify third-party sellers' IDUs since 1 January 2022 — without one, the marketplace becomes the producer and can refuse to list you.

What it changes for you

• A small e-commerce seller importing even a handful of units is a producer and must register — turnover or volume is irrelevant.
• One product can fall under several EPR streams (e.g. a smartphone: EEE, household packaging, batteries) — each needs its own IDU.
• Non-compliance exposes you to administrative penalties (Art. L.541-9-5) and to being delisted by marketplaces.

The timeline

• 10 February 2020 — Loi AGEC (n° 2020-105) frames modern EPR obligations.
• 1 January 2022 — IDU becomes mandatory; marketplaces must verify sellers' IDUs.
• 1 January 2022 — Triman + Info-tri sorting signage mandatory.
• 1 July 2026 — EPR for professional (industrial and commercial) packaging begins.

What to do now

1. List every product and packaging you place on the French market and map the EPR streams that apply.
2. Join the relevant éco-organisme(s) (Citeo, Ecosystem, Refashion…) — they register you and issue your IDU(s).
3. Add your IDU(s) to your CGV and website; keep them ready to provide to buyers and marketplaces.
4. Declare your volumes annually and pay the eco-contribution for each stream.