From 1 January 2027, a new obligation for transport companies not established in France
Professional packaging EPR and the EU PPWR regulation: when a transport company becomes responsible, when it must register as a “packaging producer”, and what it needs to do.
Key dates
Will your transport company be considered a packaging producer in France?
The “packaging producer” is whoever places the packaging on the French market for the first time – not whoever carries it. Responsibility is assessed separately for each packaging flow:
| Situation | Status | Who declares the packaging in France |
|---|---|---|
| Carrying goods already packed by the client | Service provider | The client or its supplier |
| Load unpacked in the company's warehouse | Waste holder | The producer further up the chain |
| Pallets, film, strapping bought from a French supplier | Usually not a producer | The French supplier |
| Pallets, film or boxes brought in (e.g. from Lithuania) and left with consignees in France | Producer (importer) | The transport company itself |
| Packing, repacking or palletising on the client's behalf | May be shared | To be set in the contract |
| The company's own brand on the packaging | Producer | The transport company itself |
| Pallets rented from a shared pool | Not a producer | The pallet pool operator |
| Transfer between sites with the same SIRET | Not placing on the market | – |
What counts as professional packaging
Pallets, stretch film, strapping, layer pads, boxes, drums, IBCs, big bags. Pallets and their securing elements are always professional packaging. An e-commerce parcel to a private individual belongs to the household packaging stream.
Composite pallet
Responsibility may be shared between the pallet supplier, the client and the company that assembled it. State in writing in the contract who declares which packaging.
Your obligations from 1 January 2027
Legal basis: the AGEC law and Decree No. 2025-1081 (17 November 2025). Your obligations depend on whether, for a given flow, you are the producer or the holder of packaging waste.
If you are the producer
- Join a producer responsibility organisation – Citeo Pro, Léko Pro or Twiice – by 31 December 2026.
- Obtain your unique identifier (UIN) in the ADEME register; show it in your terms of sale and on your website.
- Inventory your packaging by material: plastic, paper and cardboard, wood, metal.
- Declare quantities every year; first declaration in early 2027.
- Pay the eco-contributions. Reusable packaging is charged only once; new reusable packaging earns a 50% bonus.
- Keep records of quantities, the split of responsibilities and any exemptions.
- A foreign company with no establishment in France must appoint an authorised representative (REP mandataire). PATRIM AGENCY offers this representation: www.patrimagency.com
If you are a packaging waste holder (you unpack, store or use packaging)
- Sort packaging waste by material where it arises.
- Arrange for its collection and treatment.
- Keep proof of collection and treatment.
- Where possible, return packaging for reuse.
A holder that sorts its waste may receive support from the producer responsibility organisation towards handling costs.
Late joining and exemptions
A transport company that joins a producer responsibility organisation late pays its packaging eco-contributions retroactively, for up to three years. Very small companies buying their packaging from a French supplier are exempt.
Penalties (maximum amounts)
Large clients and marketplaces increasingly require a UIN as a condition of doing business.
PPWR: when the obligations apply to a transport company
The PPWR has applied across the EU since 12 August 2026.
- Stage one: obtain your UIN in the ADEME register, show it in your terms of sale and on your website, and join a producer responsibility organisation by 31 December 2026.
- Stage two: the key point for the transport sector – registering reusable packaging and meeting the targets from 1 January 2030.
| If the company… | Obligation | From |
|---|---|---|
| is a packaging producer in an EU country | Register in the national packaging producer register; with no establishment, appoint an authorised representative in France (Art. 44–45) Service offered by PATRIM AGENCY | 12 Aug 2026 |
| stores, packs or ships clients' goods | Do not undermine packaging compliance; serve only clients who meet their PPWR obligations (Art. 20) Service offered by PATRIM AGENCY | 12 Aug 2026 |
| carries goods on pallets, in boxes, IBCs, drums, with film or strapping | Reuse targets of 40% / 100% (Art. 29) | 1 Jan 2030 |
| fills grouped, transport or e-commerce packaging | Empty space no more than 50%; filling material counts as empty space (Art. 24) | 1 Jan 2030 |
| uses a reusable packaging system | Return, cleaning and traceability as required (Art. 29, 33) | 1 Jan 2030 |
Exemptions
Cardboard boxes are exempt from the reuse targets. For film and strapping the 100% target does not apply; the 40% target does (Delegated Decision 2026/429). Packaging for dangerous goods and large machinery is exempt (Art. 30).
Who is responsible for the targets
The operator that uses the transport packaging. Usually the shipper, but also the carrier or logistics company that chooses the pallets, boxes or film itself. Cover this in your contracts with clients.
From 12 August 2028: harmonised EU labelling requirements; QR codes for reusable packaging from 12 February 2029.
What to do before 31 December 2026
- List all the packaging you buy, bring in, add or leave with consignees in France.
- For each flow, determine your status: producer, holder or service provider.
- If you are a producer: appoint an authorised representative (e.g. PATRIM AGENCY), join a producer responsibility organisation and obtain your UIN.
- Add a clause to your contracts stating who declares each packaging item.
- Set up packaging waste sorting in your warehouses and keep the evidence.
- Prepare for the 2030 PPWR targets: assess the share of reusable pallets and crates.
