Regulation PPWR (EU) 2025/40 — the authorised representative requirement has applied since 12 August 2026
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EPR & PPWR news

Practical updates on extended producer responsibility for packaging in France and Regulation (EU) 2025/40.

October 2026 · Transport companies · France

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.

PATRIM AGENCY can handle all your registrations. Free consultation – message us on WhatsApp at +370 600 16187.

Key dates

12 Aug 2026EU PPWR regulation starts to apply
31 Dec 2026Deadline to join a producer responsibility organisation
1 Jan 2027French EPR registration for professional packaging
1 Jan 2030Use and registration of reusable transport packaging
01 · Status

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:

SituationStatusWho declares the packaging in France
Carrying goods already packed by the clientService providerThe client or its supplier
Load unpacked in the company's warehouseWaste holderThe producer further up the chain
Pallets, film, strapping bought from a French supplierUsually not a producerThe French supplier
Pallets, film or boxes brought in (e.g. from Lithuania) and left with consignees in FranceProducer (importer)The transport company itself
Packing, repacking or palletising on the client's behalfMay be sharedTo be set in the contract
The company's own brand on the packagingProducerThe transport company itself
Pallets rented from a shared poolNot a producerThe pallet pool operator
Transfer between sites with the same SIRETNot 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.

02 · French EPR

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

  1. Join a producer responsibility organisation – Citeo Pro, Léko Pro or Twiice – by 31 December 2026.
  2. Obtain your unique identifier (UIN) in the ADEME register; show it in your terms of sale and on your website.
  3. Inventory your packaging by material: plastic, paper and cardboard, wood, metal.
  4. Declare quantities every year; first declaration in early 2027.
  5. Pay the eco-contributions. Reusable packaging is charged only once; new reusable packaging earns a 50% bonus.
  6. Keep records of quantities, the split of responsibilities and any exemptions.
  7. 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)

up to €7,500Per tonne of packaging
up to €20,000Per day
up to €30,000For no UIN or registration

Large clients and marketplaces increasingly require a UIN as a condition of doing business.

03 · EU Regulation 2025/40

PPWR: when the obligations apply to a transport company

The PPWR has applied across the EU since 12 August 2026.

  1. 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.
  2. Stage two: the key point for the transport sector – registering reusable packaging and meeting the targets from 1 January 2030.
40%reusable transport packaging within the EU from 1 January 2030 (2040 target: 70%)
100%from 1 January 2030 for transport between your own or related companies' sites in the EU, or to another operator in the same country (e.g. within France)
If the company…ObligationFrom
is a packaging producer in an EU countryRegister 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' goodsDo 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 strappingReuse targets of 40% / 100% (Art. 29)1 Jan 2030
fills grouped, transport or e-commerce packagingEmpty space no more than 50%; filling material counts as empty space (Art. 24)1 Jan 2030
uses a reusable packaging systemReturn, 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.

04 · Action plan

What to do before 31 December 2026

  1. List all the packaging you buy, bring in, add or leave with consignees in France.
  2. For each flow, determine your status: producer, holder or service provider.
  3. If you are a producer: appoint an authorised representative (e.g. PATRIM AGENCY), join a producer responsibility organisation and obtain your UIN.
  4. Add a clause to your contracts stating who declares each packaging item.
  5. Set up packaging waste sorting in your warehouses and keep the evidence.
  6. Prepare for the 2030 PPWR targets: assess the share of reusable pallets and crates.

Contact our partner GRAMTAX

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Prepared by PATRIM AGENCYInformation prepared in October 2026 from public sources (Decree No. 2025-1081, Regulation (EU) 2025/40, Delegated Decision (EU) 2026/429, producer responsibility organisation guidance). The French implementing order may still change. This is not legal advice.
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