# The EPR Fee 2026: Complete Guide to New Obligations for Businesses 2026 marks a major turning point for extended producer responsibility (EPR) in France. With the new professional packaging EPR scheme coming into force and the changes introduced by the European PPWR regulation, businesses need to prepare for significant changes to their tax and reporting obligations. This shift reflects a broader move to strengthen the polluter-pays principle and speed up the transition to a circular economy. ## The EPR Fee 2026: Definition and Regulatory Context

Principle of extended producer responsibility

**The EPR fee** refers to the financial contributions that producers must pay to authorised producer responsibility organisations (PROs) as part of their extended producer responsibility (EPR) obligations. In France, this principle has been set out in Article L. 541-10 of the French Environmental Code since 1975, but has expanded considerably with the AGEC law of 2020. There are currently **19 EPR schemes** operating in France, covering sectors as varied as packaging, electrical equipment, textiles and tyres. Each scheme works on the polluter-pays principle: businesses that place products on the French market fund their end-of-life management. The distinction between the EPR fee and the eco-contribution lies mainly in their legal nature. The eco-contribution is a voluntary payment made to a PRO, whereas the EPR fee is a legal obligation subject to penalties if not met. This distinction matters even more in the tighter regulatory context of 2026.

Major changes introduced by the AGEC law and the PPWR regulation

The AGEC law (Anti-Waste for a Circular Economy) of 10 February 2020 significantly widened the scope of EPR schemes. The stated goal is to reach **100% plastic recycling** by 2025, up from just **29% today**, according to the latest official figures from 2024. The European PPWR (Packaging and Packaging Waste Regulation) introduces a new definition of "producer" that now includes **commissioning businesses**. This change, applicable from 2026, considerably widens the number of businesses subject to EPR obligations. Businesses that use third parties to package their products now become responsible for the packaging used. This regulatory change comes with stricter administrative penalties. Fines can now reach **€7,500 per tonne** left undeclared, with a cap of €30,000 for incorrect information submitted to the authorities. ## New professional packaging EPR scheme 2026

Implementation timeline and scope

Decree No. 2025-1081 of 17 November 2025 officially creates the professional packaging EPR scheme (EPRO), which comes into force on **1 January 2026**, with obligations effective from **1 July 2026**. This new scheme covers around **17 million tonnes** of industrial and commercial packaging each year. The EPRO scheme results from merging the catering EPR scheme with part of the industrial packaging previously excluded from scope. It covers all packaging used in a professional context: transport packaging, grouped packaging, and primary packaging intended for professionals. Affected businesses have a six-month transition period to get organised and join an authorised PRO. This buffer period allows businesses to gradually adapt to the new regulatory requirements.

Businesses subject to EPRO obligations

The new definition of producer significantly widens the scope of application. The following are now concerned: - **Traditional producers**: manufacturers and importers of packaging - **Principals**: businesses that have their products packaged by third parties - **Distributors**: for their own-brand packaging - **Digital platforms**: for the packaging of their third-party sellers, under certain conditions This extension reflects a logic of increased accountability for economic actors. A business that designs a product and uses a service provider to package it becomes responsible for the environmental impact of that packaging, even if it does not produce it directly. Obtaining an **EPR unique identification number (UIN)** becomes mandatory for all these categories of businesses. This number must be mentioned in the general terms and conditions of sale and used for all declarations via the SYDEREP system. ## Calculation and amount of EPR contributions in 2026

Fee scale system by material and environmental modulation

The calculation of 2026 eco-contributions relies on fee scales that differ by material and includes an environmental bonus-malus system. Base fee scales are set per tonne of packaging placed on the market, with significant variations depending on the material: The modulation system can vary contributions from **-100% to +100%** depending on the eco-design criteria met. Bonuses reward the use of recycled materials, ease of recycling or reduced packaging quantities. Conversely, penalties apply to materials that are difficult to recycle or to over-packaging. Billing follows a **quarterly** schedule for businesses whose annual contributions exceed €10,000 excluding VAT, and an **annual** schedule for others. This distinction reduces the administrative burden for small businesses while maintaining regular monitoring for larger contributors.

Impact of Citeo fees and pricing changes

The 2026 fees of the main producer responsibility organisations (PROs) such as Citeo incorporate the new requirements of the PPWR regulation. These changes result in an average increase in contributions, particularly for plastic packaging and complex multi-material packaging. The introduction of the EPRO scheme also changes the distribution of costs between household and professional packaging. Businesses may see cost transfers depending on the nature of their packaging and its final destination (household or professional use). To optimise their costs, businesses can rely on tools such as Ecobalyse to calculate the environmental impact of their packaging and identify the most effective eco-design levers. ## Reporting and administrative obligations for 2026

SYDEREP system and mandatory declarations

All EPR declarations now go through **SYDEREP**, the unified system developed by ADEME (the French environment agency). This portal centralises declarations for all EPR schemes and allows real-time monitoring of each business's obligations. Declarations must be made **quarterly** for most schemes, with specific deadlines: 31 January, 30 April, 31 July and 31 October. Failure to meet these deadlines exposes businesses to late penalties calculated on the amount of contributions due. The UIN becomes the pivot of the declaration system. Each business must obtain a UIN for each relevant EPR scheme and use it consistently in its commercial and administrative dealings. This enhanced traceability allows authorities to better monitor compliance with obligations.

Prevention plans and eco-design

Businesses whose annual contributions exceed certain thresholds must draw up a **five-year eco-design plan**. This document details the concrete actions taken to reduce the environmental impact of packaging: weight reduction, material substitution, improved recyclability. The plan must be updated annually and submitted to the relevant producer responsibility organisation (PRO). It serves as a basis for assessment when awarding environmental bonuses and may be checked by government services. Businesses can receive support in preparing these plans through public assistance schemes or advisory services offered by PROs. This preventive approach fits within the continuous improvement logic promoted by EPR regulations. ## Authorised producer responsibility organisations and membership arrangements

Competitive landscape of producer responsibility organisations

The market for packaging PROs mainly includes **Citeo**, **Léko** and **Adelphe**. Each PRO offers different services and specific fees, allowing businesses to choose the offer best suited to their needs. A PRO's authorisation is granted by the State for a maximum period of **6 years**. This authorisation is conditional on compliance with a precise specification setting collection, recycling and awareness targets. PROs are also subject to result-based obligations, unlike the simple means-based obligations previously required. Choosing a PRO should take several criteria into account: geographic coverage, service quality, pricing, but also capacity for innovation and support with eco-design initiatives.

The individual system alternative

Businesses can also opt for an **individual system** instead of joining a PRO. This option requires setting up financial guarantees and demonstrating the ability to meet regulatory targets independently. The individual system mainly suits large businesses with the technical and financial resources needed to organise their own waste management scheme. It offers greater control over costs and operational arrangements, but imposes significant administrative constraints. The financial guarantees required can amount to several years' worth of theoretical contributions, representing a significant barrier for most businesses. This is why more than 95% of producers choose to join a PRO. ## Taxation of plastic packaging: 2026 changes

Removal of the national plastic tax

The 2026 finance bill initially planned to introduce a tax on plastic packaging of **€30 per tonne** in 2026, rising to **€150 per tonne** by 2030. This measure, set out in Article 21 of the finance bill, was ultimately removed by Parliament following pressure from the industrial sector. This removal represents an estimated shortfall of several hundred million euros for public finances. It illustrates the difficulty of gaining acceptance for the "greening of taxation" in a tense economic context. Abandoning this national tax does not prevent local authorities from introducing their own plastic packaging taxation schemes, as part of their waste management powers.

European contribution maintained

At the same time, France continues to pay its **European contribution** based on unrecycled plastic packaging. This contribution, set at **€800 per tonne**, represents an annual cost of several hundred million euros for the French State. With a plastic recycling rate of only **25.9%**, compared with a European average of **41.5%**, France is among the poor performers in Europe. This situation generates significant penalties that weigh on public finances and create indirect pressure on businesses. Improving the plastic recycling rate is therefore a major economic issue, beyond environmental considerations. Investment in recycling technologies and packaging eco-design can help reduce this European bill. ## Stricter EPR sanctions and controls in 2026

Tightening of the sanctions regime

The strengthening of EPR sanctions in 2026 relies on a logic of result-based obligations rather than simple means-based obligations. PROs must now meet numerical collection and recycling targets, under penalty of financial sanctions. Administrative fines can reach **€7,500 per tonne** undeclared for the most serious breaches. This penalty applies retroactively over several financial years in the event of discovered fraud or repeated omissions. Incorrect information provided to the authorities is punishable by fines of up to **€30,000**. This penalty covers inaccurate declarations, late declarations or the submission of incomplete data.

Intensified DGCCRF controls

The French Directorate General for Competition, Consumer Affairs and Fraud Control (DGCCRF) is intensifying its checks on compliance with EPR obligations. These checks may cover the accuracy of declarations, the reality of PRO memberships, or compliance with consumer information obligations. Controls now rely on digital tools that cross-reference declaration data with customs and tax information. This data-driven approach improves the effectiveness of checks and reduces opportunities for circumvention. Businesses under review have a right of reply and can challenge sanctions before the administrative courts. However, the burden of proof lies with them to demonstrate their good faith or the absence of any breach. To avoid these risks, businesses can rely on solutions such as those offered by CompliancR to automate their EPR compliance and reduce the risk of error. ## Practical guide: achieving EPR compliance in 2026

Checklist of essential steps

EPR compliance for 2026 requires a methodical approach that follows a precise timetable. Businesses must first identify their obligations based on their activity and the geographic scope where they sell their products. The key steps include: 1. **Audit of obligations**: identify the relevant EPR schemes based on the products sold 2. **Obtaining UINs**: apply for a unique identification number for each scheme via the ADEME portal 3. **Choosing a producer responsibility organisation (PRO)**: compare offers and join before 1 July 2026 4. **Setting up reporting**: organise quarterly declarations via SYDEREP Planning ahead is a key success factor. Businesses that organise themselves in advance avoid late penalties and benefit from better support from PROs.

Official tools and resources

The **filieres-rep.ademe.fr** portal centralises all official information on EPR schemes. It offers practical guides, contribution simulators and training webinars for businesses. The SYDEREP platform not only allows you to complete mandatory declarations but also to track how your contributions evolve and access personalised dashboards. Businesses can find their declaration history there and plan ahead for upcoming deadlines. Chambers of Commerce and Industry also offer personalised support for businesses in their region. These services can be particularly useful for small and medium businesses discovering EPR obligations for the first time. For an automated and optimised approach, solutions such as CompliancR help automate the management of EPR obligations at prices accessible to businesses of any size. ## FAQ

When will I need to start paying the EPR contribution for professional packaging?

The obligations of the new professional packaging EPR scheme (EPRO) will come into force on **1 July 2026**. You must join an authorised PRO before this date and start paying your contributions from the third quarter of 2026. The first quarterly declaration must be submitted before 31 October 2026 for third-quarter volumes.

How do I know if my business is affected by the new definition of producer?

Since 2026, you are affected if you **manufacture**, **import** or **have manufactured** packaging placed on the French market. The new definition includes principals: if you outsource the packaging of your products to a provider, you become responsible for that packaging even if you do not produce it directly. Digital platforms may also be affected for the packaging used by their third-party sellers.

What is the difference between the EPR contribution and the eco-contribution?

The **eco-contribution** is the amount you pay to your PRO (Citeo, Léko, Adelphe) in return for managing your packaging at end of life. The term **EPR contribution** refers to the full set of fiscal obligations linked to extended producer responsibility, including eco-contributions but also any penalties for non-compliance. In everyday language, the two terms are often used interchangeably.

Can I change PRO during the year?

No, joining a PRO is an **annual and binding** commitment. You can only change PRO at the end of your contract, usually on 31 December. It is therefore important to compare offers carefully (prices, services, geographic coverage) before making your choice. Some PROs offer multi-year contracts with favourable pricing terms.

What does my business risk in case of EPR non-compliance in 2026?

Penalties have been significantly increased in 2026. You risk up to **€7,500 in fines per tonne** not declared, with a cap of €30,000 for incorrect information. DGCCRF inspections are intensifying and rely on digital tools that cross-check your declarations against customs data. Beyond financial penalties, failing to meet EPR obligations can harm your brand image and jeopardise your business relationships.

How do I calculate the amount of my EPR contributions for 2026?

The calculation is done by multiplying the tonnage of your packaging by your PRO's fee scale, then applying environmental modulations (bonus-malus). Fee scales vary by material: plastic, cardboard, glass, metal, etc. The modulation system can change your contribution by -100% to +100% depending on your eco-design criteria. For an accurate calculation, use the simulators available on PRO websites or consult an EPR compliance expert.

What documents do I need to keep to prove my EPR compliance?

You must keep for a **minimum of 5 years**: your PRO membership contracts, proof of payment of contributions, SYDEREP declarations, packaging purchase invoices, and your eco-design plan if applicable. These documents may be requested during a DGCCRF inspection. It is recommended to digitise and store these documents in a secure system to make them easier to retrieve.

My business distributes products in several European countries. Am I subject to French EPR rules?

You are subject to French EPR rules only for products **placed on the French market**. If you sell in several European countries, you must comply with the EPR obligations of each country where you sell your products. Each member state has its own rules and PROs. It is advisable to map your obligations country by country and get support from a European compliance specialist.

How do I obtain my EPR unique identification number (UIN) and how long does it take?

The UIN is obtained free of charge on the **filieres-rep.ademe.fr** portal by creating an account and entering information about your business and products. It usually takes **2 to 5 business days** to obtain after your file is validated. You must obtain a separate UIN for each relevant EPR scheme (packaging, textiles, electrical equipment, etc.). This number must then be mentioned in your general terms of sale and used for all your declarations.

Does the EPR contribution apply to reusable packaging such as pallets?

**Reusable** and **deposit-based** packaging can benefit from exemptions or reduced rates depending on their lifespan and actual reuse rate. Wooden pallets, for example, are often exempt if they are part of a functioning deposit scheme. However, you must be able to prove the reusable nature of the packaging and the return system in place. If in doubt, consult your PRO for a review specific to your situation. Source: Citeo, Circular economy and EPR: what changes in 2026