If your company places packaging or packaged products on the French market without being established in France, two separate requirements generally apply: joining an approved eco-organization for the packaging scheme, and, in many cases, appointing an Authorized Representative established in France.
Citeo is the historic eco-organization for the household packaging scheme in France. It is often the first name foreign producers encounter when looking for a packaging EPR compliance solution.
This article explains what Citeo is, why an Authorized Representative may be required to join it, and how Ekovio can act in this role for your company.
What Is Citeo?
Citeo is an eco-organization approved by the French State for the household packaging and graphic papers scheme (EMPAP).
It manages the vast majority of household packaging volumes declared in France.
Citeo ensures the national coordination of selective collection, finances part of the sorting infrastructure, and supports local authorities with the costs of managing packaging waste.
Adelphe, a subsidiary of Citeo, is also approved for the EMPAP scheme and focuses on the food and beverage sectors.
Citeo, Adelphe and Leko are the three eco-organizations currently approved for the EMPAP scheme, until December 31, 2029.
A company subject to packaging EPR obligations must choose one of these eco-organizations to fulfill its declaration and contribution obligations.
Why Choose Citeo for Your Packaging Compliance?
Citeo is the oldest and most established eco-organization in the household packaging scheme.
Its size and track record make it a reference point for many producers placing products on the market, both French and foreign.
For a foreign producer, this level of recognition can be a relevant factor, particularly when the company already sells in other European countries and wants to work with a well-established counterpart on the French market.
The choice of eco-organization nonetheless remains specific to each company. It depends on the sector of activity, the volume of packaging placed on the market, and the level of support expected.
Do You Need an Authorized Representative to Join Citeo?
Since July 10, 2026, Article L. 541-10-9-1 of the French Environmental Code requires a company subject to EPR that is not established in France to appoint a representative established in France.
This obligation applies to companies established in another European Union country as well as to companies established outside the European Union.
It applies to the household packaging scheme, and therefore to any company that wants to join Citeo without being established in France.
The representative must be a natural or legal person established in France. The appointment must be formalized through a written mandate specifying the scope of the obligations covered.
The European Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40), applicable from August 12, 2026, also provides, under Article 45, for the appointment of an authorized representative for EPR in certain cross-border situations.
In practice, a company not established in France that wants to join Citeo will, in most cases, need a French Authorized Representative to formalize its membership and follow up on its obligations.
What Your Authorized Representative Does With Citeo
The role of the Authorized Representative goes beyond signing a mandate.
It generally covers:
- Registering the membership with Citeo on behalf of the company.
- Declaring the quantities and categories of packaging placed on the market.
- Calculating and following up on the eco-contributions owed to Citeo.
- Updating the declared information whenever the company’s activity changes.
- Handling routine exchanges with Citeo related to the company’s EPR compliance.
The exact scope of the mandate must be defined precisely. A company may choose to delegate all of these tasks to its Authorized Representative or keep part of them in-house.
How Much Does an Authorized Representative for Citeo Cost?
The cost of representation is separate from the eco-contributions paid to Citeo, which depend on your declared packaging volumes. At Ekovio, the Authorized Representative service is priced per action rather than through a fixed subscription.
- Registration or contract transfer: €149.99
- Declaration: €99.99
- Termination: €49.99
Registration or contract transfer covers the initial setup of your representation with Citeo, whether you are starting a new membership or transferring an existing contract to Ekovio.
Each declaration submitted to Citeo on behalf of your company is billed at €99.99.
A termination fee of €49.99 applies if you end the representation mandate.
These amounts are in addition to the eco-contributions owed to Citeo, which are calculated based on your declared volumes. Full pricing details are available on our Pricing page.
Steps to Become Compliant With Citeo
Compliance generally follows these steps:
- Check whether the company qualifies as a producer under the packaging EPR scheme.
- Determine whether the company is established in France or not.
- If the company is not established in France, appoint an Authorized Representative through a written mandate.
- Choose Citeo, or another eco-organization approved for the EMPAP scheme.
- Formalize the membership and obtain a Unique Identifier (IDU).
- Declare the volumes of packaging placed on the market and pay the corresponding eco-contributions.
- Maintain compliance over time, including when products or volumes change.
A company already a Citeo member before July 10, 2026 should also check whether its situation needs to be updated in light of the representative requirement.
Can You Switch Eco-Organizations After Choosing Citeo?
The EMPAP scheme includes several approved eco-organizations. A company is therefore not permanently tied to Citeo.
Switching eco-organizations remains possible, but it must take into account the contractual conditions in force and the timelines specific to each membership.
Your Authorized Representative can support this analysis, whether the choice is Citeo, Adelphe, or Leko.
Ekovio, Your Authorized Representative for Citeo
Ekovio can act as your Authorized Representative for your membership with Citeo.
Ekovio can act solely in this role, alongside a company that already manages its own data and declarations.
Ekovio can also take on a more complete management of packaging EPR compliance, including the membership, declarations, and follow-up of eco-contributions with Citeo.
The exact scope of the assignment is defined contractually, based on your company’s organization and needs.
Start your free trial with Ekovio to organize your representation with Citeo.
Frequently Asked Questions About the Authorized Representative and Citeo
Am I Required to Choose Citeo for My Packaging Compliance?
No.
The EMPAP scheme includes several approved eco-organizations, including Citeo, Adelphe and Leko. The company chooses which eco-organization to join.
Do I Need an Authorized Representative if I Am Already a Citeo Member?
An existing membership is not, by itself, sufficient to demonstrate that the representative requirement is fulfilled.
If your company is not established in France, its situation must be reviewed against the obligation applicable since July 10, 2026.
Is Ekovio Affiliated With Citeo?
No.
Ekovio is an independent service provider that supports companies with their EPR compliance, including their relationship with Citeo. Ekovio is not affiliated with any particular eco-organization.
Can I Keep Managing My Declarations While Ekovio Handles Representation?
Yes.
Ekovio can act solely as your Authorized Representative, while your company retains operational management of its data and declarations.
What Happens if I Switch Eco-Organizations After Appointing an Authorized Representative?
The mandate must then be updated to reflect the new eco-organization concerned.
Ekovio can support this transition, including a switch to Adelphe or Leko.
Organize Your Representation With Citeo
A company not established in France that places packaging on the French market must check two things: its membership with an approved eco-organization, and its obligation to appoint an Authorized Representative.
Citeo is one of the eco-organizations approved for the EMPAP scheme, alongside Adelphe and Leko.
Ekovio can act as your representative with Citeo, on its own or as part of a more complete management of your packaging EPR compliance.
Start your free trial with Ekovio to set up your Authorized Representative with Citeo.
