Get an Authorized Representative for Packaging in France with Citeo

A company that places packaging or packaged products on the French market without being established in France usually has two separate boxes to tick: joining an approved eco-organization for the packaging scheme, and appointing an Authorized Representative established in France.

Citeo is the historic eco-organization for the household packaging scheme in France, and it’s often the first name foreign producers run into when they start looking for a packaging EPR compliance solution.

This article walks through what Citeo is, when an Authorized Representative is actually required to join it, what that representative does day to day, and how Ekovio can take on the role for your company.

Summarize this article with:

🎯 TL;DR: Citeo and the Authorized Representative Requirement

• Citeo is one of three eco-organizations approved for the EMPAP household packaging scheme, alongside Adelphe and Léko, through December 31, 2029.
• Since July 10, 2026, any company subject to EPR that isn’t established in France must appoint a French Authorized Representative, by written mandate.
• An existing Citeo membership doesn’t by itself satisfy this requirement if your company still lacks a French establishment.
• Ekovio’s representation service is billed per action (registration, declaration, termination), separately from the eco-contributions you owe Citeo.

🔍 How We Checked This

The representative obligation described here comes from Article L. 541-10-9-1 of the French Environmental Code, in force since July 10, 2026. The EMPAP scheme approvals for Citeo, Adelphe, and Léko run through December 31, 2029, per their state approval. Where PPWR intersects with this topic, we cite Regulation (EU) 2025/40 directly. Pricing figures reflect Ekovio’s own published rates at the time of writing; check the Pricing page for the current schedule.

🏢 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 large majority of household packaging volumes declared in France, coordinates selective collection nationally, finances part of the sorting infrastructure, and supports local authorities with the cost of managing packaging waste.

Adelphe, a Citeo subsidiary, is also approved for EMPAP and focuses on the food and beverage sectors. Citeo, Adelphe, and Léko are the three eco-organizations currently approved for EMPAP, through December 31, 2029. A company subject to packaging EPR obligations has to choose one of the three to fulfill its declaration and contribution duties.

Eco-organization	Focus	EMPAP approval
Citeo	General household packaging, the largest volumes in the scheme	Through December 31, 2029
Adelphe (Citeo subsidiary)	Food and beverage sectors	Through December 31, 2029
Léko	General household packaging, an alternative to Citeo	Through December 31, 2029

⭐ Why Companies Choose Citeo

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 producers placing products on the market, French and foreign alike. For a foreign producer already selling in other European countries, that level of recognition can matter, especially when the goal is to work with a well-established counterpart on the French market.

That said, the right eco-organization is specific to each company. It depends on the sector, the volume of packaging placed on the market, and the level of support you expect.

⚖️ 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. The obligation applies equally to companies established elsewhere in the EU and to companies established outside the EU, and it covers the household packaging scheme, so it reaches any company that wants to join Citeo without a French establishment.

The representative must be a natural or legal person established in France, and the appointment has to be formalized through a written mandate that specifies the scope of the obligations covered. Separately, 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 goes well 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 has to be defined precisely. A company can 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:

Action	Price	What it covers
Registration or contract transfer	€149.99	Initial setup of your representation with Citeo, whether it’s a new membership or a transfer of an existing contract to Ekovio
Declaration	€99.99	Each declaration submitted to Citeo on behalf of your company
Termination	€49.99	Ending the representation mandate

These amounts come on top of the eco-contributions owed to Citeo, which are calculated from your declared volumes. Full pricing details are on our Pricing page.

✅ Steps to Become Compliant With Citeo

Compliance generally follows these steps:

1. Check whether the company qualifies as a producer under the packaging EPR scheme.
2. Determine whether the company is established in France or not.
3. If not established in France, appoint an Authorized Representative through a written mandate.
4. Choose Citeo, or another eco-organization approved for the EMPAP scheme.
5. Formalize the membership and obtain a Unique Identifier (IDU).
6. Declare the volumes of packaging placed on the market and pay the corresponding eco-contributions.
7. Maintain compliance over time, including when products or volumes change.

A company that was already a Citeo member before July 10, 2026 should still check whether its situation needs updating in light of the representative requirement.

🔄 Can You Switch Eco-Organizations After Choosing Citeo?

The EMPAP scheme includes several approved eco-organizations, so a company isn’t permanently tied to Citeo. Switching remains possible, but it has to take into account the contractual conditions in force and the timelines specific to each membership. Your Authorized Representative can support that analysis, whether the choice is Citeo, Adelphe, or Léko.

🤝 Ekovio, Your Authorized Representative for Citeo

Ekovio can act as your Authorized Representative for your membership with Citeo, either solely in that role alongside a company that already manages its own data and declarations, or as part of a more complete management of packaging EPR compliance that includes membership, declarations, and eco-contribution follow-up 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 Léko. The company chooses which one to join.

Do I need an Authorized Representative if I’m already a Citeo member?

An existing membership alone doesn’t demonstrate that the representative requirement is fulfilled. If your company isn’t 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, without being affiliated to 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 be updated to reflect the new eco-organization. Ekovio can support this transition, including a switch to Adelphe or Léko.

Organize Your Representation With Citeo

A company not established in France that places packaging on the French market has two things to check: 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 Léko, and 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.