PPWR in France: What the Packaging Regulation Really Changes for Businesses

Since August 12, 2026, Regulation (EU) 2025/40 on packaging and packaging waste, the PPWR, has applied directly in France. No transposition law is needed: its obligations bind French companies just as they bind companies in the other 26 Member States.

But France was not starting from scratch. It already had one of the densest packaging rulebooks in Europe: a packaging EPR scheme since 1992, the 2020 AGEC law, the Triman logo and Info-tri sorting instructions, national reuse targets, bans on single-use plastics, and since July 2026 a mandatory EPR representative for foreign producers.

For a company selling in France, the real question is therefore not “what is the PPWR?” but “what changes compared with what I already do?”. Some French rules stay in place, others will have to align with the Regulation, and some EU obligations have no French equivalent yet.

This guide reviews, topic by topic, how the PPWR applies in France. For the Regulation’s overall timeline and what has applied at EU level since August 12, see our article PPWR 2026: what really changes on August 12.

Summarize this article with:

🎯 TL;DR: the PPWR in France

• The PPWR has applied directly in France since August 12, 2026, but it does not replace French packaging EPR: membership of Citeo, Adelphe or Léko and the UID remain mandatory.
• Triman and Info-tri remain required in France until EU harmonized labelling applies, on August 12, 2028 at the earliest.
• Some French bans from the AGEC law are weakened by the Regulation, as the case of plastic packaging for fruit and vegetables shows.
• France is far from the EU target of 90% bottle collection in 2029, and in September 2026 the government gave up on imposing a national deposit return scheme.
• French companies selling in other Member States must appoint an authorized representative there under Article 45 of the PPWR.
• The EU producer register and several implementing acts have not been adopted yet, so some rules are still to be clarified.

🔍 How We Checked This

This article is based on the text of Regulation (EU) 2025/40 published in the Official Journal of the EU, the French Environmental Code (including the provisions from the AGEC law and Article L. 541-10-9-1), the decision of the Conseil d’État (France’s highest administrative court) of November 8, 2024 on fruit and vegetable packaging, and communications from the French Ministry for Ecological Transition and Citeo. Several points remained uncertain at the time of writing (October 2026) and are flagged as such: the expected French decree aligning the PPWR with the AGEC law had not, to our knowledge, been published; the EU implementing acts on the producer register and harmonized labelling were still drafts; and the future of Triman depends on proceedings brought by the European Commission. This article is general information, not legal advice.

🇪🇺 A Directly Applicable Regulation, but France Keeps Control of Several Levers

An EU regulation does not need to be transposed: unlike the old 1994 packaging directive, the PPWR applies as it stands, on the same date, in every Member State. A French company cannot rely on the absence of national legislation to delay its EU obligations.

The Regulation still leaves each Member State several matters to organize itself. In France, these include:

• how EPR is organized: accreditation of eco-organizations, specifications, eco-contribution fee schedules, which remain a national competence framed by the Regulation;
• the producer register under Article 44, which each Member State must keep in an EU format that is still being adopted;
• penalties and enforcement, which each Member State sets for breaches of the Regulation;
• collection and deposit return, whose arrangements are chosen nationally to meet EU targets;
• certain national measures, which the Regulation allows to be kept under conditions, while others will have to be repealed or adapted.

A so-called “articulation” decree between the PPWR and the AGEC law was expected to sort out these rules. To our knowledge, it had not been published at the time of writing: in the meantime, French rules formally remain in force, except where they directly conflict with the Regulation, which takes precedence.

📋 French Law vs PPWR: What Changes, Topic by Topic

The table below compares, for the main topics, the existing French rule and what the PPWR adds, with what it concretely changes for a company selling in France.

Topic	Existing French rule	What the PPWR adds	What changes in France
EPR and eco-organizations	Membership of Citeo, Adelphe or Léko, declarations and eco-contributions (Environmental Code)	Common EU framework for packaging EPR (Article 45 onwards)	No immediate change: French EPR continues, its specifications evolve
Representative	Mandatory EPR representative for producers not established in France since July 10, 2026 (Art. L. 541-10-9-1)	Authorized representative in each Member State where the producer is not established (Art. 45)	Both rules apply, and French companies must appoint one outside France
Sorting information	Triman and Info-tri mandatory on household packaging	EU harmonized labelling (Art. 12), August 12, 2028 at the earliest	Triman kept for now, but set to give way to the EU label
Format bans	AGEC bans (single-use plastic, fruit and vegetables, etc.)	Harmonized restrictions in Annex V, from January 1, 2030	Some French bans are weakened or will have to align
Reuse	Minimum share of reused packaging: 5% in 2023, 10% in 2027 (Decree No. 2022-507)	Sector reuse targets from 2030 (Art. 29)	French targets remain, EU targets are added by sector
Deposit return	No national deposit scheme for plastic bottles	Mandatory deposit return by January 1, 2029 unless exempted (Art. 50)	Open question: France is far from the exemption thresholds
Recyclability	Eco-modulation of fees (bonuses and penalties)	Recyclable packaging mandatory from 2030, with performance grades (Art. 6)	Recyclability becomes a condition for market access, not just a pricing criterion
Recycled content	National targets and eco-modulation bonuses	Minimum recycled plastic content from 2030 (Art. 7)	New numerical obligation by type of plastic packaging
PFAS	No general restriction specific to packaging	PFAS limits for food-contact packaging since August 12, 2026 (Art. 5)	Applies now
Register	UID issued via the eco-organization or SYDEREP	National producer register in an EU format (Art. 44)	Format being adopted, link with the UID to be clarified
Penalties	EPR administrative penalties, marketplace checks	Penalties set by each Member State	French regime to be adapted to the new obligations

🏷️ Triman and Info-tri vs EU Harmonized Labelling

Triman and Info-tri are a French specialty: since the AGEC law, most household packaging sold in France must carry the Triman logo and a sorting instruction. Article 12 of the PPWR provides for harmonized labelling across the EU, with a pictogram showing the packaging’s material composition that consumers will also find on collection bins.

This EU labelling depends on implementing acts that the Commission was due to adopt by August 12, 2026 and that were still not adopted at the end of September 2026. It will become mandatory from August 12, 2028, or 24 months after those acts enter into force if that date is later. From then on, Member States will no longer be able to impose their own sorting labels alongside the EU label.

In addition, the European Commission considers the French Triman requirement an obstacle to the free movement of goods and has brought proceedings against France, referred to the Court of Justice of the EU according to several specialist sources. Pending a ruling or the application of harmonized labelling, Triman and Info-tri remain mandatory in France.

🚫 French Bans and the EU Restrictions in Annex V

The AGEC law introduced several packaging format bans in France, ahead of Europe. The PPWR, for its part, sets out in Article 25 and Annex V a harmonized list of restrictions applying from January 1, 2030: single-use plastic packaging for fresh fruit and vegetables under 1.5 kg, packaging for food and drinks consumed on the premises and individual portions (condiments, sauces) in the hospitality sector, miniature toiletries in hotels, very lightweight plastic carrier bags and plastic grouped packaging, among others.

Fruit and vegetables illustrate the tension between the two levels. The AGEC law banned their sale in plastic packaging for lots under 1.5 kg, but on November 8, 2024 the Conseil d’État annulled the implementing decree of June 20, 2023: the European Commission had asked France to postpone its adoption while the Regulation was being prepared, and that postponement was mandatory. The EU restriction, with its own derogations, now takes over by 2030.

More generally, the PPWR limits a Member State’s ability to ban the placing on the market of packaging that complies with the Regulation. Some earlier national measures can be kept under the conditions set out in the text, others will have to be reviewed. Until the articulation decree is published, the prudent approach is to keep applying the French rules in force while preparing for the 2030 restrictions.

♻️ Reuse: French Targets and the PPWR’s 2030 Targets

France already requires a minimum share of reused packaging. Decree No. 2022-507 of April 8, 2022 sets a trajectory from 5% in 2023 to 10% in 2027 for producers placing at least 10,000 units of packaged products on the market each year, with steps depending on their turnover. This obligation can be met individually, collectively or through the eco-organization.

Article 29 of the PPWR sets sector reuse targets from 2030, with higher indicative targets for 2040. The main ones concern transport and grouped packaging (including pallets and crates, with exemptions such as cardboard boxes) and certain beverages. For a French company, the two layers add up: the overall national target continues to apply, and the EU targets come on top in the sectors concerned.

🥤 Deposit Return: France and Article 50

Article 50 of the PPWR requires Member States to separately collect, from 2029, at least 90% of single-use plastic bottles and beverage cans, by setting up a deposit return system. A Member State can be exempted if it reaches at least 80% separate collection in 2026 and submits a credible plan to reach 90%, to be notified by January 1, 2028 at the latest.

France is far from that: according to Citeo, the collection rate for plastic beverage bottles was around 58% in 2024. Yet on September 4, 2026, the government announced it was giving up on imposing a national deposit scheme on local authorities, in favor of a voluntary, territorial approach. How France will meet the EU’s 2029 target therefore remains to be clarified.

🧾 Producer Register, UID and SYDEREP

In France, every producer subject to packaging EPR already has a unique identifier (UID), obtained via its eco-organization or via SYDEREP, the online service of ADEME (the French environment agency). This UID must appear in the terms and conditions of sale and be provided to marketplaces.

Article 44 of the PPWR requires each Member State to keep a producer register in a harmonized format. The implementing act setting this format had not been adopted at the time of writing: a draft was put out for consultation between August and September 2026, and national registers will have to comply within 18 months of its entry into force. Sources disagree on whether the French UID will be enough as it stands or whether an additional step will be needed. Keep your UID up to date and wait for ADEME’s guidance before registering again.

🤝 Authorized Representative: the PPWR Works Both Ways

For a foreign producer selling in France, two rules overlap. Since July 10, 2026, Article L. 541-10-9-1 of the French Environmental Code has required an EPR representative established in France, for every scheme. Article 45 of the PPWR, for its part, requires an authorized representative for packaging EPR in each Member State where the producer is not established. One well-drafted mandate can meet both for France. We cover this obligation in our guide to the EPR representative in France, and sector by sector in our sector-by-sector EPR representative guide.

For a French company selling elsewhere in the EU, this is the most often overlooked point. A brand established in France that ships packaged products directly to customers in Germany, Spain or Italy must, under Article 45, appoint an authorized representative in each of those countries, in addition to its local EPR obligations. A Commission “omnibus” proposal aims to suspend this requirement until 2035. On 20 October 2026, the European Parliament voted to reserve it for micro and small enterprises established in the EU, but the Council has not yet adopted its position and the text has not been adopted: Article 45 has applied since August 12, 2026. What this vote changes, and does not change, for the French representative obligation is explained in our article EPR Simplification for SMEs: The European Parliament Vote Does Not Remove the French Representative Obligation.

📦 Professional Packaging: the 2027 Scheme Within the PPWR Framework

France chose to create a dedicated EPR scheme for professional packaging, separate from household packaging. After several delays, the ministry announced on July 28, 2026 that it would go live operationally on January 1, 2027, with three accredited eco-organizations (Citeo Pro, Léko Pro and Twiice) and quarterly declarations. This scheme fits within the general packaging EPR obligation in the PPWR, which also covers professional packaging. Details are in our article on the new professional packaging EPR scheme.

⚖️ Enforcement and Penalties in France

The PPWR leaves it to each Member State to set “effective, proportionate and dissuasive” penalties. In France, breaches of EPR obligations already expose companies to administrative penalties, and marketplaces must check their sellers’ UID, failing which they become liable for those sellers’ EPR obligations themselves.

The French regime will have to be adapted to cover the new obligations under the Regulation (PFAS, recyclability, recycled content, labelling). In practice, the most immediate risk for a company remains commercial: a listing removed by a marketplace or a retailer refusing to stock products, because the company cannot prove its EPR and PPWR compliance.

🧭 Self-Check: What the PPWR Changes for You in France

Answer the four questions below to get a first list of actions. This tool runs entirely in your browser and collects no data. It does not replace an analysis of your situation: for a definitive answer, get started with Ekovio.

🗓️ PPWR Roadmap in France, 2026 to 2030

Date	Obligation	Source
July 10, 2026	Mandatory EPR representative for producers not established in France, all schemes	France (Art. L. 541-10-9-1)
August 12, 2026	General application of the PPWR, PFAS limits for food packaging, authorized representative in each Member State	EU (Regulation 2025/40)
January 1, 2027	Operational start of the professional packaging EPR scheme	France
January 1, 2028	Deadline for notifying deposit return exemptions, with an implementation plan	EU (Art. 50)
August 12, 2028 at the earliest	EU harmonized labelling mandatory, end of national sorting labels	EU (Art. 12)
January 1, 2029	90% separate collection target for bottles and cans, deposit return unless exempted	EU (Art. 50)
January 1, 2030	Mandatory recyclability, minimum recycled content, Annex V restrictions, reuse targets	EU (Art. 6, 7, 25, 29)

🤝 Ekovio: Your French EPR and PPWR Compliance in One Place

Ekovio supports French and foreign companies across all their packaging obligations: membership and declarations with eco-organizations, UID, eco-contribution tracking, EPR representative in France and authorized representative in other EU countries. Our representation offer is described on our French EPR Representative page, and the setup process in EPR Authorized Representative in 5 steps.

As PPWR implementing acts are adopted and France publishes its articulation texts, we build these changes into the platform, so you do not have to track two moving regulations on your own. Prices are published on our Pricing page.

❓ FAQ: the PPWR in France

Does the PPWR replace the French AGEC law?

No. The PPWR applies directly and takes precedence over conflicting national rules, but the AGEC law remains in force for everything that does not conflict with it, in particular how EPR is organized. Some French provisions will nevertheless have to be adapted, which an expected articulation decree is due to clarify.

Is Triman still mandatory under the PPWR?

Yes, for now. Triman and Info-tri remain required in France until the EU harmonized labelling under Article 12 applies, on August 12, 2028 at the earliest. From that date, Member States will no longer be able to impose their own sorting labels alongside it.

Will deposit return become mandatory in France?

The PPWR requires deposit return for plastic bottles and cans from 2029, unless a Member State reaches at least 80% collection in 2026. France is far from that, but in September 2026 the government gave up on imposing a national deposit scheme on local authorities. How France will meet the EU target remains to be clarified.

Does a French company need to appoint a PPWR representative?

Not in France, since it is established there. However, if it sells packaged products directly in other Member States without being established there, it must appoint an authorized representative in each of those countries under Article 45 of the PPWR.

Is my French UID enough for the PPWR register?

This is still uncertain. Article 44 provides for national registers in an EU format whose implementing act had not been adopted in October 2026. Keep your UID up to date and wait for ADEME’s guidance before registering again.

Does my current packaging remain compliant until 2030?

For most design obligations, yes: recyclability, minimum recycled content and the Annex V restrictions apply from 2030. The PFAS limits for food packaging and the authorized representative requirement, however, have applied since August 12, 2026.

Who enforces the PPWR in France?

The PPWR lets each Member State organize enforcement and set penalties. In France, the authorities already responsible for EPR and product safety are expected to step in, with the penalty regime to be adapted to the Regulation’s new obligations.

Review Your PPWR Compliance in France

The PPWR does not wipe out French packaging law: it sits on top of it, replaces some parts and weakens others. For a company selling in France, the challenge is to know exactly which rules apply to its packaging today, and which ones are coming by 2030. Ekovio helps you track both levels in one place.