Manufacturer responsibility for commercial packaging in France

The REP for commercial packaging does not only concern French companies. Any company that imports packaged products for professionals on the French market – including from Switzerland – can be considered a “producer”. Swiss exporters should therefore start to identify their affected packaging, to become a member of an eco-organization and to implement the registration procedures as soon as possible in order to ensure the continuity of their activities in France.

What is the new REP for commercial packaging? What are its objectives?

The REP is based on the polluter-pays principle: manufacturers must finance the disposal of the packaging they place on the market at the end of the product life cycle. Until now, French regulations have focused on, among other things, household packaging and are now being extended to packaging used by professionals.

This new procedure is based on the French circular economy law and aims to improve the collection, recycling and reuse of large quantities of industrial and commercial packaging. It concerns several million tons of commercial packaging with reinforced objectives in terms of circularity and waste reduction.

Information on French environmental regulation, the AGEC Law and the PPWR can be found here.

Important dates: What changes on 1 July 2026?

The decree on the REP procedure came into force at the beginning of 2026, but the financial obligations for companies are progressive.

• January 1, 2026: The REP procedure enters into force by regulation.
• February 28, 2026: Submission of applications for the accreditation of eco-organizations.
• July 1, 2026: Start of payment of ecological fees by companies.

This delay gives companies a few months to organize themselves and adapt their processes before the first registrations and fee payments are made.

Who is affected? A direct challenge for Swiss exporters

The term “manufacturer” includes the company that first introduces a commercial packaging on the French market. This can be:

• a packaging manufacturer,
• an importer or a distributor,
• a company that sells packaged products to businesses.

Specifically, a Swiss company that exports to France can be considered a manufacturer if it introduces packaged products into the French commercial economic circuit.

Which commercial packaging is affected?

The scope covers a wide range of packaging used in commercial activities and made of different materials (plastic, wood, metal, cardboard, glass or textiles), in particular:

• certain special packaging (large containers for bulk goods, canisters, etc.),
• Transport or logistics packaging (pallets, boxes, etc.),
• Outer packaging,
• Sales packaging for commercial users,
• Glass packaging in the medical and veterinary fields.

However, a packaging that does not fall under these five categories may be considered as commercial packaging if it exceeds certain thresholds in terms of weight, volume, quantity or thickness. The details of these criteria are set out in the regulation on scope on the Légifrance website.

How the procedure works: the role of the eco-organizations

By decree of 3 June 2026, three environmental organizations have been officially approved for the extended producer responsibility (EPR) area for commercial packaging: Citeo Pro, Léko Pro and Twiice. Companies can now join one of these three organizations before the environmental levies come into effect on 1 July 2026.

The environmental contribution serves to finance the collection, recycling and promotion of the reuse of packaging.

How can you prepare yourself now?

For Swiss companies that export to France, it is advisable to plan several steps ahead:

1. 
   Determine your status Check whether your company is considered a “producer” in the French sense, particularly in the case of the import or marketing of commercial packaging.
2. Affected Packaging Captures
   Listing of Transport, Re-Packaging, or Sales Packaging Used for the French Commercial Market.
3. 
   Companies can join the approved structures before the start of fee payments in July 2026.

Support for Swiss companies

Switzerland Global Enterprise and Swiss Business Hub France are available to support Swiss companies and their subsidiaries with their network of experts in these matters.