FAQ – EPR Professional Packaging by the Ecomaison College – Webinar of 03/09/2026
When does the EPR Professional Packaging come into effect?
The EPR channel for professional packaging will become operational on July 1, 2026. From this date, the companies concerned will need to join an accredited eco-organization and declare their professional packaging placed on the market.
Which companies are concerned?
Companies concerned by the EPR professional packaging are:
Companies that for the first time circulate professional packaging in France, whether as manufacturers, importers, or distributors
Or/and companies that for the first time distribute pre-packaged products in France
The scope of entities that place professional packaging on the market is still currently under discussion within OCAPRO.
I am an importer: palettes go from the production site (e.g., Poland) to a French logistics warehouse of one of our clients. Are we concerned? If yes, how?
Yes, as you are the first entity placing these palettes on the French market. Specific webinars regarding the scope will be made available. Feel free to register for pre-registration on Ecomaison's site
However, certain issues regarding market placement are still being addressed at OCAPRO.
We are members of CITEO and Ecomaison; if I understand correctly, it is preferable that I choose Ecomaison?
Ecomaison will specifically assist its PMCB/DEA/JJ/ABJ channel members within the CITEO PRO governance if the member wishes.
What are the legal/contractual consequences of pre-registration?
Pre-registration allows you to stay informed about regulations and the tools Ecomaison provides to assist with this new compliance. Subsequently, a letter of intent will be sent for integration into Ecomaison College at Citeo Pro. However, this is just a letter of intent, so your company may decide not to join Ecomaison College if it chooses not to adhere to Citeo Pro upon the publication of the barèmes.
Will membership be through Citeo Pro or Ecomaison? Or could it be both?
It will be with a letter of intent via Ecomaison, to be in Ecomaison College: Building and House. This will then lead you to declare on Citeo's site. After signing the letter of intent: The contract will be with CITEO PRO and so will the membership. Then, Ecomaison teams will take charge of managing and tracking your client account under a multi-channel approach for our sectors.
I am a Citeo member for graphic paper and packaging, and an Ecomaison member (toys). Should I declare my professional packaging with Ecomaison or Citeo Pro?
You will be asked to join Citeo Pro via Ecomaison: practically, you will be a member of Citeo Pro and will make your market-specific declarations with Citeo Pro. At the same time, you will give a mandate to Ecomaison to represent you, advocate for your interests, and receive support from Ecomaison's teams.
When will the first declarations need to be made?
The first declaration will need to be made after joining an eco-organization, starting from July 1, 2026.
Will declarations apply to packaging prior to July 2026?
No. The first obligations should concern packaging placed on the market from July 1, 2026.
You will need to estimate your market placements for H2 2026, perhaps using an average of your 2025 placements.
Subsequently, an actual declaration will be requested in Q1 2027.
This new declaration will allow the eco-organization to make a regulation adjustment, whether up or down, depending on the estimation.
When will the eco-contribution rates be published?
The rates will be published after the official approval of eco-organizations by public authorities.
Likely between mid and late May
Will rates be identical across all eco-organizations?
The regulatory framework will be common, but the rates will be specific to each eco-organization.
Could there be multiple eco-organizations?
Yes, three eco-organizations are candidates: CITEO PRO, LEKO PRO, and TWICE.
How can we avoid double declarations?
Responsibility rests with the first entity placing the goods on the market in France.
Actors should clarify this point contractually within their supply chain.
Do SMEs or small volumes have simplified rules?
Simplified or flat-rate options may be provided for companies placing small volumes of packaging on the market.
In addition, micro-enterprises with fewer than 10 employees and turnover ≤ €2M will not be considered market players; the obligation would be shifted to their suppliers. The definitive texts have not yet been published
Do palettes need to be declared?
Yes, if you are the first entity to place the palette on the market, it must be declared.
However, it's important to note and track the reuse of the palette, if applicable, because there will be reductions in the eco-contribution for reused packaging.
How will packaging collection be organized? Will we need to implement specific containers?
This will be a financial EPR; there will be no operational measures implemented for private actors.
No containers will be provided for sorting packaging waste by the Eco organization. However, the holder of packaging waste can benefit from financial support, particularly for plastic, through their operator/collector.
What about packaging already covered by other EPR channels (e.g., PMCB)?
Packaging covered by another channel remains declared within that channel according to the regulatory scope.
Can the Ecomaison Pro Card be used to deposit professional packaging at recycling centers starting in July?
No, the ECOMAISON Pro Card will not allow the deposit of professional packaging.
I import toys from China. These are packaged in cartons bearing our name as the importer. I then distribute them to our clients (hypermarkets and other distributors).
Am I affected by the professional EPR in this case?
Yes, you are considered the market player for the professional packaging of these packaged products.
What about promotional point-of-sale materials (POSM)?
Yes, promotional point-of-sale materials (POSM) should be considered professional packaging.
Are cardboard labels measuring 12xh10cm affixed to products for sale affected by the Professional EPR?
Yes
If we have no factories in France but several factories in Europe that ship to the warehouses of our clients in France, do we need to declare all transportation packaging placed on the French market coming from our factories?
Yes, since this is a European EPR, you will be responsible for declaring the packaging going from your production sites to your clients in France.
Hello, for private label (PL) finished products, is the responsibility on the manufacturer or the entity that commissions the manufacturing?
The packaging of private label products depends on the entity that commissions the manufacturing (referred to as the "ordering party").