France postpones EPR obligation for commercial packaging to July 2026
France confirms timeline for EPR waste stream “commercial packaging” – launch on 1 July 2026
France is continuing to expand extended producer responsibility: the French government has confirmed the timeline for the new waste stream “commercial packaging” under Extended Producer Responsibility (EPR). This provides companies placing packaging on the French market with greater planning certainty, particularly with regard to upcoming organisational and financial requirements.
Entry into force on 1 July 2026 (not at the start of the year)
Important for implementation: the new EPR waste stream will take effect on 1 July 2026. A start date of 1 January 2026 is therefore off the table. This postponement provides additional lead time to prepare internal processes and clarify responsibilities.
Clear distinction: household packaging vs. commercial packaging
France defines the relevant packaging by distinguishing between two categories:
Household packaging: Packaging of products that are consumed or used by households – or are expected to be.
Commercial packaging: All product packaging that does not qualify as household packaging.
This brings packaging from the B2B environment more strongly into focus, i.e. packaging that typically arises in professional supply chains, in trade, or at commercial end users.
Systems must be approved by the end of February 2026
Before companies can implement specific obligations, the responsible take-back and producer responsibility organisations must first be approved. These organisations must submit their applications by 28 February 2026. Only after that will it become clear how practical implementation will be organised and which structures will be established in the market.
No retroactive contributions
Another key point: contributions may not be charged retroactively. Fees may be levied at the earliest from 1 July 2026. This reduces short-term financial uncertainty and provides companies with greater transparency for budget planning.
What does this mean for companies right now?
At present, there is no immediate need for action. Currently, no take-back system for commercial packaging has been approved and no EPR fees have been published. Nevertheless, it is advisable to monitor developments at an early stage, especially if France is a relevant sales or production market.
As soon as approved systems and fee models are published, it will be crucial to correctly classify your packaging flows and to implement the future requirements for registration, reporting and financing properly.
If you have any questions, please do not hesitate to contact us.
