France
Who the graphic paper rules cover in France
If you sell printed products online, the marketplace is a gate you should know about. Under article L541-10-9 the platform is liable for its third-party sellers' graphic paper EPR in France unless you prove compliance, so a missing registration can block a listing.
Graphic paper here means the non-packaging paper, newspapers, magazines, office paper and advertising print. There is no small-producer exemption, so the duty starts at your first unit. You are covered if any of these fit.
- You place graphic paper on the French market, from the first unit.
- You publish or distribute printed matter such as catalogues or advertising mail.
- You already report household packaging, in which case paper now sits in the same scheme.
- You sell into France without a French establishment.
How graphic paper producers register in France
You do not register directly. You join an approved EMPAP éco-organisme, Citeo, Adelphe or Leko, and it enrols you in SYDEREP and issues your IDU, one identifier per producer per filière.
That IDU then has to appear in your terms of sale and on your website. It is the same registration proof used across EPR in France. Because paper and household packaging are now one filière, the scheme you join is usually the same one that already handles your packaging.
Reporting graphic paper volumes in France
Reporting is annual. The mechanics read most clearly as a short sequence.
| Step | Where | When |
|---|---|---|
| Join an EMPAP scheme | Citeo Adelphe or Leko | before your first sale |
| Receive your IDU | through the scheme into SYDEREP | on joining |
| Declare your volumes | to your éco-organisme | each year |
| Scheme files the data | ADEME via SYDEREP | by 30 April |
Cost sits inside this same flow rather than as a separate bill. You pay a per unit or per tonne éco-contribution to your éco-organisme, modulated under the AGEC design rules, with press publications keeping their own éco-modulation.
There is no ADEME fee for the register and no statutory rate to quote.
Selling graphic paper into France from abroad
Selling in from abroad does not lift the duty. A non-established producer complies by joining an EMPAP scheme, which registers it in SYDEREP.
The older mandataire route was partly annulled by the Conseil d'État on 10 November 2023, so lean on scheme membership and treat any specific authorised representative rule as unsettled.
Because graphic paper now sits inside the EMPAP packaging scheme, a producer who already declares packaging is very likely declaring paper on the same invoice, and a single missing IDU can still draw the flat 30,000 euro penalty.
The one dated change to watch is the merger itself, live since 1 January 2024, which folded graphic paper into the household packaging filière and is the clearest case of the pan-European trend to merge paper into packaging.
Frequently asked questions about graphic paper EPR in France
The questions publishers and print buyers raise most about the French scheme.
Who has to register for graphic paper EPR in France?
Anyone placing graphic paper on the French market, from the first unit, including publishers and distributors of printed matter. You join an EMPAP éco-organisme, Citeo, Adelphe or Leko, which enrols you in SYDEREP and issues your IDU.
Is there a threshold or exemption for small producers in France?
There is no general de minimis, so the duty applies from the first unit placed on the French market. Some schemes offer a simplified declaration for small volumes, but that eases the paperwork rather than removing the obligation.
Do foreign or online sellers need an authorised representative in France?
A non-established producer complies by joining an EMPAP scheme, which registers it in SYDEREP. The formal mandataire route was partly annulled in 2023 and its codified form is unsettled, so scheme membership is the dependable path.
What happens if I sell without registering in France?
Enforcement is administrative under article L541-9-5. Fines run up to 1,500 euros per unit or tonne for an individual and 7,500 euros for a company, with a flat 30,000 euros for failing to register or for a missing IDU and an astreinte up to 20,000 euros a day.
What changes next for graphic paper EPR in France?
The defining change already happened, the 2024 merger of graphic paper into the household packaging filière. From here the two move together, so a producer should treat paper as part of the same EMPAP registration rather than a separate scheme.
