What to grasp before anything else
French manufacturers have to answer to the AGEC law and the PPWR at the same time. The two texts do not speak the same language, do not share the same dates, and will never be fully aligned.
The PPWR is a European Regulation, not a Directive. Unlike a directive, it does not need to be transposed into national law: it applies directly across all 27 Member States. And under the principle of the primacy of EU law, it takes precedence over national legislation wherever the two conflict on the same subject matter.
Article 4 of the PPWR introduces an important nuance: Member States may keep stricter national measures in place, provided they were adopted before 1 January 2025 and notified to the Commission. AGEC measures adopted before that date remain valid. Those introduced afterwards, on subjects covered by the PPWR, are in principle incompatible.
A practical consequence that is often overlooked: France can no longer introduce new packaging obligations that diverge from the PPWR on the subjects it covers. Existing AGEC measures remain valid if they predate 2025. But French regulatory ambition is now capped by the European regulation on the harmonised subjects.
The two texts at a glance
| Criterion | AGEC (France) | PPWR (Europe) |
|---|---|---|
| Type | French national law | Directly applicable EU regulation |
| Scope | France only | 27 Member States |
| Adoption | February 2020 | December 2024 |
| Final horizon | End of single-use plastics in 2040 | 15% waste reduction by 2040 |
The real operational divergences
What creates a genuine burden for French manufacturers:
Sorting labels
The Triman has been mandatory in France since 2022. Billions of units have already been printed. The PPWR provides for a new EU-wide harmonised system based on pictograms (with an optional QR code alongside), expected in 2028, which will progressively replace the national systems. This is a clear conflict: existing Triman investment will be partly written off.
Recyclability
The AGEC law sets a target of 100% recyclable packaging in 2025, assessed against the Citeo framework. The PPWR introduces its own recyclability criteria (classes A to E), published in 2028, with a compliance obligation in 2030. The two frameworks do not always produce the same result.
Fresh fruit and vegetables
The AGEC law has banned plastic for fruit and vegetables since 2022, with a broad scope and specific French exemptions. The PPWR provides for the same ban in 2030 (Annex V) with a different perimeter and different exemptions. The overlap creates grey areas for companies selling under both frameworks.
Packaging EPR
Household EPR (Citeo) is operational in France. Commercial EPR (EPRO) comes into force in July 2026. The PPWR, for its part, provides for EPR contributions modulated according to recyclability classes, which will not be defined until 2028 at the earliest. A recalibration of contributions is therefore unavoidable.
Beverage reuse
The AGEC law sets no equivalent quantified target on this point. The PPWR requires 10% of volume in reusable packaging from 2030 for beverage distributors. This obligation applies directly in France, on top of the AGEC framework.
What sector professionals are raising
Manufacturers and federations: the Triman represents years of investment in consumer education and artwork redesign. Its gradual write-off by the PPWR system is an uncompensated cost that no one is putting an official figure on.
Specialist lawyers: the precise dividing line between AGEC measures predating 2025 (retained) and those coming after (potentially incompatible) has not yet been clarified by the French authorities. A temporary legal vacuum that companies are working through without any official guide.
SMEs and mid-caps: dual compliance with the PPWR and AGEC requires two documentation systems, two recyclability references, two timetables. Large groups have dedicated teams. SMEs often have just one person to manage the lot.
The four priority workstreams for French manufacturers
Workstream 1: dual-compliance mapping
For every packaging format in the portfolio, establish its compliance against the current AGEC law AND against the 2030 PPWR direction of travel. The two frameworks do not always produce the same result. The gaps are the areas to treat first.
Workstream 2: artwork and labelling
Do not invest heavily in artwork redesigns based solely on the current Triman if the products concerned have an artwork life cycle longer than 3 years. The transition to the PPWR system will begin in 2028. Any artwork investment planned for 2027 or later should reserve a zone for the harmonised pictogram labelling (with an optional QR code alongside) and be compatible with both systems during the period of coexistence.
Workstream 3: Commercial Packaging EPR (urgent)
Commercial Packaging EPR comes into force on 1 July 2026 in France, six weeks before the PPWR. The definitions of “producer” are not identical in the two texts. Legal teams need to clarify their company’s status under both regimes simultaneously before that date.
Workstream 4: monitoring the delegated acts
More than thirty PPWR delegated acts are due to be published between 2026 and 2030. Each publication can shift the priorities of the compliance plan. A quarterly monitoring process covering DG Environment publications is indispensable, alongside national AGEC monitoring.
What this says about the state of packaging regulation in France
France had committed to an ambitious trajectory with the AGEC law. It moves faster than Europe on certain subjects: plastic bans, the Triman, the 2040 trajectory. The PPWR now arrives overhead, with a different perimeter, a different timetable and a superior legal status.
The result is neither a major conflict nor a perfect harmonisation. It is a complex layering, with areas of complementarity and areas of tension, that French manufacturers will have to manage for several more years in the absence of a clear national doctrine.
The teams that have already worked on AGEC compliance have a real head start on the PPWR requirements. The recyclability frameworks, the documentation processes and the field habits are there. It is a matter of adapting them, not starting from scratch.
Sources: AGEC law no. 2020-105. Regulation (EU) 2025/40, Article 4. European Commission guidance of 30 March 2026. commercial-packaging EPR decree, November 2025. Content provided for information purposes only; it does not constitute legal advice.
Cover photo: Scott Graham on Unsplash