For years, commercial packaging stayed outside the extended producer responsibility framework. That time is over. The decree of 17 November 2025, followed by the scope order of 2 December 2025, set the framework. The scheme comes into force on 1 July 2026.
Who is affected
Any business that places commercial packaging on the French market, intended for another business, is covered. This includes manufacturers, importers and distributors engaged in buy-and-resell activity. Volume does not come into it. From the very first packaging item placed on the market, you are within scope.
Three producer responsibility organisations, not one
We have grown used to reducing EPR to Citeo. For this scheme, that would be a mistake. Three producer responsibility organisations are positioning themselves to manage commercial packaging: Citeo Pro, Léko and Twiice.
Léko, already well established in household packaging, arrives with its Léko Pro offering. Twiice, for its part, is moving forward in partnership with Valobat, a player drawn from the construction sector. The official publication of the approvals is expected before the summer of 2026.
In practice, you will have a choice. Competition between the three will play out on fee schedules and on the associated services. That is no small matter for a business looking to keep its costs under control.
What has not yet been settled
The framework is set, but not everything is fixed. The fate of grouping and transport packaging is still awaiting a decision by the public authorities. The fee schedules have not been published. Nor have the precise reporting arrangements. So you have to move ahead while keeping an eye on the texts still to come.
The timeline to remember
1 July 2026 marks the start of the scheme and of contributions. By that date, you must have joined an approved producer responsibility organisation, or set up your own individual system. The first declaration will cover your volumes placed on the market, according to arrangements that the public authorities will specify by then.
Three habits to adopt now
First, map your commercial packaging and estimate your volumes by material. Next, clarify your exact role: manufacturer, importer, distributor or principal. That role determines your obligations. Finally, follow the publication of the approvals and fee schedules, so you can choose your producer responsibility organisation on an informed basis rather than at the last minute.
EPR for commercial packaging is no longer a distant project. It is a deadline. And 1 July 2026 is already tomorrow.