AGEC EPR and financing 1 July 2026

AGEC law — EPR for commercial and industrial packaging

Any business placing products on the market in commercial or industrial packaging must register with Citeo Pro and contribute financially from 1 July 2026 — even if it does not make its own packaging.

What the official text says

AGEC law, Article L541-10 and Decree No. 2025-1423 of 17 November 2025

Extension of extended producer responsibility to industrial and commercial packaging and to packaging used in collective catering. Takes effect on 1 July 2026. Anyone placing packaged products on the market is treated as the producer of that packaging.

What it really means

This is the 2026 French regulatory development that affects the largest number of businesses. Roughly 8 million tonnes of industrial and commercial packaging a year — previously subject to no end-of-life contribution at all — now fall within the scope of an EPR scheme.

The principle is identical to the household EPR scheme: whoever places the packaging on the market is responsible for funding its end of life. But the scope here is wider — it covers all packaging that does not end up in household collection bins. That includes transport packaging, collective-catering packaging and B2B delivery packaging.

A point to watch for businesses operating across both household and commercial markets: the definitions of producer in the commercial-packaging EPR scheme and in the PPWR are not identical. Legal teams need to read both texts in parallel to make sure the same packaging reference is not declared twice, or missed entirely in one of the two systems.

Area of uncertainty as it stands

The contribution scales have no established average rate, given the very wide range of obligated parties involved. The first scales will be refined over the course of the first year. The precise scope for certain sectors, such as delivered catering, is still under discussion.

Impact by sector

Food and drink ▼

Questions to ask yourself

Do you place products on the market in secondary or tertiary packaging intended for professional buyers?

Are you registered with Citeo Pro?

Recommended actions

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Estimate the volumes of commercial packaging placed on the market to calculate the contribution

Cosmetics and personal care ▼

Questions to ask yourself

Is your secondary packaging distributed B2B or B2C?

Recommended actions

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Distinguish household flows (already covered by the household Citeo EPR scheme) from commercial flows (the new commercial-packaging EPR scheme)

Pharmaceuticals ▼

Questions to ask yourself

Does your pharmaceutical distribution packaging fall within the scope of the commercial-packaging EPR scheme?

Recommended actions

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Check the classification against the Citeo Pro sector guides

Foodservice and HORECA ▼

Questions to ask yourself

Is your collective-catering packaging covered by the commercial-packaging EPR scheme?

Recommended actions

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Collective-catering operators are explicitly within scope

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E-commerce and logistics ▼

Questions to ask yourself

Is your shipping packaging collected through the household or the commercial stream?

Recommended actions

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E-commerce shipping packaging falls within the scope of the commercial-packaging EPR scheme depending on the final recipient

B2B industrial packaging ▼

Questions to ask yourself

This is the heart of this EPR scheme. Are you registered?

Recommended actions

✓

Declare the volumes of all industrial and transport packaging placed on the market

How to prepare

To do now

Check whether the business falls within the commercial-packaging EPR scheme, based on its activity and its packaging

Contact Citeo Pro for free clarification if you are unsure about the scope

Short-term actions

Estimate annual commercial packaging volumes for the first declaration

Ongoing

Keep the annual declaration up to date

Track changes to the contribution scales

Is your situation more complex? Get an action plan tailored to your plant's constraints

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