Simplified pathway

PPWR and AGEC guide for SMEs

The essential obligations ranked by priority for small and medium-sized businesses without a dedicated compliance team.

Updated May 2026 — Milestones that apply without advanced technical expertise, with direct impact within 24 months or an immediate financial obligation. Thresholds per AGEC decree no. 2022-507 of 8 April 2022.

AGEC France 1 July 2026
Critical priority

Commercial packaging EPR — you are probably affected

If your company places products on the market in packaging intended for businesses or for the catering sector, you must register with Citeo Pro and declare your volumes. Eco-contributions start on 1 July 2026. There is no company-size threshold for this obligation.

Who is concerned

Any company placing packaging on the market for professional, collective-catering or industrial use, whatever its turnover.

Immediate action

Go to citeopro.com and check your situation. If in doubt, Citeo Pro offers a free scope check. Do not wait until June 2026 to start this process.

PPWR 12 August 2026
Critical priority

PFAS in your food packaging — mandatory check

If you use food packaging with a grease-resistant coating or a moisture barrier (pizza boxes, trays, baking paper, snack packaging, microwaveable packaging), you must verify before 12 August 2026 that it contains no PFAS above the permitted thresholds. Ask your packaging supplier for a written attestation. No non-compliant stock can be sold after this date.

Who is concerned

Any food business using packaging with a surface treatment or barrier, whatever its size.

Immediate action

Contact your packaging supplier this week and request a written PFAS compliance attestation for each affected item. If the supplier cannot provide it, switch suppliers or have the packaging lab-tested.

PPWR 12 August 2026
High priority

Declaration of conformity — one file per packaging item

If you make your own packaging, or have it designed by a subcontractor, you are considered a manufacturer under the PPWR. You must build a technical file for each packaging format. If you buy standard packaging from a supplier, it is the supplier who must provide this documentation. Either way, make sure you have it.

Who is concerned

Manufacturers and brand owners who have their packaging designed for them. Buyers of standard packaging can rely on their supplier's documentation.

Immediate action

If you have your packaging designed by a subcontractor: contact them to build the documentation together. If you buy standard packaging: ask your supplier for the declaration of conformity.

AGEC France 2026
Medium priority

AGEC reuse target — are you affected in 2026?

The AGEC law requires companies placing more than 10,000 packaging units on the market per year to meet progressive reuse rates. If your turnover is between 20 and 50 million euros, your target is 7% in 2026. If your turnover is below 20 million, your first quantified target starts in 2026 at 5%. These obligations can be met by joining a collective eco-organisation.

Who is concerned

Companies placing more than 10,000 packaging units on the market per year. Check whether your packaging falls into the categories that qualify for an exemption because their technical requirements are incompatible with reuse.

Immediate action

Calculate the number of packaging units placed on the market each year. If above 10,000 units, identify your turnover threshold and the collective eco-organisation suited to your sector.

No dedicated briefing at this stage. Content available in the department guides.

AGEC France 2027
High priority

AGEC 10% reuse target — every SME affected

In 2027, all companies placing more than 10,000 packaging units on the market per year must reach 10% reuse, whatever their turnover. This is the AGEC law's national target for companies of every size. Preparation must start now, because setting up a reuse system or joining a collective takes time.

Who is concerned

All companies placing more than 10,000 packaging units on the market per year.

Immediate action

If you are not yet engaged in a reuse approach, contact Citeo or a sector eco-organisation to identify the collective solutions available in your sector. Individual reuse is costly to set up alone for an SME.

No dedicated briefing at this stage.

AGEC reuse targets according to your company's size

Source: Decree no. 2022-507 of 8 April 2022

Applicable if you place More than 10,000 packaging units placed on the market per year on the market.

Turnover 20232024202520262027
Under €20M — — — 5% 10%
Between €20M and €50M — — 5% 7% 10%
Over €50M 5% 6% 7% 8% 10%
See the full PPWR and AGEC roadmap