CITEO and French EPR: What Online Sellers Need to Declare

France does not mess around with packaging compliance. It was one of the first EU countries to implement a full Extended Producer Responsibility framework for packaging — decades before the PPWR was even drafted — and it enforces actively. Inspectors from the DGCCRF (Direction générale de la concurrence, de la consommation et de la répression des fraudes) conduct audits, issue fines, and publish the names of non-compliant companies. If you sell into France, CITEO registration is non-negotiable.

What makes France particularly demanding is that it goes beyond basic EPR registration. You also need specific labeling on every piece of packaging (the Triman logo and Info-Tri sorting instructions), and France's eco-modulation system means your fees vary dramatically based on how recyclable your packaging actually is. This guide covers the full picture.

CITEO: France's Packaging PRO

CITEO (formerly Eco-Emballages, merged with Ecofolio in 2017) is France's approved Producer Responsibility Organisation for household packaging and paper. Its full legal name is CITEO S.A. It operates under the authority of the Code de l'Environnement (Articles L541-10 and following), which mandates that any entity placing packaged products on the French household market must either join an approved PRO or set up its own collection and recycling system.

CITEO manages what French law calls the "filière REP emballages ménagers" — the extended producer responsibility stream for household packaging. It collects eco-contributions from producers, funds municipal collection and sorting infrastructure, and finances recycling operations across France. In 2024, CITEO collected contributions from over 50,000 companies and funded the recycling of approximately 3.7 million tonnes of household packaging.

There is technically a second approved PRO for household packaging called Léko, which launched in 2023. However, CITEO remains the default choice for the vast majority of companies, and this guide focuses on CITEO accordingly.

Who Must Register?

Any entity that places packaged products on the French household market must register. In French legal terms, this is the "metteur en marché" — the entity that first makes the product available to the French market.

There is no threshold. Not by revenue, not by volume, not by weight.

Even one shipment of a packaged product to a French consumer triggers the obligation. The "metteur en marché" concept works as follows:

• You manufacture in France and sell domestically — you are the metteur en marché.
• You import products into France — you are the metteur en marché, because you are the first entity to place the packaged product on the French market.
• You're a foreign D2C brand shipping directly to French consumers — you are the metteur en marché. The fact that you have no French entity does not exempt you.
• You sell on a French marketplace (Amazon.fr, Cdiscount, etc.) — you are the metteur en marché for your own products. The marketplace is not responsible for your packaging.

If a French distributor or importer buys your products and resells them, the responsibility typically falls on whoever first introduces the product to the French market. This should be clarified contractually between you and your distributor.

Registration Process

CITEO's registration is done online and the process is reasonably streamlined.

1. Create an account at citeo.com

Go to the CITEO website and navigate to "Adhérer" or "Devenir adhérent." You'll create a company account with basic information.

2. Provide your company identification

French companies provide their SIREN (9 digits) or SIRET (14 digits) number. Foreign companies without a French establishment provide their national company registration number and EU VAT number. CITEO has a process for non-French companies, and their team can guide you through the specifics.

3. Complete the "déclaration d'adhésion"

This is your formal adhesion declaration. You'll confirm your company details, the nature of your products, and your estimated packaging volumes. CITEO uses this to set up your account and determine your reporting obligations.

4. Receive your "identifiant adhérent"

Once processed, you'll receive a unique CITEO member number. This is your proof of registration for marketplace compliance checks and regulatory inquiries.

Timeline

Expect 1 to 3 weeks from application to receiving your member number. CITEO is generally faster than some other European PROs, but delays happen if your company identification documents require manual verification.

Reporting Requirements

France's reporting requirements are detailed and, in some ways, more demanding than other EU countries. Here's what makes them different.

Annual declaration

CITEO requires an annual declaration, typically due in the first quarter for the previous calendar year. You report all packaging placed on the French household market during the reporting period.

Weight in tonnes, not kilograms

Unlike ECOEMBES in Spain (which uses kg), CITEO requires weights in tonnes with up to 6 decimal places. So where you might report 408.000 kg to ECOEMBES, you'd report 0.408000 tonnes to CITEO. This trips people up more often than you'd expect — a misplaced decimal point in tonnes means you've declared 1,000 times the actual amount.

Material categories

CITEO's material classification includes:

• Paper/Cardboard (papier/carton)
• Plastic — broken down by polymer type (PET, HDPE, PP, PS, other)
• Glass (verre)
• Steel (acier)
• Aluminium
• Wood (bois)
• Other materials

Note that CITEO wants plastic broken down by polymer type, not just "plastic." You need to know whether your plastic packaging is PET, HDPE, PP, or something else. Check with your packaging supplier.

Packaging levels

Declarations are segmented by packaging level: primary, secondary, and tertiary. The same rules apply as in other countries — for B2C e-commerce, your shipping box is secondary packaging since it reaches the end consumer.

Recycled content percentage

This is where France stands apart. CITEO requires you to declare the percentage of recycled content in your packaging materials. This isn't just a nice-to-have — it directly affects your fees through the eco-modulation system (covered below). If your cardboard is made from 85% recycled fibers, you declare 85%. If your plastic is 100% virgin, you declare 0%.

Getting accurate recycled content data means going back to your packaging suppliers. Many suppliers can provide certificates or data sheets with this information. If they can't, you may need to default to 0% recycled content, which means you pay the full eco-contribution without any bonus.

Triman and Info-Tri: Mandatory Labeling

Since January 2022, all packaging intended for French consumers must display two specific elements. This is not optional, and enforcement is real.

The Triman logo

The Triman is a distinctive icon: a stylized human figure combined with a recycling symbol (three curved arrows). It indicates that the product or its packaging is subject to a sorting rule and should not be thrown in the general waste bin. The Triman must appear on all packaging or, if space is too limited (items smaller than 10 cm), on the product's web page or accompanying documentation.

Info-Tri sorting instructions

Alongside the Triman, you must provide Info-Tri — specific instructions telling the consumer how to sort each packaging component. These instructions must be in French and must specify:

• What the packaging element is (e.g., "Emballage carton", "Film plastique", "Bouchon")
• Where it goes (e.g., "Bac de tri" for the recycling bin, "Poubelle" for general waste)

A typical Info-Tri for an e-commerce shipment might read:

Emballage carton — Bac de tri
Film plastique — Bac de tri

Since the extension of French sorting rules (known as "extension des consignes de tri"), most packaging — including plastic films — can now go in the recycling bin in France. But the instructions must still be present.

Non-compliance consequences

The DGCCRF can issue fines of up to €15,000 per infraction for non-compliant labeling. In practice, they often start with a warning letter (an "injonction"), giving you a deadline to comply. But repeat offenders or companies that ignore the warning face real financial penalties.

Practical implementation

For brands shipping from outside France, the simplest approach is to include the Triman and Info-Tri on your shipping packaging itself (the box or mailer). You can print it directly on the packaging, use a sticker, or include it on a packing slip. CITEO provides downloadable templates and guidelines on their website, including precise dimensional requirements for the Triman logo.

Eco-Modulation: The Bonus-Malus System

France pioneered eco-modulation in Europe, and it remains one of the most aggressive implementations. The concept is simple: packaging that is easy to recycle pays less, packaging that is difficult or impossible to recycle pays more. The gap between the two can be substantial.

How it works

Your base eco-contribution (the per-kg fee for each material) is adjusted by bonus or malus multipliers based on specific packaging characteristics:

• Bonus (lower fees) — Mono-material packaging, packaging made from widely recycled materials (PET, HDPE, cardboard), packaging with high recycled content, packaging that integrates sorting instructions.
• Malus (higher fees) — Non-recyclable packaging, black or dark-colored plastic (hard for optical sorters to detect), multi-material composites (like a plastic pouch with an aluminium barrier layer), PVC packaging, packaging that disrupts recycling streams.

Impact on fees

The malus can increase your fees by 50% to 100% or more for problematic packaging. Conversely, a well-designed, easily recyclable packaging can earn a bonus that reduces your fee by 5% to 20%. The net effect: a brand using recycled cardboard might pay less than half per kilogram compared to a brand using multi-layer plastic pouches.

Examples

• Clear PET bottle — recyclable, widely sorted and recycled in France. Eligible for bonus.
• Black plastic tray — near-infrared sorting equipment cannot detect black plastic. Heavy malus applies.
• Multi-material flexible pouch (plastic + aluminium) — not recyclable in current French infrastructure. Heavy malus.
• Corrugated cardboard box — widely recycled. Eligible for bonus, especially with high recycled content.

CITEO Fees for 2026

CITEO's fee structure is more complex than a simple per-kg rate because of eco-modulation. However, the base indicative rates for 2026 are approximately:

A worked example

A skincare brand ships 1,800 orders per year to France. Each order includes:

• Corrugated cardboard box (secondary): 220g
• HDPE plastic bottle (primary): 45g
• Cardboard product box (primary): 60g
• PP plastic cap (primary): 8g
• PE plastic film wrap: 15g

Totals: 504 kg cardboard (0.504 tonnes), 122.4 kg plastic (0.1224 tonnes), split between HDPE, PP, and PE.

Approximate fees before eco-modulation: (504 × €0.070) + (122.4 × €0.270) = €35.28 + €33.05 = €68.33 per year.

With eco-modulation bonuses for recyclable plastics (HDPE and PP are well-recycled in France), the actual bill could be slightly lower. With maluses for any non-recyclable components, it could be significantly higher.

France-Specific Gotchas

France has several requirements that go beyond standard EU EPR. These catch many foreign sellers off guard.

The AGEC law

France's Loi AGEC (Anti-Gaspillage pour une Économie Circulaire), enacted in 2020, goes further than the PPWR in several areas. It bans certain single-use plastics, mandates recycled content targets, and requires the Triman + Info-Tri labeling discussed above. Even after the PPWR enters into force, AGEC obligations remain — France is allowed to maintain stricter national rules.

Single-use plastic bans

France has progressively banned numerous single-use plastic items. As of 2026, the list includes: cutlery, plates, cups, straws, food containers made of expanded polystyrene, and packaging for fruits and vegetables under 1.5 kg (with some exceptions). If your products use any of these, you cannot sell them in France regardless of CITEO registration.

Reporting in tonnes catches people off guard

It sounds small, but switching between kg (used by ECOEMBES) and tonnes (used by CITEO) is a persistent source of errors. A brand that placed 500 kg of cardboard on the French market should report 0.500000 tonnes. Reporting 500.000000 tonnes would be wildly wrong and trigger an audit inquiry.

Info-Tri must be in French

You cannot use generic English sorting instructions. The Info-Tri text must be in French. "Recycling bin" does not cut it — it must say "Bac de tri." If you sell across multiple EU countries, this means your French-bound packaging needs French-language sorting instructions specifically.

The UDI (Unique Identifier) for marketplace sellers

French law (via AGEC Article 62) requires marketplace operators to verify that their sellers comply with EPR obligations. Amazon.fr, Cdiscount, and other French marketplaces now require sellers to provide their CITEO unique identifier number (UIN) as proof of registration. Without it, your listings can be suppressed.

Putting It All Together

French EPR compliance requires more steps than most other EU countries. Here is the complete checklist:

• Register with CITEO (1-3 weeks)
• Weigh packaging components by material and polymer type
• Obtain recycled content data from packaging suppliers
• Track all orders shipped to French consumers
• Submit annual declaration in tonnes with recycled content percentages
• Pay eco-contribution (base rate adjusted by eco-modulation)
• Add Triman logo and Info-Tri sorting instructions to all packaging
• Verify none of your packaging uses banned single-use plastics

If you also sell into Spain and Germany, you're now managing three different PROs with three different formats, units, and requirements. This is where manual spreadsheets start to break down and where tools like Pack Declare earn their keep — generating CITEO-format declarations including recycled content percentages directly from your packaging and sales data.

France is demanding, but the requirements are clear and well-documented. CITEO provides solid support for new registrants, and their website has extensive resources in French (and increasingly in English). The key is to start early, get your packaging data organized, and not underestimate the labeling requirements. The Triman and Info-Tri are the pieces most foreign sellers overlook — and they're the easiest to enforce because any inspector can simply look at your packaging.

If France is one of several EU markets you sell into, the multi-country EPR strategy guide explains how to sequence registrations efficiently. For neighboring markets, see the guides for Germany (LUCID), Belgium (Fost Plus), and the Netherlands (Afvalfonds).