Of all the EU countries your clients might sell to, France generates the most detailed packaging data requests. The reason is CITEO's eco-modulation system: France adjusts EPR fees upward or downward based on how recyclable packaging is and how much recycled content it contains. This means that the recycled content percentage you report is not just documentation — it has a direct and calculable effect on your client's invoice.
This article explains what CITEO requires, why French clients ask for data that goes beyond the standard BOM fields, and what you need to provide to help your clients file accurate declarations.
CITEO: France's packaging PRO
CITEO (Société de Conseil et de Services pour la Transition Écologique) is France's approved Producer Responsibility Organization for household packaging. Any company that sells packaged goods to French consumers must either contract with CITEO (or its competitor Léko) or demonstrate equivalent individual take-back capacity — which in practice means contracting with CITEO.
CITEO collects eco-contributions from producers, distributes funding to French municipalities for packaging collection and sorting, and runs France's consumer recycling communication program. Membership is mandatory; the question is only how much your client pays.
How eco-modulation works — and why your data drives the fee
Standard EPR systems charge a flat rate per kilogram of material. France goes further: CITEO adjusts its base fee with bonuses and maluses (penalties) based on the recyclability and recycled content of each packaging component. This is called eco-modulation.
The adjustment can be significant:
- Packaging with verified post-consumer recycled content above specified thresholds receives a fee bonus (reduction of up to several percentage points off the base rate per kg)
- Packaging designed for recyclability — using materials accepted in French sorting systems, avoiding problematic additives — receives recyclability bonuses
- Packaging that is difficult to recycle, uses black carbon pigment in plastics, or contains problematic materials receives fee maluses (increases)
- Excess packaging (void space above a certain ratio) receives a malus
- Triman-labeled packaging (compliant with France's mandatory sorting instruction label) may receive a bonus
For a brand with significant French volumes, the difference between non-modulated and eco-modulation-optimized fees can amount to thousands of euros annually. This is why your French clients care so much about the exact recycled content percentage and the specific material type of every component.
What France-specific fields your clients will request
Beyond the standard BOM fields (component, material, weight, level), French clients typically need additional information for eco-modulation assessment:
Recycled content percentage — distinguished by type
France requires the post-consumer recycled content (PCR) percentage specifically — not total recycled content, not pre-consumer recycled content. CITEO eco-modulation bonuses apply only to post-consumer recycled content.
If your component contains 30% recycled content of which 20% is post-consumer and 10% is pre-consumer (manufacturing scrap), only 20% is relevant for eco-modulation purposes. Report them separately if possible. If you can only provide a total figure, your client will conservatively assume it is all pre-consumer.
Recyclability characteristics
CITEO assesses recyclability based on its "Guide de la recyclabilité" — a reference document defining which materials and formats are accepted in French sorting and recycling facilities. Your client may ask you:
- Whether plastic packaging contains carbon black pigment (black pigment that blocks NIR sorting — strong malus in France)
- Whether packaging uses PVC (a malus material in France due to contamination of recycling streams)
- Whether the packaging format and material combination is "en cours de recyclage" (in active recycling streams) vs. not recycled in France
- Whether labels cover more than 60% of a plastic bottle or container (affects NIR detection)
Material origin and certification
To claim eco-modulation bonuses for recycled content, the claim must be documented. CITEO accepts several forms of evidence:
- Mass balance certificates from certified schemes (ISCC Plus, RecyClass, REDcert2)
- Supplier declarations for paper and board recycled content (signed declarations from your pulp or board mill supplier)
- Standard product documentation showing recycled material specifications
Without documentation, CITEO treats the recycled content as zero for eco-modulation purposes — even if your packaging genuinely contains recycled material. If you have a certification, provide it alongside your BOM.
CITEO material categories
France uses its own material taxonomy for declarations, which maps to EU categories but with some France-specific distinctions:
| CITEO category | What it includes | Supplier notes |
|---|---|---|
| Papier carton ondulé (Corrugated board) | Corrugated boxes, mailers | Separate from flat board — important for fee calculation |
| Papier carton plat (Flat board) | Folding boxboard, cartons | Includes coated and uncoated grades |
| Papier (Paper) | Kraft paper, tissue, wrap | Lighter paper grades, bags, wrapping |
| Plastique rigide (Rigid plastic) | Bottles, jars, trays, pots | Specify polymer — PET, HDPE, PP differentiated |
| Plastique film (Flexible plastic) | Polybags, film wrap, pouches | Distinct category from rigid plastic — higher fee rate in France due to lower recycling rate |
| Verre (Glass) | All glass | Clear and coloured treated similarly |
| Acier (Steel) | Steel cans, tins | Separate from aluminium |
| Aluminium | Aluminium cans, foil | Separate from steel |
| Complexes (Composites) | Multi-material inseparable | Flag dominant material; CITEO has specific composite sub-categories |
The rigid vs flexible plastic distinction is France-specific and important. Flexible plastic films (LDPE polybags, PE shrink wrap) are in a separate category with a higher fee rate than rigid plastic containers. Make sure you separate these in your BOM rather than grouping all plastic together.
The Triman label — what it means for you
France requires a Triman logo on all packaging sold to French consumers, along with Info-Tri sorting instructions explaining how to dispose of the packaging. This obligation sits with your client (the brand), not with you as the manufacturer.
However, your client needs accurate material composition data to specify the correct sorting instruction. A polybag gets a different sorting instruction than a corrugated box. A glass jar gets a different one than a PET bottle. They cannot print the correct Triman instructions without knowing what each component is made of.
This is one more reason why material classification precision matters for French clients in particular: it feeds not just the EPR declaration but also the mandatory product labeling.
Declarations timeline in France
Understanding when your clients file helps you anticipate when data requests will arrive:
- French EPR declarations cover the previous calendar year (January–December)
- CITEO declarations are typically due in Q1 of the following year (February–March)
- Fee invoices are issued after declarations are accepted
Expect the highest volume of French packaging data requests between November and February — the period when brands are preparing their annual declarations.
Key differences from Germany
- Eco-modulation: France actively adjusts fees for recycled content and recyclability — Germany does not (yet, though incentives are being introduced)
- Rigid vs flexible plastic: CITEO separates these into different fee categories — VerpackG uses a single plastic category with polymer-level differentiation
- Triman labeling: France mandates consumer sorting labels on packaging — Germany does not have an equivalent requirement
- Documentation standards: France requires documentary evidence for eco-modulation claims — Germany focuses more on declaration completeness
For Germany-specific requirements, see supplying brands that sell in Germany. For Spain, read supplying brands that sell in Spain. For a full guide to recycled content documentation, see how to document recycled content for EPR declarations.