Selling into France from stock in Portugal

A seller shipping goods from Portugal to French consumers falls under France’s extended producer responsibility schemes, known as REP, from its first sale. It joins an approved eco-organisme for each relevant product stream and receives a unique identifier, the IDU, from ADEME, which marketplaces check. French law also requires the Triman sorting sign on household products and packaging, and French in the designation, instructions, warranty terms, invoices and receipts of goods sold in France.

France adds national rules on packaging, sorting information and language to the EU framework. Most of it can be settled before the first order, and none of it depends on where the warehouse sits.

Who counts as a producer in France?

The French administration’s business portal describes the scope broadly. Companies that develop, manufacture, handle, treat, sell or import products in the regulated categories are subject to REP. That includes distance sellers and companies established abroad that sell into France.

The categories are organised as separate streams, or filières: household packaging, electrical and electronic equipment, furniture, textiles, toys and others. A seller may belong to several at once. A boxed appliance sold to a consumer touches at least the packaging stream and the electrical equipment stream.

The producer meets its obligations in one of two ways. It joins a collective eco-organisme approved for the stream, which the portal calls the largely dominant situation, or it sets up an individual system.

Do I need an IDU to sell to French consumers from another EU country?

Yes, for each stream you fall under. ADEME, the French ecological transition agency, issues a unique identification number, or IDU, as proof that a producer is registered in its SYDEREP declaration tool for a given scheme.

ADEME describes the two routes. A producer that joins an eco-organisme is registered in SYDEREP by that organisation, which sends it the IDU. A producer with an approved individual system receives it from ADEME directly. Registration asks for the company name, the SIRET for French businesses or the VAT number for foreign ones, the address and the product categories.

ADEME states plainly that foreign companies, whether from the EU or outside it, are subject to these requirements. The IDU must appear in the general terms and conditions of sale or another contractual document, and on the seller’s website, and it must be given to a buyer who asks.

What will a marketplace ask for before I sell in France?

The IDU, in practice. Under the French rules, an online platform may be exempt from REP for products sold by a third-party seller only where that third party has already met its obligations. The platform keeps a register documenting the seller’s IDU and provides quantities of REP products sold to the eco-organismes on request.

The logic is simple for the seller. A platform that cannot show the seller’s IDU carries the obligations itself, so it asks for the IDU before listing. ADEME provides a public producer search tool that marketplaces use to check an IDU against the company name, SIRET or number.

Marketplaces also carry VAT duties of their own in some cases, a separate subject covered in marketplace deemed supplier rules in the EU.

Is the Triman logo still required on packaging in France?

The obligation stood in the latest sources checked for this article, but the rule is in transition. Here is what those sources establish.

• The rule. Article L.541-9-3 of the Environmental Code, inserted by Article 17 of the AGEC law, No 2020-105 of 10 February 2020, requires a sign telling consumers that a product is subject to sorting rules. The French business portal describes it as the Triman logo or equivalent EU marking, paired with information on sorting, the Info-tri.
• The challenge. On 17 July 2025, the European Commission referred France to the Court of Justice of the EU over the Triman requirement, arguing it creates a risk to the free movement of goods. The Gossement law firm notes that the referral does not suspend the obligation for producers.
• The transition. The EU Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, has applied since 12 August 2026 and plans harmonised EU sorting labels. The French bill adapting national law to EU law, reported by Alliance du Commerce in early 2026, would end the Triman logo and Info-tri for packaging.

The practical step is to ask the eco-organisme for the current marking rule for each stream before printing packaging for France. Packaging printed for years of stock should not rest on the rule as it stood when the artwork was drawn.

Which documents must be in French under the Loi Toubon?

Law No 94-665 of 4 August 1994, the Loi Toubon, sets the rule in Article 2. French is compulsory in “la désignation, l’offre, la présentation, le mode d’emploi ou d’utilisation, la description de l’étendue et des conditions de garantie d’un bien, d’un produit ou d’un service, ainsi que dans les factures et quittances.”

In plain terms, that covers the product name and description, the offer, the presentation, instructions for use, the warranty terms, and invoices and receipts. France’s Ministry of Culture notes that the DGCCRF, the consumer protection authority, enforces the rule across France at every stage of production and distribution, including e-commerce, and that customs also check French labelling when goods are imported.

Can other languages appear next to French?

Yes. The law requires French; it does not ban other languages beside it. Article 4 provides that where the mentions covered by Article 2 are accompanied by translations, the French presentation must be “aussi lisible, audible ou intelligible”, as legible, audible or intelligible, as the foreign-language one. A pack printed in Portuguese, Spanish and French, for example, can serve all three markets if the French text is complete and as readable as the others.

Sector rules add their own requirements. Cosmetics, for example, follow the language rules of the Cosmetics Regulation, as set out in holding cosmetics stock for the EU market.

A worked example

Suppose a maker of small kitchen appliances from outside the EU releases its stock for free circulation in Portugal and sells to French consumers on a marketplace and on its own site. The details are hypothetical, for the mechanics only.

Before the first French order, it joins an eco-organisme for household packaging and one for electrical and electronic equipment, and receives an IDU for each. It shows both IDUs in its terms of sale and on its site, and gives them to the marketplace, which checks them before listing. Its packaging carries the sorting marking its eco-organisme confirms as current. The box contains French instructions and a French warranty statement, and its invoices to French consumers are in French.

Once released in Portugal, the goods reach French addresses as ordinary deliveries within the single market. VAT on sales to French consumers follows its own rules, which OSS, IOSS, and what they do not cover sets out.

What does the seller check before the first French sale?

1. Which REP streams the product and its packaging fall under.
2. Membership of an approved eco-organisme, or an individual system, for each stream.
3. An IDU per stream, shown in the terms of sale and on the website, and ready for marketplaces.
4. The current sorting marking for each stream, confirmed with the eco-organisme before artwork is printed.
5. French text for the product name, description, instructions, warranty, invoices and receipts, at least as legible as any translation.
6. The GPSR operator details on the product, for consumer goods.

Sellers that supply French retailers or distributors, rather than consumers, meet the same questions in the supply agreement. What European distributors ask before signing covers how they come up.

What about the new EU packaging rules?

The PPWR applies across the EU, France included, and it has changed how packaging obligations are organised in some member states. Germany now requires an authorised representative for sellers without a German branch that sell directly to end users, as set out in selling into Germany from stock in Portugal.

A Commission proposal of 10 December 2025, COM(2025) 982, would suspend the EU obligation behind that rule, Article 45(3) of the PPWR, until 1 January 2035. It covers only producers established in the EU that sell into another member state. Producers established outside the EU stay in scope: member states may still require them to appoint an authorised representative by written mandate, or must ensure traceability and enforcement by other means. Packaging Journal reports that Council discussions on the proposal were halted after a majority of member states objected.

For a manufacturer outside the EU, the proposal does not remove the obligation. For France, the eco-organisme is the first place to confirm what applies to a given stream.

This is general information, not legal advice. REP and labelling duties for a specific product are confirmed with the eco-organisme and the seller’s advisers.

How this runs at EFC

For a brand selling into France, EFC’s part is the stock and the shipping. Goods are held at its base in Portugal, run with its logistics partner, and sent to French customers after release for free circulation, as described on fulfilment. The French registrations remain the brand’s own: EFC does not register brands with eco-organismes, does not obtain IDUs and gives no legal advice. Its GPSR Responsible Person role covers consumer products only and is described on responsible person.

Sources

Label	Value	Source
Who is a producer; eco-organisme or individual system; IDU display; marketplaces; Triman or equivalent EU marking	scope includes distance sellers and foreign companies; platform exemption where the third party has met its obligations; register of IDUs	Entreprendre.Service-Public.gouv.fr, extended producer responsibility schemes, opened 2026-09-04
IDU	issued by ADEME via SYDEREP; two routes; foreign companies concerned; display and supply on request; producer search tool	ADEME, unique identifier for EPR schemes, opened 2026-09-04
Triman legal basis and CJEU referral	Article L.541-9-3, inserted by Article 17 of law 2020-105; referral on 17 July 2025; obligation not suspended	Gossement Avocats, Triman: the Commission refers France to the CJEU, opened 2026-09-04
French bill on EU adaptation	would end Triman and Info-tri for packaging; bill under parliamentary review in early 2026	Alliance du Commerce, DDADUE 2026 bill, opened 2026-09-04
PPWR	Regulation (EU) 2025/40; applies from 12 August 2026	European Commission, packaging waste, opened 2026-09-04
Commission proposal	COM(2025) 982 of 10 December 2025; suspends Article 45(3) of Regulation (EU) 2025/40 until 1 January 2035 for EU-established producers; third-country producers stay in scope (recitals 6 and 8, Article 2)	European Commission, COM(2025) 982 final, opened 2026-09-04
Proposal status	Council discussions halted after a majority of member states objected	Packaging Journal, EU Commission wants to scrap authorised representative obligation for PPWR, opened 2026-09-04
Loi Toubon, Article 2	French compulsory in designation, offer, presentation, instructions, warranty, invoices and receipts	Légifrance, Loi n° 94-665, article 2, opened 2026-09-04
Loi Toubon, Article 4	where mentions are accompanied by translations, French as legible, audible or intelligible as the foreign-language version	Légifrance, Loi n° 94-665, consolidated text, opened 2026-09-04
Enforcement	DGCCRF across France, including e-commerce; customs check French labelling at import	Ministry of Culture, ensuring the use of French, opened 2026-09-04