Selling into France from stock in Portugal

Suppose a maker of small kitchen appliances outside the EU releases its stock for free circulation in Portugal. It then starts selling to French consumers, on a marketplace and on its own site. The details below are hypothetical, built only to walk through the mechanics.

Before the first French order goes out, four things need to be in place. An eco-organisme membership for household packaging, and another for electrical and electronic equipment, each producing a unique identifier called an IDU. Both IDUs shown in the terms of sale, on the website, and handed to the marketplace before it will list the product. Packaging carrying whatever sorting mark the eco-organisme currently confirms as correct. And French text inside the box: instructions, a warranty statement, and French invoices for every French buyer.

Once the goods are released in Portugal, none of this depends on the warehouse. It depends on who is selling into France and to whom. France layers its own producer-responsibility and language rules on top of the EU framework. Almost all of this can be settled before the goods ever move.

Who counts as a producer in France?

Broadly, anyone who develops, manufactures, handles, treats, sells or imports products in a regulated category, according to the French administration’s business portal. That includes distance sellers and companies established abroad. It is not a narrow definition built for domestic manufacturers.

The categories run as separate streams, filières: household packaging, electrical and electronic equipment, furniture, textiles, toys, and others. One boxed appliance can touch two streams at once, packaging and electrical equipment. That is why our hypothetical seller above needed two eco-organisme memberships rather than one.

A producer meets its obligations by joining a collective eco-organisme approved for the stream, or by running an individual system. The portal calls the collective option the largely dominant route.

Is an IDU needed to sell to French consumers from another EU country?

Yes, one for each stream. ADEME, the French ecological transition agency, issues the IDU as proof of registration in its SYDEREP declaration tool.

There are two routes to getting one. A producer that joins an eco-organisme is registered by that organisation, which passes the IDU along. A producer running an individual system gets it from ADEME directly. Either way, registration asks for the company name, the address, and the product categories. It also asks for a SIRET number for French businesses or a VAT number for foreign ones.

ADEME states plainly that foreign companies, EU or not, are subject to these requirements. The IDU has to appear in the general terms and conditions of sale and on the seller’s website. It also has to be handed over to any buyer who asks for it.

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

The IDU. Under French rules, a platform can be exempt from REP obligations for a third-party seller’s products. This applies only if that seller has already met its own obligations. The platform is required to keep a register of sellers’ IDUs and to report REP product quantities to the eco-organismes on request.

That gives a marketplace a simple reason to ask early: if it cannot show the seller’s IDU, it inherits the obligation itself. ADEME runs a public producer search tool that marketplaces use to check an IDU against a company name, SIRET or number. There is nowhere to bluff this one.

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

Is the Triman logo still required on packaging in France?

Yes, for now. The rule is mid-transition, and each of the three points below explains why.

• The current rule. Article L.541-9-3 of the Environmental Code was inserted by Article 17 of the AGEC law (No 2020-105 of 10 February 2020). It requires a sign telling consumers a product is subject to sorting rules. That sign is the Triman logo or an equivalent EU marking, paired with sorting information called Info-tri.
• A legal challenge already filed. On 17 July 2025 the European Commission referred France to the Court of Justice of the EU over the Triman requirement. The Commission argued that the requirement risks the free movement of goods. Gossement Avocats notes the referral does not suspend the obligation while it is pending.
• A national bill that would end it. A French bill adapting national law to the EU’s own packaging rules would retire Triman and Info-tri for packaging altogether. Alliance du Commerce reported it under parliamentary review in early 2026.

The practical move is to check with the eco-organisme before printing packaging for France, rather than trusting artwork drawn a year or two ago. Stock printed for a long run should not lean on a rule that might not survive the run.

Which documents must be in French under the Loi Toubon?

Law No 94-665 of 4 August 1994, the Loi Toubon, sets this out in Article 2. French is compulsory in the designation, offer, presentation, instructions for use, warranty terms, invoices and receipts for goods sold in France. That is a wide net, covering everything from the product name to the paperwork after the sale.

France’s Ministry of Culture notes the DGCCRF, the consumer protection authority, enforces the rule at every stage of production and distribution, including e-commerce. The Ministry adds that customs check French labelling on import as well.

Can other languages appear next to French?

Yes. The law requires French; it does not exclude anything else. Article 4 covers the case where a translation accompanies the required French text. The French version must then be “aussi lisible, audible ou intelligible” (as legible, audible or intelligible) as the foreign-language one. A pack printed in Portuguese, Spanish and French can serve all three markets. The condition is that the French text is complete and reads no less clearly than the rest.

Sector rules sit on top of this. Cosmetics, for instance, follow the language rules of the Cosmetics Regulation, covered in holding cosmetics stock for the EU market.

What about the new EU packaging rules?

The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, applies across the EU, France included, and has already reshaped one national rule elsewhere. Germany now requires an authorised representative for sellers without a German branch who sell directly to end users. That rule is covered in selling into Germany from stock in Portugal.

A Commission proposal of 10 December 2025, COM(2025) 982, would suspend that requirement, Article 45(3) of the PPWR, until 1 January 2035. The suspension applies only to producers already established in the EU selling into another member state. Producers established outside the EU stay in scope regardless. Member states may still demand an authorised representative by written mandate, or must ensure traceability and enforcement some other way. Packaging Journal reports that Council talks on the proposal stalled after a majority of member states objected.

For a manufacturer outside the EU, in other words, that proposal changes nothing. For France specifically, the eco-organisme remains the first place to check what applies to a given stream.

Summary of the French obligations

Back to the appliance maker above. Two eco-organisme memberships, two IDUs shown wherever French rules require them, a sorting mark confirmed current, and a French-language box. Once that is in place, the goods reach French addresses as ordinary intra-EU deliveries. VAT on those consumer sales runs on its own track, set out in OSS, IOSS, and what they do not cover. Sellers supplying French retailers or distributors rather than consumers meet the same underlying questions inside the supply agreement instead. That subject is covered in what European distributors ask before signing.

France’s producer responsibility system, as set out, reflects the rules in force today. It does not tell a specific seller what a specific product needs; the eco-organisme and the seller’s own advisers do that.

How EFC ships French orders from stock in Portugal

EFC holds the stock and runs the shipping, as described on fulfilment. After release for free circulation, goods sit at its base in Portugal and move with its logistics partner to customers in France and across Europe. The French registrations above stay the brand’s own: eco-organisme registration and IDUs stay the brand’s own responsibility, and we give no legal advice. Our GPSR Responsible Person role, where it applies, 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	EPR Spain, PPWR authorised representative deadline, opened 2026-09-25
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