France has postponed the planned expansion of its Extended Producer Responsibility system for professional packaging.

The wider system was due to launch on 1 July 2026. At the end of June, the French government announced that implementation would be moved to a later date. No new start date has yet been confirmed.

The postponement does not abolish professional packaging EPR in France. Existing obligations for certain food-service packaging remain in force, while the broader system for all professional packaging is waiting to become operational.

What was due to change on 1 July 2026?

France already has an EPR system covering specific packaging used by food-service businesses.

The next phase was intended to bring all other professional packaging into the same wider EPR framework. This includes packaging used to market products consumed or used by businesses rather than households.

The future scope is expected to cover a much broader range of industrial and commercial packaging, including packaging used in sectors such as:

• manufacturing;
• wholesale and distribution;
• retail operations;
• construction;
• logistics;
• healthcare;
• hospitality;
• other business-to-business supply chains.

The expansion was scheduled for 1 July 2026 but has now been postponed to an unspecified later date.

Has the legal framework been cancelled?

No.

The regulatory framework for the expanded system has already been created through a decree adopted in November 2025 and implementing orders adopted in December 2025.

These rules set out the future scope and operating requirements for the professional packaging EPR system.

Three producer responsibility organisations were also approved on 5 June 2026:

• Citeo Pro;
• Léko Pro;
• Twiice.

Their approval means that the organisations have been authorised to operate within the future system. It does not mean that the wider obligations started automatically on 1 July 2026 despite the postponement.

The current position is therefore unusual but clear: the legal and organisational framework exists, while the operational launch of the expanded system has been delayed.

Which obligations still apply?

The existing EPR system for food-service packaging remains in force.

It covers primary food packaging used specifically by professional food-service operators where the packaged product exceeds the relevant weight or volume thresholds.

Examples can include large-format packaging for products such as:

• cooking oil;
• sauces;
• dairy products;
• beverages;
• ingredients supplied specifically for professional kitchens.

The relevant thresholds determine whether the packaging is treated as professional food-service packaging or remains within the household packaging system.

Companies already covered by the food-service packaging EPR must continue to comply. The postponement does not suspend existing registrations, declarations, fees or membership with Citeo Pro.

Citeo Pro remains the currently approved producer responsibility organisation for this existing scope.

Which packaging is not covered by the existing food-service system?

The current food-service system is narrower than the future professional packaging system.

It does not generally cover:

• packaging for non-food products used by restaurants;
• secondary and tertiary packaging used by food-service businesses;
• food packaging below or equal to the defined size thresholds;
• general industrial and commercial packaging outside the food-service scope.

Some smaller or mixed-use food packaging remains within the household packaging EPR system because the same formats may be used by both households and professional users.

A business should therefore not conclude that all packaging delivered to a restaurant is already covered by professional packaging EPR.

The product, packaging level and applicable size threshold all matter.

What will the future system cover?

Once the expansion takes effect, the professional packaging system will cover packaging used to market products consumed or used by professionals, subject to the detailed scope rules.

Packaging already assigned to another French EPR stream will not also be included in the professional packaging system.

This distinction is intended to avoid double coverage. For example, packaging classified within the household packaging EPR system should not also generate a second obligation under the professional packaging stream.

The classification will depend on the intended user and the characteristics of the packaged product and packaging.

Who will be considered the producer?

This is one of the areas where further clarification is still expected.

Under the existing food-service packaging system, the producer is generally the company that packages or has its products packaged for placement on the market. An importer can also become responsible where imported products are marketed in covered packaging.

The physical manufacturer of an empty box, bottle or container is not automatically the producer. Responsibility generally follows the packaged product placed on the market.

For the future wider system, ADEME refers to the producer definition in the EU Packaging and Packaging Waste Regulation.

That definition takes account of factors such as:

• where the company is established;
• whether it manufactures packaging or packaged products;
• whether products are sold under its own name or trademark;
• whether it imports products;
• whether it sells directly to users in another country.

ADEME has stated that further information on the interpretation of this definition will be provided.

Until then, companies should avoid assuming that responsibility will always sit with the packaging supplier, the French customer or the foreign seller. The outcome may differ depending on the sales and distribution model.

Does the postponement affect household packaging EPR?

No.

France’s existing EPR system for household packaging and graphic paper continues separately.

Companies placing packaged consumer goods on the French household market must continue to comply with the relevant requirements, including scheme membership, declarations and payment of eco-contributions.

The delay to the wider professional packaging system does not postpone or replace household packaging obligations.

It also does not change the existing distinction between:

• household packaging;
• mixed-use food packaging;
• professional food-service packaging;
• future industrial and commercial packaging.

Correct classification remains essential because it determines which EPR system receives the declaration and fees.

Do companies need to join one of the three future schemes now?

The approval of Citeo Pro, Léko Pro and Twiice does not by itself confirm that every future producer already has an active registration or reporting obligation under the expanded scope.

Companies outside the existing food-service packaging system should check the effective date and contractual terms before treating scheme membership as legally mandatory.

They should also distinguish between:

• joining a scheme in preparation for the future system;
• an agreement that already creates contractual fees;
• a statutory obligation that has formally started.

Businesses already covered by the current food-service system should not end their Citeo Pro membership because of the postponement.

Why do some sources still show 1 July 2026?

The launch date appeared in legislation, scheme communications, compliance calendars and company guidance before the postponement was announced.

Some pages have not yet been updated and continue to state that the expanded system started on 1 July 2026.

Companies should rely on the latest information from ADEME and the French authorities rather than an earlier implementation timetable.

The postponement also creates a reason to review contracts or advice based on the original date. A document prepared before the end of June 2026 may no longer reflect the current position.

What remains uncertain?

Several important points still require confirmation:

• the new operational start date;
• the detailed interpretation of the producer definition;
• when companies outside the current food-service scope must join a scheme;
• the first reporting period;
• how the transition from the current food-service system to the wider system will work in practice;
• whether scheme fee structures or contractual timelines will change.

These are implementation questions. They do not mean that France has abandoned the wider professional packaging EPR system.

The current position in brief

The French professional packaging EPR framework now has two different stages:

Currently applicable:
EPR for certain primary food packaging used specifically by professional food-service operators.

Adopted but postponed:

The expansion to all professional packaging, originally planned for 1 July 2026.

Companies should continue meeting any existing food-service and household packaging obligations while waiting for confirmation of the new start date for the wider system.

How Viron can support

Viron helps companies determine whether packaging falls within the French household, food-service or future professional packaging EPR system.

We also manage scheme registrations, declarations, authorised representation and ongoing packaging compliance in France and other EU markets.