Selling in France without being established there makes you subject to Extended Producer Responsibility (EPR). REP·Pro becomes your authorised representative established in France and carries your obligations for you.
Short answer: a producer established outside the European Union (United States) that places products on the French market falls under French EPR — packaging, WEEE and/or batteries depending on your products. You must register with ADEME (unique identifier), join an approved producer responsibility organisation (PRO), report your volumes and pay the eco-contribution. REP·Pro acts as your authorised representative established in France to carry out these steps. You remain the responsible producer.
US companies export to France notably in electronics, machinery, pharmaceuticals, aerospace and cosmetics — all of which involve packaging, and often electrical equipment or batteries. As soon as these products are placed on the French market, they fall under the relevant EPR schemes. For your profile, the most frequently concerned scheme is WEEE (electrical and electronic equipment), but a single producer often falls under several schemes at once.
As a producer established outside the European Union, you have no establishment in the EU: local representation becomes central. Placing your products on the French market makes you subject to the French EPR schemes (registration with ADEME, membership of an approved producer responsibility organisation, reporting and eco-contribution), and an authorised representative established in France is the practical route — and, for batteries, mandatory (EU Regulation 2023/1542).
Batteries: if you place batteries on the French market, appointing an authorised representative is mandatory under EU Regulation 2023/1542 (Article 56, applicable since 18 August 2025), whether you are inside or outside the EU.
Yes. Distance selling to French customers falls within the scope of EPR just like selling through a distributor. The authorised representative lets you carry this responsibility locally.
No. The French Conseil d'État ruled (10 November 2023) that an EPR authorised representative cannot be subrogated to the producer's obligations: you remain responsible, REP·Pro carries out the steps on your behalf.