EPR Professional Packaging 2026: Are you ready for the new regulation?

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Industrial waste management is entering a highly strategic phase for businesses. As the major regulatory deadline of July 1, 2026, Extended Producer Responsibility (EPR) now extends to professional packaging. At the Tennaxia Connect event, Christophe Rémy, EHS Chief Services Officer at Tennaxia, hosted a round table with Marion Halby, General Manager of Léko, and Julien Leroy, General Manager of RecycleMe France.

This presentation helped clarify the scope of this 19th EPR scheme in France: who is affected, how financial and operational flows are structured, and the precise timeline companies must adhere to for compliance.

Why the EPR for Professional Packaging scheme is starting now

France stands out as a leader in Extended Producer Responsibility with already 19 EPR schemes and 26 eco-organizations in operation. While household packaging (historically managed by Citeo or Adelphe) or the building (PMCB) and chemical product schemes are well-known, the professional packaging segment remained the last major area to be structured.

This launch on July 1, 2026 coincides with a convergence of national and European regulatory texts:

• Nationally: The founding decree of November 17, 2021, supplemented by the "scope order" of December 2, 2025, and the order of April 22, 2026, which strictly clarifies the boundary between household packaging and professional packaging.
• At the European level: The imminent entry into force (on August 12) of the PPWR (Packaging and Packaging Waste Regulation), which aims to standardize rules, producer definitions, and sorting targets across the European Union.

For businesses, the question is no longer whether to act, but how to adapt to this system which concretely applies the principle of the polluter-pays to industrial and commercial packaging.

Who is concerned and what packaging falls within the scope?

The concept of "placer on the market" or producer of professional packaging affects a much wider range of stakeholders than it seems. The industry targets a complete chain of operators: packaging manufacturers, manufacturers of packaged products, assemblers, importers, distributors, wholesalers, resellers, and unpackers.

The scope of the regulation is segmented into three main categories of professional packaging:

• Sales packaging: Cups, jerrycans, drums, big bags, boxes….
• Grouped packaging (secondary): Batch plastic films, cardboard, crates…
• Transport packaging (tertiary): Pallets, stretch films, interleaves…

A key structural feature: Unlike traditional EPR schemes where responsibility lies with the party that packages and places the final product on the market, the EPR for Professional Packaging introduces an exception for transport packaging (such as pallets). Here, it is directly the packaging manufacturer (the pallet manufacturer) who is designated as responsible and liable for the eco-contribution, in order to simplify an already highly interconnected market.

Operational framework and the role of the eco-organization

The deployment of this new sector relies on eco-organizations approved by the State. Following the submission of applications and hearings conducted at the Ministry, three official accreditations were granted to TWIICE, CITEO PRO, and LEKO PRO for professional packaging EPR (decrees of June 3, 2026, published on June 24, 2026, in the official journal).

The system is based on a precise model of financial and contractual flows:

1. Membership and contribution: The responsible market placer or manufacturer signs a membership agreement with the eco-organization and pays an eco-contribution calculated according to several criteria, particularly proportional to the tons of packaging placed on the market.
2. Contractual support for operators and local authorities: Thanks to the collected funds, the eco-organization signs financial support contracts with private collection operators and local authorities. A financial support scale (per ton cost) is thus redistributed to finance collection, sorting, and recycling.
3. The direct impact for the waste holder: For companies that properly hold and sort their professional packaging waste daily, this system is beneficial. As the eco-organization provides direct financial support to the private collection operator, the latter passes on this gain by reducing the waste management bill for the professional waste holder.

Recycling Targets and the Major Reuse Challenge by 2028/2030

The establishment of the scheme addresses ambitious environmental performance targets set by public authorities, with two clear priorities outlined by Marion Halby:

Focus on Plastic

This is the material with the largest gap. Currently, the recycling rate for industrial plastic caps at 26%. The regulatory target requires reaching 50% by 2028, then 60% in 2030. This is where the collection and traceability efforts of eco-organizations will primarily focus.

The Massive Reuse Undertaking

The current reuse rate for industrial packaging is extremely low, estimated at only 3.4% (barely 3.5%). However, the targets set for 2030 require a true industrial scale-up, with mandatory reuse quotas ranging from 10% to 40%, or even 100% depending on the types of industrial packaging (particularly transport or consolidation packaging). The eco-organization will act as an incubator through calls for projects and R&D investments to encourage eco-design and reuse.

For wood (pallets) and the cardboard, existing collection and sorting circuits (via public services or private channels) will be preserved and financially supported by the sector without disrupting current contractual relationships.

The operational compliance timeline

Julien Leroy outlined the precise chronological timeline of post-adhesion compliance steps that every company must anticipate:

• Before July 1, 2026: Analysis of the company's status (liable or not) and signing of the membership agreement with the chosen eco-organization.
• During Q3 2026: Payment of a first financial advance (provisional semi-annual payment) to initiate the sector's funding.
• End of 2026: Payment of the second provisional advance.
• January - February 2027: Internal data collection phase and declaration of actual market placements made throughout 2026 (tonnages by material: cardboard, plastic, wood, etc.).
• March 2027: Financial regularization step (calculation of the difference between the provisional advances paid in 2026 and the actual declaration).

Towards European harmonization, without a single eco-organization

The two speakers sought to clarify a common ambiguity regarding the impact of the future European PPWR regulation on cross-border companies: there will not be a single European eco-organization.

The PPWR regulation will simplify things for manufacturers by harmonizing definitions (what constitutes a producer, what constitutes packaging) across the 27 EU countries, ending current discrepancies. However, operational management will remain strictly national as economic models fundamentally differ from one country to another.

For example:

• In France: The system mandates non-profit eco-organizations non-profit approved by the state.
• In Germany: The model relies on a private market of for-profit eco-organizations for-profit with commercial competition dynamics and other market placement criteria.

Compliance will therefore involve networking tools, synergies, and simplified member areas, but declarations will still need to be broken down country by country.

To conclude

The implementation of the EPR for Professional Packaging does not aim to dismantle existing, well-functioning recycling channels, but rather adds a layer of funding, traceability, and financial incentives for sorting. For manufacturers, the watchword by July 1st is to map their packaging, identify their obligations, and rely on the support of future approved eco-organizations to transform this administrative constraint into an effective lever for the circular economy and eco-design.