REP Professional Packaging 2026: Are You Ready for the New Regulations?

Industrial waste management is entering a highly strategic phase for businesses. With the major regulatory deadline of July 1, 2026, fast approaching, Extended Producer Responsibility (EPR) now extends to commercial packaging. At the Tennaxia Connect event, Christophe Rémy, EHS Chief Services Officer at Tennaxia, moderated a panel discussion with Marion Halby, CEO of Léko, and Julien Leroy, CEO of RecycleMe France.

This presentation helped clarify the details of France’s 19th REP program: who is affected, how the financial and operational processes work, and the specific timeline that companies must strictly adhere to in order to comply.

Why Is the Professional Packaging EPR Program Launching Now?

France has established itself as a leader in Extended Producer Responsibility ( EPR ) , with 19 EPR sectors and 26 eco-organizations already in operation. While household packaging (historically managed by Citeo or Adelphe) and the construction (PMCB) and chemical sectors are well known, the commercial packaging sector remained the last major area to be organized.

This implementation, set to begin on July 1, 2026, is part of an overlap between national and European regulations:

• At the national level: 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 distinction between household packaging and commercial 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, definitions of producers, and sorting targets across the European Union.

For businesses, the question is no longer whether to take action, but how to adapt to this system, which effectively applies the “polluter pays” principle to industrial and commercial packaging.

Who is affected, and what types of packaging are covered?

The concept of a “marketer” or professional packaging producer encompasses a much broader range of stakeholders than it might seem at first glance. The industry targets an entire chain of operators: packaging manufacturers, manufacturers of packaged products, assemblers, importers, distributors, wholesalers, retailers, and unpackers.

The scope of the regulations is divided into three main categories of commercial packaging:

• Sales packaging: Cups, jugs, drums, big bags, boxes…
• Grouping (secondary) packaging: Plastic wrap for batches, cardboard boxes, crates, etc.
• Transport packaging (tertiary): Pallets, stretch film, divider sheets, etc.

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

The Operational Functioning and Role of the Environmental Organization

The rollout of this new collection system relies on state-approved eco-organizations. Following the submission of applications and hearings held at the Ministry, three official accreditations were granted to TWIICE, CITEO PRO, and LEKO PRO for the Extended Producer Responsibility (EPR) program for commercial packaging (decrees dated June 3, 2026, published on June 24, 2026, in the Official Journal).

The operation is based on a specific financial and contractual flow model:

1. Membership and Fees: The responsible marketer or manufacturer signs a membership agreement with the eco-organization and pays it an eco-fee calculated based on several criteria, including, in particular, the number of metric tons of packaging placed on the market.
2. Contractual Support for Operators and Local Authorities: Using the funds raised, the eco-organization enters into financial support contracts with private collection operators and local authorities. A financial support schedule (based on cost per metric ton) is then distributed to fund collection, sorting, and recycling.
3. The direct impact on the waste holder: For businesses that properly manage and sort their commercial packaging waste on a daily basis, this system is beneficial. Since the eco-organization provides direct financial support to the private collection operator, the latter passes on this benefit by reducing the waste management bill for the business holding the waste.

Recycling Targets and the Major Challenge of Reuse by 2028/2030

The establishment of the supply chain is in line with ambitious environmental performance goals set by the government, with two clear priorities outlined by Marion Halby:

Focus on Plastic

This is the material with the widest gap. Currently, the recycling rate for industrial plastics is capped at 26%. The regulatory target requires reaching 50% by 2028, then 60% by 2030. This is where environmental organizations will focus their collection and traceability efforts first and foremost.

The Massive Reuse Project

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

For wood (pallets) and cardboard, existing collection and sorting systems (through public services or private sectors) will be maintained and financially supported by the industry without disrupting current contractual relationships.

The Operational Compliance Timeline

Julien Leroy outlined the precise timeline of the post-accession compliance steps that every company must plan for:

• Before July 1, 2026: Determine the company’s status (whether it is required to comply or not) and sign the membership agreement with the selected eco-organization.
• During the third quarter of 2026: Payment of an initial installment (provisional semiannual payment) to begin funding the program.
• End of 2026: Payment of the second interim installment.
• January–February 2027: Internal data collection phase and reporting of actual market placements made throughout 2026 (tonnage by material: cardboard, plastic, wood, etc.).
• March 2027: Financial adjustment phase (calculation of the difference between the estimated tax payments made in 2026 and the final tax return).

Toward European Harmonization, Without a Single Environmental Organization

Both speakers made a point of clearing up a common misunderstanding regarding the impact of the future European PPWR regulation on cross-border companies: there will be no single European eco-organization.

The PPWR regulation will simplify matters for manufacturers by harmonizing definitions (what constitutes a producer, what constitutes packaging) across the 27 EU member states, thereby putting an end to current distortions. However, operational management will remain strictly national, as economic models differ fundamentally from one country to another.

For example:

• In France: The system requires the use of state-approved nonprofit environmental organizations.
• In Germany: The model is based on a private market of for-profit environmental organizations that operate according to the principles of commercial competition and other market-based criteria.

Compliance will therefore require networking tools, synergies, and simplified member portals, but reports will still need to be broken down by country.

In conclusion

The implementation of the Extended Producer Responsibility (EPR) program for commercial packaging does not disrupt existing recycling systems that are functioning well, but rather provides a foundation for funding, traceability, and financial incentives for sorting. For manufacturers, the priority between now and July 1 is to map out their packaging, identify their obligations, and rely on support from future accredited eco-organizations to transform this administrative requirement into a powerful driver of the circular economy and eco-design.