Last week I wrote about the German packaging law being replaced on 12 August. Two things landed on that same date that got less attention and catch different sellers.
France has its own version of the authorised representative rule, plus a registration number and a label most UK sellers have never heard of. And PPWR put hard numeric limits on PFAS in food-contact packaging — three of them, cumulative, applying to anything placed on the EU market.
If you sell food, drink, supplements, pet treats, or anything that touches the product through its wrapper, the second half of this is the one that matters.
France: three things, not one
German compliance is one register and one dual system. French compliance has three separate components and sellers routinely complete one, assume they're done, and get restricted on the other two.
The IDU. A unique identification number issued by ADEME, the French environment agency. It is not your VAT number, not your CITEO account reference, and not your SIRET. It's a separate identifier that proves you're registered for extended producer responsibility, and it's the one Amazon validates against.
The eco-organisme. CITEO is the main one for household packaging. You contract with them, declare your volumes, and pay the fees that finance collection and recycling. Registering with ADEME and not contracting with an eco-organisme leaves you half-compliant in exactly the way that passes a quick self-check.
The Triman label. France requires sorting information on the product or packaging. Not a certificate you file — artwork. Which means it has a lead time your registration doesn't: if your packaging is already printed and already in a container, fixing this is a production decision, not an admin one.
And as in Germany, PPWR's Article 45(3) means a producer with no French establishment needs a mandataire — an authorised representative — to carry those obligations. Same mechanism, different word, same consequence if it's missing.
Why "I'll do France next quarter" is more expensive than it sounds
The thing about the French set-up is that the components fail independently.
You can hold a valid IDU and be unable to sell because you never contracted with CITEO. You can be fully paid up with CITEO and get restricted because Amazon can't validate your IDU — usually because the company name on the ADEME record doesn't character-match the name on your Seller Central account. You can clear both and still be non-compliant on the Triman label, which nobody checks at listing level and which turns up in a consumer complaint or a market surveillance sweep instead.
Each of those has a different fix and a different lead time. The registration is days. The eco-organisme contract is days to weeks. New artwork, approved, printed, and on the next production run is months.
Which is the argument for looking at this in October rather than January. Not because enforcement is imminent — I don't know that it is — but because one of the three failure modes can't be fixed quickly at any point, and knowing which ones apply to you takes an afternoon.
The PFAS limits: actual numbers
This is the part with hard figures, and they're worth knowing precisely because "PFAS-free" is not what the regulation says.
From 12 August 2026, food-contact packaging placed on the EU market must comply with three cumulative maximum limits under PPWR Article 5(5):
→ 25 ppb (µg/kg) for any single PFAS, measured by targeted PFAS analysis. Polymeric PFAS are excluded from this quantification.
→ 250 ppb (µg/kg) for the sum of PFAS, measured as the sum of targeted analysis — with prior degradation of precursors where applicable. Polymeric PFAS again excluded.
→ 50 ppm (mg/kg) for total fluorine, and this one includes polymeric PFAS.
PPWR PFAS limits on food-contact packaging since 12 August 2026 — 25 ppb single, 250 ppb sum, 50 ppm total fluorine. Three cumulative tests; passing one tells you nothing about the other two.
Read those three again, because the structure is the point.
Cumulative means all three, not whichever is most convenient. Passing the single-substance test tells you nothing about the sum, and passing both tells you nothing about total fluorine.
The polymeric carve-out reverses between tests two and three. Polymeric PFAS don't count toward the 25 ppb or the 250 ppb. They do count toward the 50 ppm. So a packaging component built on a fluoropolymer coating can look clean on targeted analysis and fail outright on total fluorine. If a supplier sends you a certificate showing "no detectable PFAS," the first question is which of the three limits it tested against — because a targeted-analysis result on its own doesn't answer the one that catches polymers.
"Prior degradation of precursors where applicable" is doing real work. Precursor substances aren't PFAS as supplied, but break down into regulated PFAS. A test that doesn't degrade precursors first can return a passing sum from a material that won't pass once the precursors have converted.
What this means if you're a seller, not a manufacturer
You almost certainly don't test packaging. Your supplier does, or claims to.
So your exposure is a documentation problem rather than a chemistry one, and it has a specific shape: you need, for every food-contact SKU, a statement from your packaging supplier that addresses all three limits by name and number. Not "complies with PPWR." Not "PFAS-free." The three figures.
Three questions that get you most of the way:
"Which of the three Article 5(5) limits does this test report cover?" If the answer is one of them, you have a gap. If the supplier doesn't know there are three, you have a bigger one.
"Does the total fluorine result include polymeric PFAS?" It has to. If they can't say, the test probably wasn't the right test.
"Were precursors degraded before the sum was measured?" Where applicable. A supplier who understands the question is a supplier who's done this properly.
Those three answers, in writing, per SKU, filed somewhere you can find them. That's the deliverable. It isn't glamorous and it's the thing that matters if anyone ever asks.
The audit routine
An afternoon, done once, then reviewed when you add a SKU or change supplier.
1. List every SKU with food-contact packaging. Wider than people expect. Direct food contact, obviously — but also supplement pouches, pet treat bags, anything with an inner liner, and the greaseproof layer in a gift box with chocolate in it.
2. For each, find the supplier's substance declaration. If you don't have one, that's the finding. Request it with the three questions above rather than a generic compliance ask; you'll get a usable answer faster.
3. Check the French set separately. IDU issued by ADEME, eco-organisme contract live, Triman on the artwork, mandataire appointed if you have no French establishment. Four boxes, each independently able to stop you.
4. Reconcile names, not just numbers. Legal name on the ADEME record against legal name in Seller Central, character for character, suffix included. This is the most common cause of a valid registration failing validation, and it's invisible until you compare the two strings side by side.
5. Put the numbers in Seller Central. Account Info → Compliance. France and Germany are separate fields with separate registrations. Populating one doesn't populate the other, and sellers who sorted Germany in 2022 frequently have an empty France field they've never looked at.
The part worth being blunt about
None of this is interesting. It's the least interesting work in ecommerce.
It's also the category of problem that doesn't degrade gracefully. A listing with weak copy sells less. A listing that's non-compliant sells nothing, at a moment you don't choose, and the fix takes as long as the slowest component — which, if it turns out to be artwork, is measured in months.
The two hours is cheap because the thing it's buying isn't compliance. It's knowing which of your SKUs are exposed and which aren't, so that if something does go quiet you're diagnosing rather than discovering.
If your Amazon.fr listings are already restricted on EPR or compliance grounds, Fin Method's Listing Suppression Recovery (£150 per suppressed listing) covers the diagnosis, the Seller Central fix, and the reinstatement request. For the backend compliance updates — IDU, mandataire details, local-language safety text — Amazon Listing Amendments (£120 per listing) handles the data entry across each affected marketplace. Fixed price. Delivered in days, not weeks.