Professional Packaging EPR & EGAlim 2: what every B2B food distributor needs to know before 1 July 2026

REP Professional Packaging: understanding the regulatory context

The Extended Producer Responsibility (EPR) — known in France as REP (Responsabilité Élargie du Producteur) — is a fundamental principle of European environmental law that places the financing of product end-of-life on those who bring them to market. Long applied to household packaging (via Citeo since 1992), it now extends to professional packaging — the B2B chain packaging used outside domestic settings.

The regulatory timeline is as follows: the decree of 17 November 2025 officially created the Professional Packaging EPR scheme (EPRO). Regulatory entry into force is set for 1 January 2026, and the operational start — with actual contribution obligations — is set for 1 July 2026, with no retroactive effect on the first half of the year.

Who is affected by the Professional Packaging EPR?

The EPRO targets market placers — a broader concept than it appears. Any company that manufactures, imports, distributes professional packaging or packaged products to professionals on the French market falls within scope. For Martigane and its B2B distributor clients, this means that any business distributing packaged beverages, canned goods, grocery products or commodities to professional clients in France potentially falls within the EPRO scope.

What packaging is in scope?

The order of 2 December 2025 specifies the packaging covered: all non-household packaging — primary (in direct contact with the product), secondary (multipacks, shrink wrap), and tertiary (transport cartons, stretch-wrapped pallets, dividers). Packaging already covered by another specific EPR scheme is excluded.

Concrete obligations for businesses from 1 July 2026

1. Join an accredited eco-organisation

Companies that do not opt for individual compliance must join an accredited eco-organisation. Citeo Pro, Citeo's B2B subsidiary, is the main accreditation candidate. Companies already members of the Catering Packaging EPR must renew their contract with the accredited EPRO eco-organisation — Citeo Pro promises a simplified process for existing clients.

2. Declare market placement volumes

Each market placer must declare to their eco-organisation the quantities of packaging placed on the French market. For the first EPRO period (1 July → 31 December 2026), the declaration will cover second-half 2026 volumes. This declaration is the basis for calculating the eco-contribution.

3. Pay eco-contributions

The eco-contribution is calculated based on the type and weight of packaging placed on the market. It varies by material (cardboard, plastic, glass, metal, wood) and recyclability. Packaging designed according to eco-design principles (100% recyclable, reusable, free from problematic substances) benefits from reduced rates — a direct incentive to evolve packaging practices.

EGAlim 2: what the law requires of food distribution operators

EGAlim 2 (Law n°2021-1357 of 18 October 2021, the "Besson-Moreau law") is the second major law balancing commercial relations in French agriculture and food. It responds to a painful observation: despite EGAlim 1 (2018), farmers and suppliers continued to sell at a loss, because supermarkets were passing input cost increases onto suppliers rather than consumers.

The founding principle: the agricultural price "tunnel"

EGAlim 2's major contribution is creating a non-negotiable floor for the share of price devoted to agricultural raw materials. The supplier has three options: a reference indicator defined by a recognised inter-professional organisation, a reference indicator from a framework agreement, or a supplier's own transparent indicator. The aim is to "disconnect" the agricultural raw material component from the annual commercial negotiation — it can no longer be used as an adjustment variable by distributors.

The automatic price revision clause

EGAlim 2 requires an automatic price revision clause in all contracts between food suppliers and their clients (distributors, manufacturers, caterers — excluding wholesale merchants). This clause allows price revision during the year if agricultural raw material costs vary significantly — without waiting for the annual renegotiation. This is particularly important given the raw material inflation context since 2021.

EGAlim 2 and collective catering

EGAlim 2 requires public sector collective catering to achieve 50% quality and sustainable products in its procurement (including at least 20% organic) from 1 January 2022. For private sector catering, a similar target is set for 1 January 2025. For a distributor like Martigane, this is a direct commercial opportunity: traceability documentation, certifications (MSC, ASC, Organic, Label Rouge) and transparency on origins become concrete selling points.

EGAlim 3 — Measures still in force in 2026

EGAlim 3 (Descrozaille law, 30 March 2023) extended and strengthened several provisions: promotional caps on food products (34% value, 25% volume in supermarkets) until 15 April 2026; and new legislation preventing distributors from relocating commercial negotiations to foreign buying offices to circumvent French legal obligations.

What this means for your B2B purchases from Martigane

• On pricing: Martigane's suppliers can pass on raw material increases during the year via EGAlim 2 revision clauses. B2B prices may therefore evolve outside traditional annual negotiation cycles.
• On packaging: from 1 July 2026, if you are yourself a market placer of professional packaging (you repackage or import packaged products), you must join an accredited eco-organisation and declare your volumes.
• On traceability: collective catering obligations (50% sustainable products) create demand for origin and quality documentation that Martigane can meet across its entire range.
• On compliance: Martigane supports its clients in understanding these new obligations and can provide on request the documentation needed (origins, certifications, product data sheets) to meet regulatory requirements.