The postponement of the Extended Producer Responsibility (EPR) for commercial packaging does not eliminate any of the challenges facing companies in the printing and packaging industries. It simply pushes the deadline back to January 1, 2027. For case manufacturers, label printers, cardboard converters, flexible packaging producers, and companies involved in packaging, these few months will primarily be used to determine who reports what, for what quantities, and with what economic impact.
January 1, 2027, is the date to mark on your calendars
The first issue is the timeline. The operational launch of the EPR program for commercial packaging was originally scheduled for July 1, 2026. The Ministry of Ecological Transition has postponed it to January 1, 2027.
This delay occurred after the environmental certification bodies had been approved and the first eco-contribution schedules had been released. In other words, some companies had already begun their preparations when the deadline changed.
For a printing company, however, an additional six months can be of very practical use. It is necessary to identify the affected products, distinguish between materials, determine the volumes sold, establish contractual responsibilities, and adapt management systems capable of generating the data required for reporting.
The calendar includes another deadline to watch for. New rates are scheduled to be announced in September 2026. They will provide companies with a more precise basis for preparing their 2027 budgets.
The postponement therefore has one advantage: more time to develop internal procedures. The downside is just as obvious. As long as the final economic parameters are unknown, it remains difficult to finalize estimates, contracts, and margin projections.
The marketer remains the sticking point for printers
This is probably the least dramatic?and most important?question: Who is legally considered the marketer?
This classification determines which company is responsible for the obligations associated with extended producer responsibility (EPR). And in the graphic arts industry, the answer isn't always as simple as identifying the company that physically manufactures the packaging.
Let?s take the supply chain for a folding box as an example. A printer purchases cardboard, prints, cuts, and glues the box on behalf of a brand. The packaging is then filled with a product before being delivered to a distributor or a business user. Several companies are involved, but they do not necessarily occupy the same position within the system.
The same issue arises with custom-made packaging, imports, products sold under private labels, and certain packaging services.
That is precisely one of the reasons given for the postponement. The ambiguities regarding the definition of ?marketer? must be resolved before operations begin.
For printers, the issue goes beyond mere administrative compliance. An incorrect assignment of liability can affect the invoiced price, the general terms and conditions of sale, and the allocation of costs among the client, the manufacturer, and the packager.
The time gained until January 1, 2027, should therefore also be used to review the contracts. In a subcontracting chain, it?s best to know who is responsible before the invoice arrives.
The eco-fee is included in the calculation of the cost price
The REP introduces a new factor into the professional packaging industry: the eco-contribution.
For a company subject to the regulation, simply filing a regulatory declaration will not be sufficient. The corresponding amount must be included in the economic calculation for the packaging in question.
This raises a familiar question for printers: Where should this cost be allocated?
In an industry where quotes are calculated based on paper, format, number of press runs, machine passes, inks, finishes, and quantities, adding a charge for packaging requires a method that is precise enough to avoid distorting profit margins.
The first schedules were published shortly before the initial deadline. With the postponement, we must now wait for the information announced for September 2026.
This interim period can be used to run simulations. Companies already have data from their raw material purchases, production records, and invoices. All that remains is to organize this data according to the categories required for reporting.
And that is often where regulatory requirements meet the reality of the production floor. A company knows how many sheets it purchases and how many cases it ships. It does not necessarily have, on a product-by-product basis, all the information required to prepare an environmental declaration.
Management systems will need to speak the language of packaging
Extended Producer Responsibility (EPR) therefore raises issues related to data as much as to waste.
A printer or converter already manages paper weights, sizes, quantities, materials, waste, and bills of materials. This information is spread across quotes, ERP systems, production management software, and technical data sheets.
The task involves verifying whether they can identify packaging that falls within the scope of the Extended Producer Responsibility (EPR) program and generate the necessary information without requiring extensive manual processing.
For companies that handle a few recurring product lines, the process remains relatively straightforward. It takes on a whole new dimension for a manufacturer producing several thousand product lines, with complex structures and multiple material families.
The postponement to January 1, 2027, provides some time to prepare. This time can be used to create any missing fields in the product databases, review the bills of materials, and designate the person responsible for consolidating the reports.
The downside is the associated administrative cost. Extended Producer Responsibility (EPR) isn't just about the trash bin behind the workshop. It extends all the way to the information system, the purchasing department, management control, and billing.
Reuse and recycling are also becoming economic factors
The sector covers approximately 7 million metric tons of commercial packaging placed on the market each year in France. Commercial packaging also accounts for a portion of the plastic waste stream targeted by national recycling goals.
The mechanism does not rely solely on the payment of eco-fees. Financial support is provided for certain recycling or reuse initiatives.
This approach is of direct interest to packaging manufacturers. Material selection, the separability of components, single- or multi-material structures, and the organization of packaging recovery take on an additional economic dimension.
However, the information provided does not yet allow us to determine precisely the financial impact of these factors for each packaging technology. It would therefore be premature to conclude that a cardboard box, printed plastic packaging, or another type of packaging will automatically fare better.
Nevertheless, this topic deserves to be part of the discussions between the printer, the converter, and the client. The graphic and structural design of packaging is no longer limited to the printing process, finishing, product protection, and how it looks on the shelf. Its end-of-life is gradually becoming part of the economic equation.
The postponement does not mean that preparations have stopped
Eco-organizations continue to prepare the system despite the change in schedule. Membership is still open at Léko Pro, among others, while Citeo Pro is also among the organizations set to play a role in this sector.
For companies, therefore, there is little operational benefit to shelving the matter until December 2026.
The period leading up to January 1, 2027, provides an opportunity to identify the packaging in question, clarify responsibilities in contracts, prepare the data, and assess the impact of the fees on cost prices.
It also allows us to wait for regulatory clarifications without building the entire system on assumptions.
For a printer or packaging manufacturer, the right balance is therefore to prepare the aspects that are no longer subject to the schedule?such as material data, bills of materials, volumes, contracts, and billing processes?while maintaining flexibility regarding the elements that still need to be finalized.
