Floral exporters face dual...
...French and EU packaging rules
France’s new rules for professional packaging will operate alongside the EU-wide PPWR. For flower and plant exporters, understanding who is responsible—and which pots, trays, sleeves, boxes and trolleys are covered—will be essential.
In 1992, France was one of the earliest adopters of a national ERP system for household packaging. It required companies placing packaged household products on the French market to finance the collection, sorting, and recycling of waste packaging.
More recently, the country bolstered the framework through the Anti-Waste for a Circular Economy Act (2020), and a general EPR scheme including B2B packaging. The latter was due on 1 July 2026 but has now been postponed until 1 January 2027.
By Ron van der Ploeg
The scale of the challenge
Far-reaching consequences
While the regulation applies to every industry, the consequences for ornamental horticulture are particularly far-reaching. From plastic pots and containers to transport trays, Danish trolleys, sleeves, and wooden boxes, almost every piece of packaging accompanying ornamental products to professional customers may fall within the scope of the new rules.
For exporters, the challenge does not end there. They also must comply with the first provisions of the European Packaging and Packaging Waste Regulation (PPWR). This new set of rules introduces a phased implementation schedule that started in August and extends into 2030. It has three clear objectives: to reduce the volume of packaging and packaging waste, to encourage reuse and high-quality recycling, and to create a level playing field for packaging rules across the EU.
The polluter pays
Based on the common principle that ‘the polluter pays’, the French legislation makes companies responsible for the environmental impact of the packaging they introduce to the French market.
For the flower and plant industry, this represents much more than another administrative exercise.
Every day, thousands of truckloads carrying flowers, pot plants, and nursery stock products cross the French border. Virtually every shipment contains a range of packaging materials.
Companies must determine exactly which packaging falls under the ERP legislation, who bears legal responsibility and how much environmental contribution must be paid.
The polluter pays
French legislation makes companies responsible for the environmental impact
of the packaging they introduce to the French market
Danish trolleys used to transport and display plants may carry different obligations depending on ownership and branding. Photo: Ron van der Ploeg.
Two systems, one compliance burden
PPWR versus ERP
The European PPWR complicates matters even more. Although both pieces of legislation deal with packaging, they address different parts of the product lifecycle.
The PPWR harmonises packaging design throughout the European Union by introducing requirements covering recyclability, packaging reduction and technical compliance. Among its first measures are mandatory EU declarations of conformity, restrictions on certain packaging formats and tighter limits on empty space in transport and e-commerce packaging.
France’s REP scheme focuses on something different: funding and operationally supporting the collection, recycling and disposal of B2B packaging placed on the French market.
For exporters, this means complying with two complementary systems at the same time.
The crucial question
The crucial question is: who is placing products on the French market?
One of the first challenges companies encounter is identifying the so-called ‘metteur en marché’—the organisation legally considered to be placing the packaged product on the French market for the first time.
In day-to-day terms, this may be the flower and plant wholesaler exporting directly to a French garden centre, supermarket, or landscaping company. In more complex supply chains involving wholesalers and distributors, determining legal responsibility can quickly become less obvious.
Importantly, there is no minimum threshold. Whether a company exports one trolley or one thousand, the obligations remain the same.
Two rules, two responsibilities
EU PPWR Sets requirements for packaging design, reduction, recyclability and technical compliance. French REP/EPR Funds and organises the collection, reuse, recycling and disposal of professional packaging placed on the French market.
The crucial question is:
Who is placing products on the French market?
Three approved éco-organismes
Twiice Reporting tools, packaging analyses and support for eco-design and improved sorting. Citeo Pro Focuses on packaging reduction, reuse and recycling. Léko Pro Supports prevention, collection, reuse and recycling for professional packaging.
Registration and reporting
Eco-organismes
For most exporters, the logical first step is to register with one of the French government’s recognised ‘éco-organismes’ consulting firms, officially called Producer Responsibility Organisation (PRO).
These organisations administer the environmental contributions—known as écocontributions—and organise the nationwide systems for collection, sorting, recycling and reuse.
Three organisations currently hold official approval.
Twiice offers value-stream analyses, reporting tools, decision trees and support for eco-design projects. It also provides financial incentives encouraging better source separation and investment in sorting equipment.
Citeo Pro concentrates on reducing packaging impacts through reduction, reuse and recycling.
Léko Pro coordinates producer responsibility schemes covering prevention, collection, reuse and recycling for professional packaging streams.
Following registration, companies receive an official Unique Identification Number (IDU) from the French environmental agency ADEME. Increasingly, this number is becoming a licence to operate in France.
Data is becoming as important as the packaging itself
Compliance requires far more than paying an invoice. Companies must first estimate the packaging volumes they expect to place on the French market during the first half of 2027. Those forecasts determine the provisional environmental contributions. Actual figures submitted will then determine the final settlement.
Consequently, exporters need reliable internal systems that can record packaging materials, weights, quantities, and product flows.
For many floral wholesalers, this means departments that traditionally had little interaction—purchasing, logistics, finance and sustainability—must team up.
Data is becoming as important as the packaging itself
When packaging is not straightforward
When is a pot or container actually packaging?
Perhaps nowhere does the legislation illustrate its complexity better than with something as ordinary as a plastic plant pot or container.
Whether a pot falls within the scheme depends largely on its function.
A propagation pot used exclusively during nursery production is considered a production aid and therefore falls outside the legislation. However, once that same pot accompanies the finished plant to a professional customer in France, it becomes packaging.
Volume also matters
Plant pots of 10 litres or less are regarded as consumer packaging under French legislation, while larger containers are classified as professional packaging.
Similar distinctions apply throughout the supply chain.
Shrink film only becomes packaging once it is wrapped around a Danish trolley or pallet. Wooden transport boxes assembled on-site may create different responsibilities from ready-made boxes purchased from a supplier. Transport trays, sleeves and even branded Danish trolleys can each involve different legal obligations depending on ownership and branding.
For exporters accustomed to viewing packaging as a routine logistical necessity, these distinctions require a significant mindset shift.
When is a pot actually packaging?
Volume also matters
Incentives, enforcement and business impact
Rewarding circular packaging
The French ERP scheme actively encourages more sustainable packaging choices.
Reusable packaging designed according to strict technical criteria may qualify for substantial fee reductions—sometimes as much as 50 per cent.
Complete exemption is possible where companies can demonstrate that packaging genuinely circulates within a verified reuse system.
However, companies must support such claims with documentation. During inspections, companies may be asked to prove that certain pots remained within internal production or that transport packaging genuinely operates in a closed-loop system.
A competitive advantage—or more red tape?
French authorities have indicated that the first months will focus on helping businesses adapt. Nevertheless, companies should not underestimate the long-term consequences of ignoring the new legislation.
Administrative fines can reach several thousand euros per infringement and may be accompanied by daily penalty payments. Ultimately, authorities can prohibit non-compliant products from being marketed in France.
Lawmakers and environmental organisations will stress that packaging regulation benefits not only the environment but also a company’s business model: companies that invest early in understanding their environmental responsibilities are likely to find that regulatory compliance can also give them a competitive advantage in an increasingly sustainability-driven European marketplace.
Meanwhile, growers —especially those running small and medium-sized enterprises (SMEs) —are increasingly vocal about the crippling effects of “red tape”: excessive bureaucracy and complex regulations that hinder growth and innovation. Complying with the (packaging) regulations consumes valuable time, resources, and capital, diverting them from core business activities and potentially stifling the entrepreneurial spirit that drives the horticulture industry.
For many exporting companies, the real challenge is not only understanding the deadlines, but collecting supplier data, managing evidence, and documenting compliance across complex packaging portfolios.
A competitive advantage—or more red tape?
