France wants 10% reusable packaging in 2027: what it means for exporters' pallets and crates

France has put a number into law for 2027. One in every ten packaging units placed on the French market should be a reused one.

For an exporter, the first question is simple. Do my pallets, my stretch film and my crates count?

They do. But the obligation usually sits with your French buyer, not with you.

Checked against official sources on 28 October 2026.

My short answer: the rule is Décret n° 2022-507 of 8 April 2022, which wrote Articles R. 541-350 to R. 541-354 into the French Environment Code. It applies to "producers" placing at least 10,000 units of packaged products a year on the French market, and the definition includes importers. The minimum share of reused packaging is 10% in 2027 for every turnover band. Each packaging counts, including tertiary (transport) packaging. An Indian exporter selling to a French importer is normally not the obligated party. Your buyer, though, will need your packaging data. And a pallet that makes one trip from India cannot count as reused.

I am a packaging maker, not a French lawyer. I have gone through the decree in the copy on AIDA, the official database of INERIS, and the declaration guide of ADEME, the French environment agency. Where something rests only on press reports, I say so.

What does the decree say?

1. "Emballages" are packaging as defined in Article R. 543-43 (R. 541-350 II 1°). ADEME's guide quotes that article: sales or primary packaging, grouped or secondary packaging, and transport or tertiary packaging. Road, rail, sea and air containers are not packaging.
2. A "producteur" is anyone who professionally packs products, or has them packed, for placing on the market. It is also "tout importateur dont les produits sont commercialisés dans des emballages", any importer whose products are sold in packaging. If neither can be identified, it is whoever first places the products on the market (R. 541-350 II 2°).
3. A reused packaging is one used at least a second time, for the same kind of use it was designed for, with the reuse organised by or for the producer (R. 541-350 II 3°).
4. Packaging is counted one by one, "qu'il soit primaire, secondaire, ou tertiaire" (R. 541-350 IV). A producer may use an equivalent unit of 0.5 litre or 0.5 kg if it can justify it.
5. The obligation applies to every producer responsible for at least 10,000 units of packaged products a year, and to approved packaging eco-organisations (R. 541-351). Producers can comply alone, through a collective structure or through their eco-organisation.
6. Each obligated producer reports every year the total packaging it placed on the market and the share that was reused (R. 541-354).

Two kinds of packaging are left out (R. 541-350 III). The first is packaging of products where a law forbids reuse for hygiene or consumer-safety reasons. The second is packaging of products whose authorisation forbids reuse or requires disposal of the product with its container.

The trajectory to 2027

Source: Art D. 541-352. All three bands meet at 10% in 2027.

Do pallets, stretch film and crates count?

Yes. ADEME's guide for the 2026 declaration (January 2026, for 2025 data) lists examples of industrial and commercial packaging: "palettes, tourets, bacs, caisses, sangles, cerclage, films de palettisation, cagettes, bidons, fûts". In English, that is pallets, cable drums, tubs, cases, straps, strapping, pallet film, crates, cans and drums.

Three counting details in the same guide matter for transport packaging.

1. For the 10,000 threshold, you count packaged products, not packaging. The guide's own example: 20 car parts on a pallet, with cartons, pallet film and dunnage, are 20 units of packaged product.
2. For the reuse rate, grouped and transport packaging is counted per packaging item, together with small attached parts such as a label or tape.
3. A grouped or transport packaging counts as reused if its single-use elements weigh less than 20% of its total weight.

That third rule is the useful one for us film people. A reusable pallet that goes out with single-use film and straps can still count as reused, if the film and straps are light enough.

The guide also says that goods exported out of France are left out of a French producer's count. And packaging makers count the packaging they use to ship their own products, such as the delivery pallet and the pallet film, but not the packaging they make.

One caution. The guide says it covers 2025 data and "ne préjuge pas" changes for 2026 and later. So treat these counting details as current practice that may still change.

Who carries the target when goods come from India?

On the plain wording, your French importer does. It is a producer, because it is an importer whose products are sold in packaging.

Whether the pallet and film your goods arrive on enter its count, or only the packaging it uses for onward sales, is a finer point. ADEME's guide answers it with worked examples for imports and intermediaries, drawn as diagrams in its Annex 2. I would ask your buyer to check those with its adviser rather than assume either way.

Two other roles from the guide are worth knowing.

1. A logistics platform can be a producer if it packs products for its own order shipments, and is not working as a subcontractor. A pure cross-dock is not.
2. A marketplace is responsible for declaring packaging placed on the market by its third-party sellers, unless it can show the seller has already done so.

How realistic is 10% for transport packaging?

Reuse here means a second use for the same purpose, organised by or for the producer. A pallet that arrives once from India and is then broken up or sold on does not meet that test. Sending pallets or crates back from France to India is a long and costly loop.

So for most importers, the reuse they count will come from legs inside France and Europe. Pallet pools, returnable crates between their own sites and regular customers, and reusable covers in place of film inside their own network are the obvious routes. Our part, as the people who send the goods, is to make our packaging easy to fold into those loops.

Another French date in 2027: EPR for professional packaging

France is also starting extended producer responsibility (EPR) for industrial and commercial packaging. According to an AFP report published by Banque des Territoires on 28 July 2026, the government moved the start from 1 July 2026 to 1 January 2027 and asked the companies concerned to join an eco-organisation by the end of 2026.

The French building federation, FFB, reports three approved eco-organisations: Citeo Pro, Léko Pro and Twiice. It also reports a dispute over a state interpretation note that would make any company buying certain transport packaging, such as films, strapping and corner boards, a "producer". I have not read that note myself.

If you supply pallet film or strap into France, this matters. Wait for the published order and your buyer's eco-organisation contract before you assume who pays.

What an exporter can do in 2027

1. Ask your French importer three things. Does it place 10,000 units or more a year? Which turnover band is it in? How will it count your packaging?
2. Send a packaging sheet with every shipment: pallet type and weight, film weight per pallet, strap weight, corner boards, cartons per pallet. France counts in units and tests reuse by weight, so your buyer needs both.
3. Weigh your film and straps against the pallet. If your buyer reuses the pallet, the 20% weight rule decides whether it counts as reused, and less film helps. Our guide to film per pallet explains how to measure it.
4. Use pallet sizes and types your buyer can put straight into its own pool or loop, so each pallet has a second life in France.
5. For repeat products, offer returnable crates if your buyer runs a closed loop with its own customers. Agree who owns them before the first one ships.
6. Keep straps simple to cut, remove and sort. Our strapping guide compares PP, PET and steel.
7. Read the EU picture too. From 2030, the EU's own reuse targets for transport packaging start at the first EU warehouse. See the EU reuse rules for pallet wrap and straps.

If you need help putting that packaging sheet together for a French buyer, write to us through our contact page. We will tell you which weights and counts to record.

This article is general information, not legal advice. French rules on reuse and on professional packaging are still being written, so please confirm your position with your French importer and a French adviser.