DGCCRF or DDPP inspection of a UK company: what happens and how to respond

DGCCRF or DDPP inspection of a UK company: what happens and how to respond

Yes, the French consumer authorities can inspect a UK company that sells in France, even without a French office. They check your website as a French customer would, visit any warehouse or office you have in France, demand documents and interview your staff. The outcome can be a compliance order with daily penalties, an administrative fine, publication, product recalls or criminal proceedings. Before a fine, you get one month to respond in writing, and every letter is in French.

Updated: November 2026. Key provisions: Articles L. 512-5, L. 512-8, L. 512-10, L. 512-16, L. 512-23, L. 521-1, L. 521-7, L. 522-5 and R. 522-2 of the French Consumer Code (Code de la consommation); Article 18 of Regulation (EU) 2019/1020; Article 121-2 of the French Criminal Code.

This article follows the procedure from the point of view of a UK company: who is targeted, what officers can do, the deadlines, what can follow and what happens with a fine if your assets are in the UK. The substantive rules (CE marking, EU responsible person, French consumer law, language, prices) are covered in the other articles of our UK series, starting with our guide to selling to France from the UK after Brexit. Victoris is a Paris law firm: English law is mentioned only to explain your position, and nothing here is advice on English law. All examples are fictitious. If you have already received a letter, see our page for a lawyer for DGCCRF and DDPP inspections.

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Who the French authorities are

The DGCCRF (the French authority for competition, consumer affairs and fraud control) is a directorate of the Ministry of the Economy. Locally, inspections are carried out by the DDPP (direction départementale de la protection des populations), the consumer protection office of each French département, and by regional and national services. Their officers are empowered to investigate breaches of the French Consumer Code (Article L. 511-3), including product safety and compliance rules (Article L. 511-11) and the obligation to have an economic operator established in the EU under Articles 4, 5 and 7 of Regulation (EU) 2019/1020 (Article L. 511-12, 5°).

These rules apply to offers made to French consumers and to products placed on the French market. Your registered office in the UK does not take you outside their scope. In practice, the DDPP of the département where your warehouse, office or French partner is located usually leads the case.

Who is targeted: your company, your French branch and your directors

A French branch is not a separate company

Many UK companies have registered an establishment (établissement secondaire, often called a succursale or branch) in France: a warehouse, a sales office, a customer service team. The French Commercial Code defines it as a permanent establishment, separate from the registered office, run by a person with authority to deal with third parties (Article R. 123-40). A branch has no legal personality of its own: as Bpifrance Création, the French public business agency, puts it, it has no assets, capital or company name of its own, and its debts are those of the company.

So when officers visit the French warehouse or write to the branch manager, it is the UK company itself that is being inspected, and any order or fine will be addressed to it. Take a Bristol company selling cosmetics online and shipping from a warehouse in the Oise, north of Paris, run by its French branch (fictitious example): the findings made at the warehouse concern the Bristol company directly.

A subsidiary, a logistics provider or an authorised representative is a separate person

A French subsidiary is a separate French company, and so is an independent fulfilment provider, distributor or authorised representative. Each can be inspected for its own obligations. Officers then look at the role of each one in the supply chain: manufacturer, importer, distributor, authorised representative or fulfilment service provider. The criteria are known (who buys and owns the goods, who first makes them available on the EU market, under whose name or brand, who stores and ships them without owning them), and the answer depends on contracts, invoicing and actual flows. It should be worked out before anyone answers the authorities.

Directors can be personally liable for criminal offences

Administrative measures under the Consumer Code target the business, in practice the company running the website or placing the products on the market. Under criminal law, Article 121-2 of the French Criminal Code makes companies liable for offences committed on their behalf by their bodies or representatives, and states that this does not exclude the liability of the individuals who committed the same acts. A director registered at Companies House can therefore, depending on the facts, face criminal proceedings in France while living in the UK.

What French inspectors can do

Online checks and test purchases

For a UK seller, the inspection almost always starts on its website. Officers may use an assumed identity to check online sales and commercial practices (Article L. 512-16). They place an order as a French customer, keep screenshots of the checkout, download your terms, receive the parcel and test the withdrawal process, without saying who they are. You usually learn about it weeks later, when you receive a report or a request for documents. The parcel itself (labels, instructions, operator details, language) becomes evidence.

Visits to your French premises

Officers may enter business premises between 8 am and 8 pm (Article L. 512-5). A branch warehouse, a customer service office or a logistics provider's site all qualify. Visits may be announced or not. Officers examine stock, labels, instructions and any documents available on site. A short written instruction saying who to call and who may speak for the company helps the employee on duty that day.

Requests for documents and information

Officers may demand "documents de toute nature" (documents of any kind) that help them carry out their task (Article L. 512-8), and may collect any information, justification or document needed, on the spot or by summons (Article L. 512-10). For a UK company, the request typically covers the technical file, the EU declaration of conformity, test reports, the identity of your EU economic operator, contracts with French partners, French sales volumes and complaint history. The documents are often in the UK; the deadline is the same.

Interviews (auditions)

Officers may interview anyone likely to provide useful information, on the spot or by summons (Article L. 512-10). The written record must include the questions asked; the person interviewed reads it, may add comments and signs it. It is drafted in French, which is a real problem for a UK director who does not read the language. Where the person is suspected of having committed an offence, the safeguards of Article 61-1 of the French Code of Criminal Procedure apply: the right to leave at any time, the right to an interpreter where needed, the right to remain silent and, for an offence punishable by imprisonment, the right to a lawyer. See why a DGCCRF interview is not a formality.

Product samples

Officers may take samples under conditions set by decree, and test or analysis reports may be sent to the persons concerned (Article L. 512-23). For a Manchester company selling kettles and hair dryers from a French warehouse (fictitious example), that can mean electrical safety tests in a laboratory. Results often arrive months later and then serve as the basis for product measures or criminal proceedings.

Obstruction is a criminal offence

Obstructing officers is prohibited (Article L. 512-4) and punishable by two years' imprisonment and a fine of €300,000, which can be raised to 10% of average annual turnover (Article L. 531-1). Prolonged silence, refusing access to a warehouse or handing over plainly incomplete documents may be looked at in that light. Where the line lies between discussing a request and obstructing it is a case-by-case question to settle before you reply.

Letters in French, deadlines and the right to be heard

Language

Requests, reports, preliminary letters and decisions are written in French, and no provision of the Consumer Code reviewed for this article requires the authorities to translate them for a foreign company. You need a reliable translation for your board, and your reply should be in French, or at least come with a French version. English attachments can be produced, but a document the officer cannot read may be misunderstood or ignored. Some documents must exist in French anyway, such as the EU declaration of conformity for electrical equipment (Article 13 of Decree No 2015-1083 of 27 August 2015).

Before a compliance order (injonction)

Under Article L. 521-1, officers may order a business to comply with its obligations, stop an unlawful practice or remove an unlawful clause "après une procédure contradictoire" (after an adversarial procedure, meaning you must be heard first). The order is signed by the director of the DDPP, the regional directorate (DREETS) or the head of the DGCCRF's national investigation service (Article R. 521-1). In practice you first receive a letter announcing the intended orders and inviting your comments by a date it sets. We found no minimum period in the Consumer Code for this stage: the deadline is the one in the letter.

Before an administrative fine: one month

Before any fine, the authority must inform you in writing of the intended penalty, tell you that you may be assisted by the adviser of your choice and invite your written and, where relevant, oral comments (Article L. 522-5). The period is one month (Article R. 522-2). After that, the fine can be imposed by a reasoned decision. The authority may also send a settlement proposal (transaction administrative) with the same letter, which suspends the one-month period (Article L. 522-9-1); any settlement may itself be published.

Before a measure on products: at least ten working days

Where the authority acts as a market surveillance authority under EU harmonisation legislation (CE-marked products, for example) or Regulation (EU) 2019/1020, Article 18 of that Regulation applies directly. Any measure must state its exact grounds and be communicated without delay with the available remedies and time limits. Before it is taken, the operator "shall be given the opportunity to be heard within an appropriate period of not less than 10 working days", unless urgency based on health, safety or another protected public interest prevents it; in that case you must be heard as soon as possible afterwards and the measure reviewed promptly.

Asking for more time and getting assistance

You can ask in writing, before the deadline and with reasons (documents held in the UK, translation, technical analysis), for more time. The authority does not have to agree, and a late or unexplained request rarely succeeds. Article L. 522-5 expressly mentions assistance by an adviser. For a UK company, that means a lawyer admitted in France for the French procedure, working with your UK advisers on questions of English law or group organisation.

What can follow: orders, fines, publication, product measures and prosecution

Compliance order and daily penalty

A compliance order sets a reasonable period to comply and may carry a daily penalty of up to €3,000, capped at €300,000 (Article L. 521-1). Where the breach is punishable by a fine of at least €75,000, the daily penalty can be set by reference to worldwide turnover, up to 0.1% per day and 5% in total. If the order is addressed to a company whose accounts are consolidated, the turnover used is that of the consolidating entity, which for a French subsidiary of a UK group may be the group itself.

Administrative fine

Administrative fines are imposed by the consumer authority itself, without a court hearing (Article L. 522-1), at the end of the one-month procedure. The maximum depends on the breach: for example €75,000 for a company that fails to give French consumers the required pre-contract information (Article L. 242-10) or uses a blacklisted clause in its terms (Article L. 241-2). The amounts for the breaches most often found on UK websites are set out in our article on French consumer law for UK online sellers.

Publication

Both a compliance order (Article L. 521-2) and a fine (Article L. 522-6) can be published at your expense, by press, online or by posting a notice for up to two months (Article R. 521-2). You are told during the adversarial procedure what publication is envisaged. A publication in France is visible to your customers and partners on both sides of the Channel, especially if you trade under the same brand.

Product and website measures

If products are shown to be non-compliant or dangerous, the authority can order (by arrêté, an administrative order) their suspension from sale, withdrawal, recall or destruction (Article L. 521-7); in case of serious or immediate danger, ministers can suspend a product for up to one year (Article L. 521-17). Where a product compliance breach is found online and the seller cannot be identified or has ignored an order, the authority can require a warning message on the website, and more drastic measures, up to restricting access, for offences punishable by at least two years' imprisonment (Article L. 521-3-1).

Criminal proceedings

Some breaches are criminal offences. Misleading commercial practices carry two years' imprisonment and a €300,000 fine, which can be raised to 10% of average annual turnover, and five years and €750,000 when committed online (Article L. 132-2). Deception about a product's qualities or risks carries three years and €300,000 (Articles L. 441-1 and L. 454-1). Companies face five times the fine applicable to individuals (Article 131-38 of the Criminal Code). The report is then sent to the public prosecutor, and the case becomes a criminal defence matter. See also what makes a DGCCRF case worse.

Can a French fine be enforced against a UK company?

Recovery under French rules

An administrative fine "est recouvrée comme en matière de créances étrangères à l'impôt et au domaine" (is recovered like non-tax State debts) under Article L. 522-9. For daily penalties under a compliance order, Article R. 521-2-1 refers to recovery orders (titres de perception) issued by the minister. Recovery follows its own rules, with its own deadlines to challenge it, separate from the appeal against the decision. Letting those deadlines pass because you assume the fine cannot be enforced closes that door.

Assets in France

Enforcement starts in France. Because a branch has no separate assets, its stock, a French bank account in the company's name or money owed to the company by French customers or platforms all belong to the UK company. A French subsidiary is different: a fine imposed on the UK parent does not become the subsidiary's debt.

Enforcement in the UK

If the company has no assets in France, the question becomes whether a French administrative decision can be enforced in the UK. That is a matter of UK law, on which we do not advise. None of the French or EU texts reviewed for this article provides a mechanism for enforcing French consumer administrative fines in the UK. The fine nevertheless remains due in France, can be recovered from any assets that later arrive there, and weighs on any future French business. Product and website measures do not depend on recovery at all.

What the UK authorities can and cannot do

The EU-UK Trade and Cooperation Agreement includes a provision on cooperation on market surveillance and non-food product safety (Article 96). Section 14 of the European Union (Future Relationship) Act 2020 governs how UK authorities may use non-food product safety information supplied by the European Commission under that Article, for limited purposes: health and safety, consumer protection and environmental protection. This is information sharing between authorities. It does not turn UK regulators into enforcers of DGCCRF or DDPP decisions, and it does not cover consumer law issues unrelated to product safety, such as withdrawal rights or website terms.

A product measure taken in France may therefore come to the attention of UK authorities, who apply UK law to UK sales. Keep what you tell each side consistent. Where your EU economic operator is in another Member State (an authorised representative in Ireland, for example), the European Commission's 2021 guidelines confirm that the French authority can contact it directly, and it can only answer with your documents.

DDPP letter to a UK company: what to do first

These first steps avoid early mistakes. They are not a defence strategy, which depends on the findings, the products and how your group is organised.

1. Record the date of receipt, the authority that sent the letter (which DDPP, DGCCRF or national service) and the deadline.
2. Identify who is targeted: the UK company itself (including through its branch), a subsidiary, a logistics provider or an authorised representative.
3. Get an accurate translation for your board and plan a reply in French.
4. Appoint a single contact for the authorities and check that this person can bind the company.
5. Gather the documents requested as they exist, without creating new ones after the event, and keep a dated list of everything sent.
6. Keep dated records of your website and product pages before changing them, even when a correction is needed.
7. Tell French partners who may be contacted (warehouse, authorised representative, distributor) that the authorities may approach them.
8. Before any interview, know the legal framework and the person's rights, and arrange assistance.
9. If documents or translations cannot be ready in time, ask in writing for more time, with reasons, before the deadline.

In a UK group, the temptation is either to let the French branch reply because it speaks the language, or to send everything to London because it holds the documents. Both go wrong when one entity's answers contradict the other's. Each person interviewed answers for what they know. Coordination is about documents and roles: who holds which documents, who speaks for which company, and in what order the questions of role (manufacturer, importer, representative) are dealt with. That is the point at which a lawyer admitted in France is most useful.

FAQ

Can the DGCCRF inspect a UK company with no office in France?

Yes. Officers check offers made to French consumers and products sold on the French market, wherever the seller is based. They can buy online under an assumed identity (Article L. 512-16 of the Consumer Code) and contact operators present in France or the EU. Measures target the products, the website and its French offers.

Is my French branch fined separately from my UK company?

No. A branch has no separate legal personality, so the UK company itself is inspected and, if need be, penalised. A French subsidiary is different: it is a separate company, responsible for its own obligations.

How long do I have to respond to a DDPP letter?

One month from the written notice of an intended fine (Articles L. 522-5 and R. 522-2). Before a compliance order, the deadline is the one set in the letter. Before a market surveillance measure on a product, at least ten working days unless the matter is urgent (Article 18(3) of Regulation (EU) 2019/1020).

Can I reply to the French consumer authority in English?

Letters and reports are in French, and a reply in French avoids misunderstandings. English documents can be produced, but their weight depends on what the officer can understand, so translations of the relevant passages are often needed.

Can a French consumer authority fine be enforced against my UK business?

It is recovered under French rules (Article L. 522-9), first from assets in France, including those of a French branch. Enforcement in the UK is a matter of UK law, on which we do not advise. The fine remains due in France even if you have no assets there today.

Can a UK director be prosecuted in France?

For criminal offences, yes, depending on the facts: the company's liability does not exclude that of the individuals involved (Article 121-2 of the Criminal Code). A director who is interviewed as a suspect has the rights set out in Article 61-1 of the Code of Criminal Procedure.

Conclusion

A UK company inspected by the DGCCRF or a DDPP faces the same powers and the same outcomes as a French company. What differs is the structure in France (branch or subsidiary), the language, the time needed to gather documents held in the UK, and enforcement. The deadlines are short and start running when the first letter arrives. If your company, its French branch or a French partner has received a request from the French authorities, Victoris can review the situation with you and assist you through the procedure, working alongside your UK advisers.

Article written by Guillaume Leclerc, lawyer at the Paris Bar, 34 avenue des Champs-Élysées, Paris. Working languages: French and English.

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