Extended Producer Responsibility in France
In France, Extended Producer Responsibility (EPR) obligations are integral to the country’s environmental policy supporting a circular economy, aiming to make producers accountable for the entire life cycle of their products, especially in terms of waste management and recycling. As of May 2024, the French EPR rules are explained in this guide for e-commerce sellers.
Who is Required to Comply?
Producers, sellers, or distributors—any entity that designs, manufactures, processes, or introduces products into the French market—must adhere to EPR regulations. It includes both local and international businesses supplying directly to the French market.
Key Steps for EPR Compliance
- Register with a Producer Responsibility Organization (PRO):
- Unlike DE , where you need to register and report at an authorized registry and join one of the take-back schemes, in France these PRO’s take on the obligations of reporting to the ADEME registry and handle the take-back system resposnibilities. For each relevant product category, epr registration is required. You’ll need a unique registration number for each category, and thus register with the relevant, multiple individual systems.
- Obtain a Unique Identification Number (UIN): after registering with a PRO you will receive a UIN from ADEME (the French Agency for Ecological Transition).
- Fulfill annual reporting requirements: and pay necessary fees to maintain the validity of the UIN.
EPR Applicable Categories and PRO Registration
EPR Product Categories in France
France’s EPR framework encompasses a variety of product categories that require different modalities of waste management. At the moment, France has the most EPR categories of all countries in the EU.
Please note: your products might fall into more than one, two or even three categories. Legally you should have all corresponding UIN numbers.
Corresponding PROs and Their Responsibilities
EPR Category | Notable PROs |
EEE | Eco-systèmes, Ecologic, Soren |
Batteries | Corepile, Screlec |
Packaging | Citeo, Léko, Adelphe |
Print Paper | Citeo |
Furniture | Ecomason, Valdelia, Valobat |
Textiles | Refashion |
Tires | GIE FRP, Aliapur |
Chemicals | EcoDDS |
Medical Devices | Dastri |
Sports and leisure articles | Ecologic |
Toys | Ecomason |
Chemical products | Ecodds |
DIY & Garden Items | Ecomanson, Valobat |
Pleasure & Sports Boats | Aper |
Lubricating Oils | Cyclevia |
Unused Medicines | Cyclamed |
Construction Products or Materials for the Building Sector | OCA Building |
Tobacco | Alcome |
Summary: EPR Compliance Details and EPR Obligations
| EPR Category | Applicable Products | Regulatory Requirement | Where to Register | Frequency of Filings | Potential Fines for Non-compliance |
|---|---|---|---|---|---|
| REP (Packaging) | All products with packaging | Registration with a PRO, Annual reporting, Fee payment | Adelphe (Citeo) | Generally annually | Fines, penalties, suspension from selling in France, fines can go up to €75,000 |
| DEEE (WEEE) | Waste Electrical and Electronic Equipment | Registration with a PRO, Annual reporting, Fee payment | Eco-organisme (Eco-systèmes, ERP, etc.) | Generally annually | Fines, penalties, suspension from selling in France, fines can be up to 5% of annual turnover |
| ECOBATTERIES | Products with batteries | Registration with a PRO, Annual reporting, Fee payment | Eco-organisme (Corepile, Screlec, etc.) | Generally annually | Fines, penalties, suspension from selling in France, fines up to €75,000 |
| Textiles | Textile products | Registration with a PRO, Annual reporting, Fee payment | Specific textile EPR organizations | Generally annually | Fines, penalties, suspension from selling in France, fines can vary |
| All Other Categories | Various different categories | Similar requirements as above | Relevant EPR organizations | Typically annually | Similar penalties and fines as specified above |
Unique ID Number Information
Each producer will receive a unique identifier upon registration with ADEME:
- Format: Begins with ‘FR’, followed by six numbers, an underscore ‘_’, and four uppercase letters (e.g., FR239691_01VNFV).
- Validity: Annually renewable upon fulfillment of EPR commitments.
Labeling Requirements
Producers must ensure that the Triman logo, indicating recyclability, along with sorting instructions, is present on all applicable products and packaging. The Triman logo is specifically for France, it’s like an equivalent of the Green Dot you might know from packaging in other EU countries.
International Considerations
International sellers or those using French upstream suppliers must submit the UINs to prove compliance. Non-compliance can lead to a halt in sales within France.
unlike Amazon DE it is possible to sell or open listing at Amazon FR without all the UIN numbers. However, in this case you will need to pay Amazon France fees.
Additional Information and Assistance
Resources are available for guidance on EPR compliance specifics, including contacts at PROs such as Fenja Petrich from Léko Sas for packaging and the Refashion hotline for textiles.
In conclusion, for e-commerce sellers and importers active in the French market, navigating EPR compliance and understanding the environmental code is critical. Accurate adherence to the guidelines, including proper registration, reporting, and fee payments, is necessary to avoid penalties and to contribute positively to France’s ecological transition.
