Packaging registration in France – EPR

The acronym EPR is used outside of Poland as “Extended Producer Responsibility”. The WEEE Directive, which describes the requirements introduced by environmental regulations, primarily covers the rules for disposing of electronic equipment, but also packaging. We will discuss this aspect in this text because it concerns virtually every e-commerce seller who introduces goods to the French market via this channel.

Table of Contents:

1. Who is subject to the extended producer responsibility system?
2. What is the product fee in France?
3. Registration procedure and resulting obligations
4. Producer Responsibility Organization

Who is subject to the extended producer responsibility system?

What’s it all about? Clearly, it’s about money. Sellers are introducing an increasing amount of packaging to the market, and national economies have to bear the costs of their disposal and sorting. Regulations have appeared that aim to reverse this trend and transfer these burdens to those introducing packaging to the market, i.e., producers. Not only producers, but we will discuss that later.

The WEEE Directive aims to optimize the process of e-waste disposal and reduce environmental pollution. Its introduction is a consequence of the constantly growing amount of used electrical and electronic equipment, as well as packaging, which, with the rapid development of electronic commerce, initiated during the COVID 19 epidemic, also generate a massive increase in the amount of waste.

Manufacturers and sellers who introduce packaging to the French market are required to pay a fee for their recycling to one of the three collection systems. These organizations are responsible for recycling waste in different administrative units. This is a product fee.

What is the product fee in France?

The product fee is a recycling fee – it is intended to balance the cost of recycling packaging waste introduced to the market. The obligation to recycle packaging introduced into circulation applies to all sellers, regardless of the size of the company. It doesn’t apply only to online sellers but also to those who introduce their products to the market through traditional channels, and even restaurants or bars that offer meal delivery in temporary packaging.

From 2022, EPR numbers are required by sellers from marketplace platforms. Not every seller on such platforms is a producer at the same time, but French regulations automatically classify everyone in this role who:

• Produces a product subject to EPR requirements,
• Imports a product subject to EPR requirements,
• Sells a product subject to EPR requirements, but does not have a headquarters in this country.

If you meet any of these conditions, you must register.

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Registration procedure and resulting obligations

The registration obligation covers individual packaging, bulk and transport packaging introduced to the French market. Single-use plastic products and packaging for chemicals and hazardous substances are also subject to registration.

Registration requires the following steps:

• Signing an agreement with a recycling organization,
• Achieving recycling levels (through a recovery organization),
• Paying a fee to the waste recovery organization,
• Periodic reporting on the quantity and weight of introduced packaging and products,
• Marking packages regarding selective collection, secondary raw material content, recyclability, or reusability,
• Compliance with the ban on introducing food packaging containing Bisphenol A.

Producer Responsibility Organization

If you sell on the French market using marketplaces, you must also provide platforms with a unique identification number (UIN) from one of the Producer Responsibility Organizations related to the categories of products sold. From January 2022, they are automatically generated for all sellers. Several organizations operate in France.

The most popular among e-commerce sellers are Citeo and Léko.

After registration, once a year, you have the obligation to report the actual quantities of packaging waste introduced to the market. If the number of packages introduced to the market does not exceed 10,000, you submit a simplified statement and pay a standard recycling fee of 80 EUR net. If you exceed this amount, you must determine the recycling fee, preferably by contacting a representative of the PRO where you registered. The deadline for submission is February 28th of the following year. Participation in such an organization also costs 80 EUR annually.

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