EPR requirements in France in 2024 – what you need to know

Extended Producer Responsibility (EPR) applies in France as well as in other European countries. As far as the complexity of EPR requirements is concerned, France is among the most advanced markets within the EU.  

EPR is an environmental policy approach. Companies subject to EPR are legally required to take responsibility for their products and packaging with various regulations – from design to disposal.

Who is subject to EPR requirements in France?

Companies that manufacture or import packaged products on the French market for the general public are considered as producers. This also applies to online retailers based outside of France, marketing their products in France.

The exact definition is: “any natural or legal person who develops, manufactures, handles, processes, sells or imports waste-generating products or the elements and materials used to manufacture them.

Subject to EPR requirements in France are those producers selling products that belong to the product categories falling under producer responsibility and therefore requiring EPR registration.

What are the product categories falling under EPR in France?

Failure to fulfil the legal requirements can result in severe sanctions. In Germany, for example, these include penalties of between 10,000 and 200,000 Euros or even a complete sales ban on the German market and an entry in the trade register. However, companies not only suffer economic damage but also have to accept a loss of image and reputation. 

The following list is not complete but contains a selection of product categories falling under EPR in France:

• Household Packaging
• Electric and Electronic Equipment (WEEE)
• Batteries 
• Textiles
• Do-it-yourself and garden supplies
• Furniture
• Tires
• Toys
• Print Paper
• Graphic papers
• Sport Articles 
• Building products and materials
• Chemicals
• Medical piercing equipment for auto-treatment

From 2024, the household packaging and graphic paper sectors will merge to become a single stream. 

In addition, there will be two further categories added to this list in 2024:

• Disposable sanitary products
• Chewing gum

What are the general EPR requirements in France?

Companies subject to EPR requirements in France have two options to fulfil their obligations. They can either build their own individual solution to cover the complete lifecycle of their products and packaging.

Or they can delegate their responsibility as a producer to a Producer Responsibility Organisation (PRO). PROs in France are state-approved eco-organisations like, for example, our partner Léko.

The main obligations consulting from EPR requirements in France are the following categories:

1. Application for the unique identification number.
2. Ensure take-back and recycling.
3. Installation of mandatory sorting and reuse signs on packaging and products.
4. Providing consumer information and claims.
5. Compliance with recyclability quotas.
6. Achievements of reuse targets.
7. Preparation of prevention and eco-design plans.

First steps to fulfil your EPR requirements in France 

To ensure compliance with the EPR requirements in France, companies subject to the regulations need to register with a PRO.

Once registered, they will obtain their Unique Identification Number(s) (UINs). The UINs will be automatically generated via ADEME (l’Agence de la transition écologique) and issued to the respective PRO. The PRO will then transfer the number, which serves as proof of compliance. 

Companies must then declare their sales (of products falling under the different EPR categories) to the PRO for the applicable reporting period and pay eco-contributions to the PRO. The PRO will take responsibility for the collection and recycling of the company’s products and packaging.

Do you want to get started right away? Click here and begin your easy way to EPR compliance in France.

What is new since 2023?

There have been some regulatory developments regarding EPR requirements in the past years and months. Here is an overview of the new laws that have been in force since 2023.

• By 2023, producers with sales of more than €50 million and marketing more than 10,000 units of packaged products per year have to market at least 5% reusable packaging.
• Companies must prepare a prevention and eco-design plan. This plan must be completed for the next 5 years.
• Producers with sales in excess of 50 million euros, putting 25,000 units of product on the French market must inform consumers about the environmental characteristics of household packaging via a web-based product sheet. 
• Creation of an EPR system for restaurant packaging.
• From 2023 onwards, producers contribute to the cost of cleaning up abandoned waste.

Where can you find more information?

PROs such as Léko offer further helpful information regarding compliance with EPR requirements in France.