Overview of France EPR Requirement
France’s Extended Producer Responsibility (EPR)
France’s Extended Producer Responsibility (EPR) law, enforced since January 1, 2022, mandates companies that produce, import, or sell waste-generating products to manage their end-of-life. This regulation spans a wide array of product categories, from packaging and electronics to furniture, clothing, and single-use items. Companies must comply with measures promoting eco-design, consumer information, and proper waste collection and recycling, typically by joining an accredited eco-organization or setting up an approved individual system.
Benefits for Businesses and the Environment
France’s EPR system supports sustainable production and consumption by making businesses accountable for post-consumer waste. It promotes eco-design, extends product lifecycles, and enhances material recycling. Businesses benefit from streamlined waste compliance, brand reputation, and environmental impact reduction. Compliance can also open access to eco-conscious markets and customer segments, while aiding France in achieving EU waste reduction targets.
What Qualifies as Packaging
Packaging covered under France’s EPR scheme includes all materials used to contain, protect, handle, deliver, or present products to consumers, including items used by households and catering professionals. It encompasses household packaging, printed paper, and packaging used outside the home. Specific product groups such as EEE, toys, sports equipment, and furnishings also come under EPR obligations if they involve packaging.
Exempted Packaging
Certain exemptions exist under the French EPR, such as household glass beverage packaging which is exempt from Triman logo requirements. Additionally, products or packaging below specific size thresholds (e.g., under 10 cm²) may display mandatory sorting and Triman information digitally instead of on the product. Other exemptions apply to cross-border product rules compliant with EU or member state standards.
Special Requirements for Single-Use Plastic (SUP) Packaging
France imposes additional requirements on single-use plastic packaging. Compostable plastic must be clearly labeled as “do not throw away in nature,” with specific labels for domestic and industrial composting. Environmental characteristics such as recycled content and recyclability must be declared, alongside potential hazardous content. These rules aim to curb pollution and promote transparency.
Who Must Register for EPR in France
EPR obligations in France apply to any legal or natural person placing waste-generating products on the French market. This includes manufacturers, importers, retailers, and distance sellers across several sectors. Such companies must register with the Ministry of Environment and obtain a Unique Identifier (UID) for each applicable EPR stream they manage.
Data Management and Record-Keeping
Companies subject to France’s EPR must submit annual declarations by May 31, reporting quantities of products placed on the market and waste treatment outcomes. This includes data on recyclability, hazardous substance presence, recycled content, and reusability. The information is submitted to eco-organizations, which forward it to ADEME via the SYDEREP platform.
Common EPR Compliance Challenges in France
Many businesses face challenges with data collection, understanding multiple product stream obligations, and fulfilling labelling requirements like the Triman logo. Managing multiple Unique Identifiers and aligning with eco-organization rules for each product stream adds complexity. Failure to comply can result in substantial administrative fines and reputational damage.
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