I am a company based outside France: what should I do?
Not all foreign companies are required to appoint an EPR representative. This requirement depends, in particular, on the relevant EPR scheme, your sales channel and the applicable regulations. However, with recent regulatory changes, this requirement is becoming more widespread. Always check the specific rules for the EPR schemes that apply to you.
If you are a foreign company and place products on the French market, you must check whether your products fall under one or more EPR schemes.
If so, you must ensure compliance, either directly where possible or with the support of an EPR representative, depending on your situation.
Step 1: Identify your products
Start by listing the products or packaging that you sell or distribute in France.
Also consider the related elements:
- Batteries;
- Electrical or electronic equipment;
- Packaging;
- Photovoltaic panels;
- Accessories;
- Integrated components.
A single product may fall under multiple EPR schemes. This step is essential to avoid addressing only one scheme when several EPR obligations may apply.
Step 2: Identify the relevant EPR schemes
Depending on your products, different producer responsibility organisations (PROs) may be relevant:
- Batribox for batteries;
- Ecologic for electrical and electronic equipment, sports and leisure goods, and powered DIY and gardening equipment;
- Soren for photovoltaic panels;
- Twiice for professional packaging.
This step helps identify the appropriate contacts, the steps to take and any specific requirements for each EPR scheme.
Step 3: Check whether you need an EPR representative
If you do not have an establishment in France, check whether you need to appoint an EPR representative for the EPR schemes that apply to you.
The EPR representative can support you with the steps set out in the mandate, such as joining a PRO, EPR reporting, payment of EPR fees, administrative follow-up and management of compliance documentation.
The rules may vary between EPR schemes. It is therefore important to assess your situation product by product, packaging type by packaging type and scheme by scheme.
Step 4: Gather the necessary information
Before contacting a producer responsibility organisation (PRO) or an EPR representative, gather the following key information:
- Your company’s identity;
- Country of establishment;
- Products sold in France;
- Volumes or estimated quantities placed on the market;
- Potentially relevant EPR schemes;
- Sales channel: direct sales, through a distributor, via a marketplace or online;
- Whether you already have an EPR representative in France;
- UINs already obtained, if any.
This information will help you identify the appropriate steps more quickly and determine whether several EPR schemes need to be handled in parallel.
Key Takeaways
First, you must identify your products, packaging and the relevant EPR schemes. You can then determine whether you need to appoint an EPR representative and contact the appropriate organisations.