What are my obligations?
When you place products or packaging on the French market that fall under one or more EPR schemes, you must comply with several obligations.
Under the French Environmental Code, these EPR obligations cover all the steps a company must take to comply with the regulations and contribute to the end-of-life management of its products or packaging.
Depending on the products or packaging concerned, these obligations may include identifying the applicable EPR schemes, joining a producer responsibility organisation (PRO) or, where permitted, setting up an individual system, obtaining a Unique Identification Number (UIN), reporting the quantities of products or packaging placed on the market and paying the required eco-contributions or eco-fees.
Identify the relevant EPR schemes
France currently has around 20 EPR schemes covering a wide variety of product categories.
The first step is to identify the products you place on the market in order to determine which EPR scheme or schemes apply.
A company may be subject to a single EPR scheme or several EPR schemes at the same time, depending on the products it sells.
For example:
- If you place batteries on the market, you fall under the Batteries EPR scheme (Batribox).
- If you sell electrical or electronic equipment, you may fall under the EEE EPR scheme (Ecologic, depending on the relevant scope).
- If you place photovoltaic panels on the market, you fall under the Photovoltaic EPR scheme (Soren).
- If you sell professional packaging, you may fall under the Professional Packaging EPR scheme (Twiice, depending on the relevant scope).
Be sure to analyze the entire product, including its components and related parts. A single product may fall under several EPR schemes.
For example, electrical equipment that contains a battery and is sold in professional packaging may be subject to multiple EPR schemes.
If you are unsure which EPR scheme(s) apply to your products, see the article “Which EPR scheme applies to my product?”.
Choose a compliance method
Once the relevant EPR schemes have been identified, you must decide how to meet your obligations.
There are generally two ways to do this:
- By joining an approved producer responsibility organisation (PRO) for the relevant EPR scheme;
- Or by setting up an individual system, that is, by directly fulfilling your EPR obligations, when this option is provided for by regulation
In practice, joining a producer responsibility organisation (PRO) is the most common approach. It allows companies to rely on an established system with reporting rules, fee schedules, tools and dedicated support.
Report products placed on the market
You must report the quantities of products or packaging placed on the market for each relevant EPR scheme.
The frequency of reporting varies depending on the EPR scheme and the producer responsibility organisation (PRO). Depending on the circumstances, reports may be submitted quarterly, every six months or annually.
These reports are used to calculate the eco-contributions or eco-fees due and to monitor the performance of the relevant EPR scheme. They must be accurate, complete and submitted in accordance with the applicable reporting requirements.
If you sell several types of products, you may therefore need to file several reports, corresponding to the various EPR schemes that apply to you.
Obtaining and using your Unique Identification Number (UIN)
The Unique Identification Number (UIN) is assigned to your company for each relevant EPR scheme. It confirms that your company is registered for that scheme.
You may have several UINs if you are subject to several EPR schemes. For example, you may have one UIN for batteries, another for electrical and electronic equipment, another for packaging and another for photovoltaic panels.
Key Takeaways
As a producer, you must identify the relevant EPR schemes for your products or packaging, join the appropriate producer responsibility organisation (PRO) or, where permitted, set up an individual system, report the products placed on the market, pay the required EPR fees and obtain the UINs corresponding to your EPR schemes.
As a producer (the person placing products on the market), you must:
- Identify the relevant EPR scheme(s) for your products;
- Choose your compliance method (membership in a producer responsibility organisation (PRO) or, where permitted, an individual system);
- Obtain the Unique Identification Number(s) (UIN) corresponding to your EPR scheme(s);
- Report the products or packaging placed on the market in accordance with the applicable procedures;
- Pay the required eco-contributions or eco-fees, depending on the relevant EPR scheme.
