Who does what under Extended Producer Responsibility (EPR)?
Extended Producer Responsibility (EPR) involves several stakeholders, each with a specific role: producers, producer responsibility organisations (PROs), public authorities, operational stakeholders, distributors and, in some cases, EPR representatives.
Understanding these roles makes it easier to know who to contact and what steps to take.
The producer or person placing products on the market
Under the Extended Producer Responsibility (EPR) framework, a producer is the entity that places a product or packaging on the French market.
This may include:
- a manufacturer;
- an importer;
- a distributor;
- a private-label retailer;
- a foreign company selling in France.
Its role is to comply with the EPR obligations applicable to products placed on the market: joining a producer responsibility organisation (PRO) or, where permitted, setting up an individual system, submitting EPR reports, paying the required EPR fees, obtaining a Unique Identification Number (UIN) and keeping its information up to date.
The producer responsibility organisation (PRO)
A producer responsibility organisation (PRO) is an organisation approved by the French authorities for one or more EPR schemes.
It supports producers in meeting their obligations by providing tools, fee schedules, reporting platforms and practical information. Depending on the EPR scheme, it organises or funds prevention, collection, reuse, recycling or treatment activities.
Public authorities
Public authorities establish the regulatory framework for EPR.
In particular, they define:
- The relevant EPR schemes;
- Producers’ obligations;
- The approval conditions for producer responsibility organisations (PROs);
- The targets to be met;
- Monitoring procedures.
They also ensure compliance with the applicable framework.
Operational stakeholders
Operational stakeholders carry out activities such as collecting, sorting, preparing for reuse, recycling and treating used products.
They help translate EPR obligations into concrete action, close to product and waste flows.
Distributors
Distributors may have specific obligations, particularly regarding the take-back of certain used products.
These obligations vary depending on the EPR scheme and the products concerned.
The EPR representative
An EPR representative may be needed when you must meet EPR obligations in France without having an establishment there, or when you wish to entrust certain compliance steps to a dedicated representative.
An EPR representative acts on your behalf under a mandate. Their role may include joining a producer responsibility organisation (PRO), submitting EPR reports, handling administrative follow-up, paying EPR fees or liaising with producer responsibility organisations, depending on the tasks set out in the mandate.
Key Takeaways
In the Extended Producer Responsibility (EPR) system, the producer or person placing products on the market remains central to the framework. The producer responsibility organisation (PRO) supports them, public authorities set the regulatory framework, operational stakeholders manage used products in practice, and an EPR representative may act on behalf of a company when necessary.
