How can you comply with your EPR obligations?
Complying with Extended Producer Responsibility (EPR) means identifying your obligations, finding the right contacts and completing the necessary steps for each relevant EPR scheme. Although the process may seem complex, it can be tackled step by step.
The goal is to avoid omissions, particularly when a single product falls under multiple EPR schemes.
List the products or packaging placed on the market
The first step is to list the products or packaging sold, imported, distributed or made available on the French market.
Don’t forget to consider the associated elements:
- Packaging;
- Batteries;
- Electrical or electronic equipment;
- Accessories;
- Integrated components;
- Products covered by a specific EPR scheme.
This step helps identify the potentially relevant EPR schemes.
Identify the relevant EPR schemes and producer responsibility organisations
Once the products have been listed, you must identify the applicable EPR schemes and the relevant producer responsibility organisations (PROs).
For example:
- Batteries: Batribox;
- Electrical and electronic equipment: Ecologic, depending on the products concerned;
- Sports and leisure goods: Ecologic;
- Powered DIY and gardening equipment: Ecologic;
- Photovoltaic panels: Soren;
- Professional packaging: Twiice, depending on the products concerned.
A single product may fall under several EPR schemes. It is therefore important to assess the product as a whole, including all its components.
Verify that you are the producer
Under Extended Producer Responsibility (EPR), a producer is the entity that places a product or packaging on the French market.
This could be a manufacturer, an importer, a distributor, a private-label seller, or a foreign company that sells to customers located in France.
You must therefore check whether you are responsible for placing the products or packaging on the French market for the first time.
Join a PRO or set up an individual system
If you are subject to EPR obligations, you must join the relevant producer responsibility organisation (PRO) or, where permitted, set up an individual system.
Membership generally allows you to provide the necessary information:
- Company Information;
- Relevant products or packaging;
- Volumes or quantities placed on the market;
- Period of activity;
- Administrative information;
- Data on products placed on the market required to calculate eco-contributions.
The producer responsibility organisation (PRO) will let you know what information you need to provide when you join.
Report, pay contributions and keep your information up to date
Once you have joined a producer responsibility organisation (PRO), you must report the quantities of products placed on the market according to the reporting schedule for your EPR scheme and pay the required EPR fees.
You must also keep your information up to date if your business activities, products, relevant EPR schemes or volumes change.
Key Takeaways
To comply with Extended Producer Responsibility (EPR):
- List the products or packaging that you place on the market;
- Identify the relevant EPR schemes;
- Make sure you are the person placing the product on the market;
- Join a producer responsibility organisation (PRO), or set up an individual system where permitted;
- Obtain your UINs;
- Report the products or packaging placed on the market and keep your information up to date.
