FAQ for multiple EPR schemes
What is My EPR Journey for?
My EPR Journey is a service created by Eco-Op in partnership with Twiice to support producers in understanding and complying with their Extended Producer Responsibility (EPR) obligations.
It provides educational information, content covering multiple EPR schemes and guidance tools to help you:
- understand your EPR obligations;
- identify the EPR schemes that apply to your products or packaging;
- know which producer responsibility organisation (PRO) to contact;
- find an EPR representative when your situation requires it.
The goal is to simplify the process for you, especially if your company is subject to multiple EPR schemes or if your situation requires dealing with multiple points of contact.
Key Takeaways
My EPR Journey is an information and guidance service created by Eco-Op in partnership with Twiice. It helps you understand your EPR obligations and identify the right contacts, without replacing producer responsibility organisations (PROs) or EPR representatives.
Which producer responsibility organisation(s) should I contact?
The producer responsibility organisations (PROs) you need to contact depend on the products or packaging you place on the market and the EPR schemes that apply.
Each EPR scheme is managed by one or more approved producer responsibility organisations (PROs). If your company is subject to several EPR schemes, you may need to join several PROs and complete several compliance processes.
My EPR Journey helps you identify the relevant EPR schemes and directs you to the appropriate producer responsibility organisations (PROs). In particular, you’ll be able to identify Eco-Op’s partner PROs, such as Batribox, Ecologic and Soren, as well as Twiice for professional packaging.
For example, electrical equipment containing a battery and sold in professional packaging may fall under the following EPR schemes: Waste Electrical and Electronic Equipment (WEEE), Batteries and Professional Packaging. In this case, several compliance steps may be required.
Key Takeaways
The PROs you need to contact depend on the EPR schemes that apply to your products or packaging. A single company may need to work with several PROs.
How do I join a producer responsibility organisation (PRO)?
To join a producer responsibility organisation (PRO), you must first identify the EPR schemes that apply to your products or packaging. Joining a PRO generally involves several steps:
- Identify the EPR schemes that apply to your products or packaging.
- Choose the approved producer responsibility organisation (PRO) that corresponds to your activity.
- Create an online account and sign a membership agreement with the producer responsibility organisation (PRO).
- Report the products or packaging placed on the French market, in accordance with the procedures set by the producer responsibility organisation (PRO).
- Pay the applicable EPR fees or eco-contributions, calculated based on the products or volumes reported.
- Obtain your Unique Identification Number (UIN), which confirms your compliance with EPR obligations.
Membership requirements may vary depending on the EPR scheme and the producer responsibility organisation (PRO).
If your company is based outside France, additional steps may be required, including the appointment of an EPR representative where required by law.
Key Takeaways
Joining a producer responsibility organisation (PRO) generally involves the same main steps, although the practical requirements may vary between EPR schemes.
What is a Unique Identification Number (UIN)?
The Unique Identification Number (UIN) is proof of your registration with a producer responsibility organisation (PRO) for a given EPR scheme. You may have several UINs if your company is subject to several EPR schemes.
For example, you may have:
- a UIN for batteries;
- a UIN for electrical and electronic equipment;
- a UIN for packaging;
- a UIN for photovoltaic panels.
The UIN may be required in certain commercial transactions or by certain online sales platforms to demonstrate your compliance with EPR requirements.
Key Takeaways
The UIN is specific to each relevant EPR scheme. It must be included in your general terms and conditions of sale or any other contractual document, in accordance with applicable regulations.
When do I need to report the products I place on the market?
If you are subject to one or more EPR schemes, you must report the products or packaging you place on the French market in accordance with the procedures and schedule defined by each producer responsibility organisation (PRO).
The frequency of reporting may vary between EPR schemes and according to the terms of your membership agreement. If your company is subject to several EPR schemes, you may need to submit several reports.
These reports are used to calculate the EPR fees or eco-contributions due and to monitor the performance of the relevant EPR schemes.
If your company is subject to several EPR schemes, you may need to submit multiple reports.
Key Takeaways
Reporting procedures and frequency depend on the relevant EPR scheme and producer responsibility organisation (PRO). Your reports must be accurate, complete and kept up to date if your business activities, products or the volumes you place on the market change.
What is an eco-contribution?
An eco-contribution, or EPR fee, is a financial contribution paid by the producer to a producer responsibility organisation (PRO).
It helps fund prevention and end-of-life management of the products or packaging concerned: collection, sorting, reuse, repair, recycling or appropriate treatment.
The amount generally depends on the relevant EPR scheme, the type of product, the quantities placed on the market and the rules set by the relevant producer responsibility organisation (PRO).
Key Takeaways
The eco-contribution is not a tax. It is used to fund initiatives for prevention and management of end-of-life products and packaging.
What is the difference between an EPR representative and a producer responsibility organisation (PRO)?
A producer responsibility organisation (PRO) is a private, non-profit organisation approved by the French Ministry for the Ecological Transition. Its role is to fund and/or organise prevention and end-of-life management of the products or packaging covered by its approval, on behalf of its member producers.
An EPR representative is a private, for-profit company that helps businesses manage their EPR obligations. It acts on behalf of a producer under a mandate signed by both parties. Depending on the company’s needs, it may act as a legal representative where required by regulations and/or support the producer with compliance procedures, such as joining a PRO, EPR reporting and administrative follow-up.
Key Takeaways
The producer responsibility organisation (PRO) manages the EPR scheme. The EPR representative supports the producer in meeting its obligations and may, in certain cases, represent the producer in dealings with PROs.
What are the risks for my business if it does not comply with EPR requirements?
A company that fails to meet its EPR obligations may face administrative and financial penalties under the French Environmental Code.
Depending on the nature of the breach, the relevant authorities may impose the following penalties:
- A fine of up to 7,500 euros per unit or per metric ton of products or packaging placed on the market
- A daily penalty payment of up to €20,000 until the situation is brought into compliance.
- A fine of up to €30,000 may be imposed in the following cases:
- The company is not registered in the national registry of producers (SYDEREP) maintained by ADEME.
- The company submitted inaccurate or incomplete data
- The company does not include its Unique Identification Number (UIN) in its general terms and conditions of sale or other contractual documents when required.
Key Takeaways
Meeting your EPR obligations helps you avoid significant financial penalties and demonstrate compliance to your business partners and the relevant authorities.
