Do I need to join a producer responsibility organisation (PRO)?
If you place products or packaging subject to an Extended Producer Responsibility (EPR) scheme on the French market, you must fulfil your obligations. Joining a producer responsibility organisation (PRO) is the most common way to comply with your EPR obligations.
A producer responsibility organisation (PRO) is an organisation approved by the French authorities. It supports producers in meeting their EPR obligations for one or more EPR schemes.
What is the role of a producer responsibility organisation (PRO)?
The producer responsibility organisation (PRO) supports producers in meeting their EPR obligations and, depending on the EPR scheme, organises or funds the end-of-life management of the products concerned.
Depending on the EPR scheme, it may organise or fund:
- Prevention measures
- Collection of used products;
- Sorting;
- Reuse or preparation for reuse, where possible;
- Recycling;
- Treatment;
- Data and performance monitoring;
- Supporting producers in meeting their obligations.
In return, the producer pays a financial contribution, often referred to as an eco-contribution or eco-fee.
This fee is not a tax: it is used to fund the end-of-life management of products. Depending on the EPR scheme and the applicable rules, it may be visible or subject to specific pass-through arrangements.
How do you choose the right producer responsibility organisation (PRO)?
The appropriate point of contact depends on the product or packaging placed on the market and the EPR scheme(s) involved.
For example:
- Batribox operates in the Batteries EPR scheme;
- Ecologic operates in particular in the Waste Electrical and Electronic Equipment (WEEE), Sports and Leisure Goods, and Powered DIY and Gardening Equipment EPR schemes;
- Soren operates in the Photovoltaic Panels EPR scheme;
- Twiice operates in the Professional Packaging EPR scheme.
You should therefore check the exact scope of your products before joining. If several products or components are concerned, multiple EPR schemes may apply.
Is membership still required?
You are required to fulfil your EPR obligations as soon as you place the relevant products on the market.
There are generally two options:
- Join an approved producer responsibility organisation (PRO);
- Set up an individual system, where permitted.
In most cases, joining a producer responsibility organisation (PRO) is the simplest option. It provides support, access to a reporting platform, helps you obtain a Unique Identification Number (UIN), and contributes to funding the relevant EPR scheme.
What if my company is subject to several EPR schemes?
You may be covered by several EPR schemes at the same time.
For example, if you sell electrical equipment containing a battery and supplied in professional packaging, you will need to check the applicable obligations for the equipment, the battery and the packaging separately.
The best approach is to assess each product individually, and then each component individually.
If in doubt, check the obligations applicable to each product and component concerned before taking any action.
Key Takeaways
If you place products covered by an EPR scheme on the market, you must choose a compliance method. In most cases, this means joining an approved producer responsibility organisation (PRO). The choice of PRO depends on the EPR scheme or schemes that apply to your products.
