What is the role of an EPR representative?
An EPR representative can support a company with all or part of its Extended Producer Responsibility (EPR) obligations. Depending on the scope of the mandate, the EPR representative may consolidate information, submit reports and manage communications with producer responsibility organisations (PROs) on the company’s behalf.
An EPR representative should not be confused with a producer responsibility organisation (PRO). The EPR representative acts on your behalf. The producer responsibility organisation (PRO), on the other hand, organises or finances the prevention, collection, reuse, recycling, or treatment of end-of-life products or packaging for a given EPR scheme.
What an EPR representative can do
Depending on the scope of the mandate, the EPR representative may:
- Manage your membership with a producer responsibility organisation (PRO);
- Prepare the information required for EPR reporting;
- Report products or packaging placed on the market;
- Pay EPR fees on your behalf;
- Manage administrative follow-up;
- Manage communications with producer responsibility organisations (PROs).
Article L.541-10-13 of the French Environmental Code provides that producers subject to Extended Producer Responsibility (EPR) must be registered with the relevant administrative authority and obtain a Unique Identification Number (UIN). This number confirms that the producer is registered for the relevant EPR scheme.
What remains your responsibility
Working with an EPR representative does not transfer your responsibilities as a producer.
You remain responsible for providing accurate information about your products, packaging, volumes and relevant EPR schemes, and for the accuracy of the data submitted on your behalf. Using an EPR representative does not transfer the producer’s responsibility.
The mandate must therefore clearly specify the tasks entrusted to the EPR representative: membership, EPR reporting, payment of EPR fees, administrative follow-up, communications with producer responsibility organisations (PROs), and management of compliance documentation.
A role that varies by EPR scheme
The role of an EPR representative may vary depending on the products involved.. A company may be subject to several EPR schemes at the same time, such as Batteries, Waste Electrical and Electronic Equipment (WEEE), Photovoltaic Panels, Professional Packaging, Sports and Leisure Goods, or Powered DIY and Gardening Equipment.
For example, if you sell electrical equipment containing a battery and supplied in professional packaging, several EPR schemes may apply: the WEEE, Batteries and Professional Packaging EPR schemes.
Key Takeaways
The role of an EPR representative depends on the scope of the mandate. They can support a company with all or part of its EPR obligations, but the producer remains responsible for compliance.
