Extended producer responsibility for packaging in France
From January 2022, according to the Anti-Waste & Circular Economy Law, sellers offering their goods in France must comply with the new Extended producer responsibility (EPR) rules for packaging and register with the French Agency for Ecological Transition (ADEME) to fulfil their waste obligations.
Who must register
According to Article L541-10 of the French Circular Economy Law, all producers must register for packaging waste if they generate waste in France.
This producer designation applies to those who fulfil any of the subsequent criteria:
- produces an item that falls under the scope of Extended Producer Responsibility (EPR) regulations in France and market it within the French territory;
- imports a product subject to Extended Producer Responsibility (EPR) requirements into France.
There is no threshold for registration. When placing any quantity of packaging on the territory of France, the manufacturer is obliged to register in accordance with the EPR.
Producers’ obligations for Extended Producer Responsibility (EPR) packing in France
- Registration procedure
In order to comply with the EPR scheme, must get UIN number. To obtain a UIN number, need to register with the French Agency for Ecological Transition (ADEME). Only this agency can assign a UIN number.
Usually, producers do not register directly with the agency but register with a producer responsibility organization (PRO).
This organization is then responsible for obtaining the UIN number.
However, to do this, first need to provide all the information about the company with supporting documents and the volume of packaging used for the year. Also need to pay the first eco-fee, usually 150 euros. Only then will the organization (PRO) apply for a UIN number for companies, but this takes a few days and always happens on time.
UIN is a unique indication number issued by the relevant authority (ADEME) and is proof that the manufacturer has registered with the recycling system and paid all the necessary fees and charges for recycling. It is valid for only one year, but the term is renewable if the company submits correct reports on time and pays all required fees. An example of a UIN number is FRXXXXXX_01VNF.
- Conclusion of a contract with a producer responsibility organization (eco-operators).
- Payment of periodic fees for packaging volumes.
- Submission of annual reports on packaging volumes delivered to France.
Foreign companies don’t need an authorized representative to register for EPR packaging registration.
Packaging reports for 2023 are due by February 29, 2024.