According to Article L541-10 of the French Circular Economy Law, you are considered a producer if you are generating waste in France. You are a producer if you meet at least one of the following conditions:

• You manufacture a product subject to EPR requirements in France and sell it domestically; or
• You import a product subject to EPR requirements into France; or
• You sell products under your own brand/name.

Starting from 2022, marketplaces require confirmation of your compliance with the requirements of extended producer responsibility. The principle of extended producer responsibility requires companies to participate in managing the production of products they place on the consumer market. In France, this applies to clothing, home textiles, and footwear intended for household use.

Which products are affected?

• New consumer clothing;
• Home textiles;
• Footwear.

To confirm your compliance with the requirements, you need to obtain a Unique Identification Number (UDI). The UDI serves as evidence that your company is registered with an eco-organization and provides up-to-date information about its environmental contributions, as required by law. The UDI is used to facilitate monitoring and control of the obligations imposed on producers.

This requirement came into effect on January 1, 2022 (Law No. 2020-105 of February 10, 2020, on waste management and the circular economy).

The number is generated by ADEME, the French authority in the field of ecological transition (ademe.fr), but it is issued by the eco-organization.

For producers who are not yet members, the number will be issued after completing all the steps:

• Become a participant: enter into an agreement with the eco-organization Refashion as a producer;
• Prepare your annual declaration for Refashion. The declaration is annual and must be submitted no later than March 15th;
• Pay the contribution associated with this declaration annually;
• The payment of the contribution amount must be received after receiving the invoice and no later than 31/03.

The contribution amount is calculated for each product based on the quantity of corresponding products sold in the previous year, using 4 different scale codes depending on the size of the products.

Here is an example of the calculation scale for bedding entering the market in 2023. The amounts are expressed in euros without VAT/item.

The minimum amount of the Contribution is set at 120 euros excluding tax in 2023.

*Once your membership is confirmed, you will need to submit declarations for the previous 3 years. For example, if you join in January 2023, you must provide sales volumes for the years 2022, 2021, and 2020.

Read more information about the EPR in France here.