- EPR Registration & Reporting
France EPR Registration and Filing
Are you affected by EPR regulations in France?
Extended Producer Responsibility is a key environmental concept in France and across the European Union. In a nutshell, EPR regulations mandate that producers take responsibility for the entire lifecycle of their products, from manufacturing to disposal.
Who is defined as a producer?
The following types of businesses are considered as ‘producers’ under French EPR regulations:
- Manufacturers
- Retailers
- Importers
- Resellers (including distance sales)
Any business that is considered a producer and trading in regulated products must register for the correct EPR categories.
EPR Categories in France
The following EPR categories are currently enforced in France.
- WEEE
- Batteries
- Packaging
- Chemicals
- Furniture
- Sports & Leisure
- Textiles
- Toys
Products classified as Waste Electrical and Electronic Equipment (WEEE) are covered under this category.
The European Union has provided a consolidated list of 6 individual categories which are considered WEEE:
- Category 1: Temperature exchange equipment
- Category 2: Screens, monitors and equipment containing screens having a surface greater than 100 cm²
- Category 3: Lamps
- Category 4: Equipment with any external dimension more than 50 centimetres (Large equipment) Category 5: Equipment with no external dimension more than 50 centimetres (Small equipment)
- Category 6: Small IT and telecommunication equipment with no external dimension more than 50 centimetres
If your product contains a battery, you will also need to register for the Batteries category separately.
Products containing most of types of batteries (single-use, rechargeable, automotive) are covered under this category. If your product is classified as WEEE and also contains batteries, you will be required to register for both categories.
Products packed in primary and/or secondary packaging are covered under this category.
‘Primary’ packaging refers to the actual product packaging itself. ‘Secondary’ packaging refers to any additional packaging (e.g. shipping packaging, external protective padding etc.).
This means that many products covered by other categories will also be covered by the Packaging category – most products will be wrapped in its own packaging, along with shipping materials.
Products containing chemicals are covered under this category. Chemical products include (but are not limited to):
- Pyrotechnics
- Fire extinguishers
- Hydrocarbon-based products
- Adhesive/sealing products
- Material treatment/coating products
- Common chemicals
- Solvents
- Fertilisers
Products consisting of furniture (or furniture related items) are covered under this category. This includes:
- Indoor and outdoor furniture (including tables, chairs, sofas, wardrobes, footstools, ironing boards, laundry baskets, dustbins etc.)
- Design elements (including dressing room equipment, front doors, worktops, shelves, racks, baskets, storage boxes etc.)
- Bedding and sleeping equipment
- Curtains and carpets
- Accessories for any furniture products
Products categorised under Sports & Leisure are covered under this category. This includes:
- Bicycles and other transport equipment (non-powered)
- Water sports and leisure
- Sliding sports (mountain, e.g. ski equipment)
- Outdoor recreation
- Horse riding/equestrian
- Racquet sports
- Ball sports
- Personal Protective Equipment
- Sports/bodybuilding
- Hunting/shooting
Products categorised under Textiles are covered under this category. This includes:
- Clothing products
- Footwear
- Household linen
Products categorised under Toys are covered under this category. This includes:
- Outdoor games
- Indoor games (dolls, plush toys, construction, action games etc.)
- Board games and puzzles
- Toy gifts (toys given for free as part of the sale of another product)
How do I prove that my business is compliant?
Major online marketplaces such as Amazon are required to verify that you have obtained the correct EPR registration(s) before commencing sales.
You will be required to upload a valid EPR number for each EPR category for which your product listings are covered under.
Failure to do so can result in product listing suspensions, and repeated offences may result in your seller account privileges being revoked.
If you are selling on your own platform/website, you must ensure that you are compliant or the local authority may levy additional financial penalties.
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Frequently Asked Questions
No, although each EU Member State is required to follow EU EPR principles, they are responsible for implementing their own domestic regulations. This means that every Member State will implement their own EPR categories and registration systems.
You will usually be considered a producer if you are a i) manufacturer, ii) retailer, iii) re-seller or iv) importer.
EU Member States who have implemented EPR regulations will usually require online marketplaces such as Amazon to verify that their sellers are compliant.
Most EU Member States are phasing in new EPR requirements gradually to allow businesses time to make the necessary arrangements for compliance. In order to minimise disruption to sales, it is therefore beneficial for businesses to ensure that they are fully compliant before any relevant enforcement dates.
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