New French EPR Changes to Packaging – How Does This Affect My Business?

New French EPR Changes to Packaging – How Does This Affect My Business?

Regulatory Changes

French EPR regulations have been updated again. You may be aware that there are already several mandatory EPR categories in France, and that Packaging is the most common category.  

New legislation (Decree No. 2023-305) means that as of the 1st January 2024, the Paper EPR category has been merged with the existing Packaging category.

How do the EPR changes affect my business?

Most businesses trading in France already need to register for Packaging EPR, as the vast majority of shipments contain some form of primary and/or secondary packaging. 

The new changes mean that many businesses that sell paper products on the French market will not need to register for Paper EPR, but for Packaging instead.  You’ll no longer any need to apply for two separate categories.  

In order to be compliant with the new combined regulation, paper products must: 

 Have a grammage of 224 g/m2 or less

 Not be part of a book/shaped paper

Items such as brochures/leaflets, newspapers and reams of paper will be part of the new merged Packaging EPR category.

Declarations and Contribution Fees under new EPR

The newly combined Packaging category will continue to be managed your Packaging Producer Responsibility Organisation (PRO).  

In addition to your existing packaging usage, you’ll be expected to declare your paper usage under the same category. The < 5-ton contribution exemption for paper will also no longer apply.  

PROs are also making changes to their contribution fee tariffs to take the merger into account. 

Does this affect my sales on Amazon?

Nothing has changed – Amazon is still obligated to check that you have valid EPR registrations for the products that you are selling. Your existing Packaging EPR number will become valid for the Paper category.   

You’ll still be required to upload a valid Packaging number to Amazon Seller Central, which will be checked against your product listings.   

If you do not upload a valid EPR number for your products, Amazon will automatically withhold a portion of your sales to pay for the EPR contribution fees on your behalf.

For more support, please refer to our previous articles, or get in touch with us for a free one-to-one consultation at info@tbaglobal.com.