TBA Global

# EPR Compliance

Extended
Producer
Responsibility
In France

WEEE Compliance in Germany Deadline 2 Month Left

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Are you affected by EPR regulations as a merchant or manufacturer in France?

The French government has enforced a new regulation (called “AGEC”, which is the law against wastage and for circular economy) and set up a mandatory compliance system that operates as follows: 
 

Each platform – in this instance, Zalando – is required to provide for, or contribute to, the prevention and management of waste. To comply with this provision, Zalando must be able to prove that our partners who sell in the French market via Zalando have each been issued with a unique ID number (“Identifiant Unique”, or UIN) from the ADEME (l’Agence de la transition écologique – the French Agency for Ecological Transition).


Partners are responsible for registering with the appropriate organisations (more details below) and ensuring that you are compliant and able to continue selling on Zalando.

Zalando is responsible for creating and maintaining a register containing: the identification details of each partner selling in the French market, their VAT number, their unique ID number, and the quantities of products covered by EPR schemes, by category, sold by each partner.


This register must be made available to the ADEME upon request.

A producer refers to “any natural or legal person who develops, manufactures, handles, processes, sells or imports waste-generating products or the elements and materials used to manufacture them”. 

This will either be a company present in another state supplying products to a French distributor, or a French company supplying products on the French market. In the case of a company selling its products directly to French end-users, it is the distant seller i.e. the company selling online. For Zalando and our partners, this therefore refers to partner brands as well as most retailers.

However, if a retailer works with an upstream supplier who is considered a producer as defined above (e.g. an importer), the retailer is not considered a producer. 

Please be aware of the following requirements specific to packaging: for packaging you are accountable for your primary packaging and / or the secondary packaging added by you, such as delivery packaging, i.e. if you place an article within the packaging, you are therefore also considered a producer.

Important note: If you are a Zalando Fulfillment Solutions (ZFS) partner, then ZFS is considered the producer with regard to the secondary (shipping) packaging. However, you will still be considered a producer with regard to the product  packaging (primary packaging).

Please reach out to the relevant PRO that you are registered with. If  the classification between producer / non-producer raises questions.

Every producer selling products in France that fall within an EPR scheme (e.g. textiles, packaging) must register with a Producer Responsibility Organization (PRO) relevant to the product categories you carry. There are further details on the product categories.Each partner is responsible for two registrations:

  1. First with a Producer Responsibility Organization (PRO), if you haven’t already done so. The PRO will issue you with a registration number. In order to receive this number, it is mandatory to pay the required EPR fees. 
  2. Secondly, with the ADEME to get the new unique ID number. Registration with the ADEME is only possible after registering with a PRO. After registration, the unique ID number will be issued from the ADEME to the PRO; the PRO will transfer the new number to its members from early 2022. Please be aware that this is a legal requirement. 

For example: If you sell textiles, you must register with two PROs: one for textiles and one for packaging because of the product packaging, and if you are not a ZFS partner, your shipping packaging. This means that you will get two unique ID numbers: one for textiles and one for packaging.

Please note: In most cases the PRO will apply for the new unique ID number at the ADEME for you. The PRO will provide you with the new unique ID number when you log in on their website. Please reach out to the relevant PRO if you cannot find your number.

If you do not produce or import products, but buy them from a retailer (upstream supplier) within France, your retailer should already have registered. Zalando then requests from you the unique ID number(s) of your upstream supplier(s) as proof of compliance.

If you sell products from different upstream suppliers located in France, you must provide Zalando with the unique ID number of all your upstream suppliers. 

For example:  If you buy your textiles from two suppliers in France, you will have to provide Zalando with the unique ID numbers of both of your upstream suppliers. This would be one unique ID number for textiles and one unique ID number for the product packaging from both suppliers. 

For partners using their own fulfillment on Zalando, you will additionally need to provide Zalando with your own unique ID number for shipping packaging as well. ZFS partners will not need to provide this information, in this case.

If you:

(i) Sell products from upstream supplier(s) located in France, and; 

(ii) Import products from suppliers located outside France, 

You must provide Zalando with the unique ID numbers from your upstream supplier(s) and with your own unique ID number with regard to the products you imported.  

Please note: Your upstream supplier is legally obliged to disclose its unique ID number in its General Terms and Conditions or in a contractual document (e.g. purchase contract, delivery bill, etc.). Please refer to a relevant document, or reach out to your upstream supplier directly.

EPR Compliance Categories in France

WEEE

Register, Appoint a representative (if required), Commission a recycling system

Packaging

License, Register, Report data

Batteries

Register, Appoint a representative (if required), Commission on a take-back system

Textiles

Register, Appoint a representative (if required), Commission on a take-back system

Paper

Register, Appoint a representative (if required), Commission on a take-back system

Furniture

Register, Appoint a representative (if required), Commission on a take-back system

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Our skilled & qualified accountants are ready whenever you are. We help you avoid the risks of wrong EPR registration in France and make sure that you sell legally compliant. Talk to our experts to see how we can help to grow your business.

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