Within the framework of the French law on circular economy (loi AGEC), it is provided that an EPR registration number be allocated to the producer for each EPR to which his products are subjected to. This registration number must appear in a contractual document or on the internet website, under penalty of sanction. The implementation of the registration number will allow to better identify the producers who are not compliant with their obligations as part of the EPR.
This new provision generates considerable consequences not only for French distributors but also for e-commerce platforms. The latter are responsible to ensure EPR compliance of their vendors. In practice, vendors will therefore have to prove their EPR compliance to the e-commerce platforms on which they sell products.
Who is concerned?
Each person who manufactures, imports, or introduces products subject to EPR on the French market. Depending on the provisions of the EPR field, it will either be a company present in another member 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 who is concerned by the obligation.
What are the fields subject to Extended Producer Responsibility (EPR) in France, and therefore concerned by the EPR registration number?
You will find here a table with currently existing and upcoming EPR fields.
How to obtain an EPR registration number?
The approved collective compliance schemes in France will send the EPR registration number to their members at the beginning of next year. If you are already a member of a compliance scheme in the sectors concerned by EPR (packaging, WEEE, batteries, furniture, textiles, household chemical waste, etc.) you do not need to take any action.
If you are not yet a member of a compliance scheme and your packaging or products are covered by extended producer responsibility, you can obtain the EPR registration number by joining the collective compliance schemes concerned.
Dates and deadlines:
The law comes into effect on the 2nd of January 2022.
Communication obligation:
Starting in 2022, the producer must be able to communicate his registration number upon the buyer’s request. Additionally, the registration number must be indicated in the general conditions of sale, or if non-applicable, in any contractual document transmitted to the buyer. Each producer disposing of an internet website must also make the registration number appear on it.
Support by the Environmental Department at the CFACI:
The Franco-German Chamber of Commerce and Industry supports you by making sure that you are compliant with the Extended Producer Responsibility (EPR). Contact us now and ask for your “Compliance Check” (personalized advisory service) to determine your responsibilities as producer or supplier.