Regulations regarding packages sent to France (French EPR)

Learn about the new French Packaging Act (part of the Extended Producer Responsibility regulations). Here you will find information on who needs to register their business under this law and what you have to remember about while selling on the French market.

Topics in this article:

• Introduction: Extended Producer Responsibility
• Registration: French Packaging Act
• Who needs to register under this law? 
• Where can I find links to register my company?
• Do I have to register for EPR France if I don't sell in an EPR category scheme?
• Do I have to register for EPR France if I sell used items?  
• Can Webinterpret register my company to be EPR France compliant?
• What will happen during registration?
• How can I calculate the eco-participation fee?
• After registration: showing compliance
• What is a Unique Registration Code (UPIN)?
• How to add UPIN to the items?
• How to check if the UPINs were applied on French listings

Introduction: Extended Producer Responsibility

If you sell products on the French market, you are obligated to comply with the Extended Producer Responsibility regulation (Responsabilité Élargie du Producteur).

This environmental law is part of a bigger initiative started by the European Union called the EU packaging waste directive that aims to reduce landfill waste and increase recycling. Under this law, manufacturers, importers as well as eBay and Amazon sellers are responsible for the life cycle of the products they sell.

The packaging license is required in the country where the packaging ends up as waste. Since there’s no unified recycling scheme, having a license from one country (for example Germany) does not mean you can sell to France without required registration.

Under these French regulations, producers and importers of goods in certain categories are required to add extra information to their eBay listings proving that they have fulfilled their legal responsibilities regarding the utilization of the product.

Registration: French Packaging Act

Who needs to register under this law? 

You need to register with the French recycling scheme if you: 

1. Are a French business, or

2. Sell cross-border to France.

If you sell more than 10 000 products a year and the packaging you use contains paper, plastic, wood, glass or aluminum, you have to:

• Register with a French national directory for packaging 
• Declare the amount of packaging you’re going to send to France in a year.

If you sell less than 10 000 products a year, you have to:

• Register with a French national directory for packaging 
• Pay 80 euros annually to a French recycling company.

All sellers must contribute to the cost of recycling packaging. To comply with these regulations, you will need to contact a relevant eco-organisme. An eco-organisme is a company approved by the public authorities within the framework of Extended Producer Responsibility (EPR) to manage the end-of-life of equipment you put on the market (collection, sorting, recycling and recovery of waste).

Where can I find links to register my company?

The list of registered organizations can be found in the below table. The following list that has been published by eBay (click Eligible categories in the article to expand):

Do I have to register for EPR France if I don't sell in an EPR category scheme?

If some or all of the codes are not required for you, that's ok, you don't need to add them to Seller Hub on eBay. If your products do not fall under the EPR regulations you need to license the household and professional packaging with a recycling system in France. 

Do I have to register for EPR France if I sell used items?  

Most likely you do.  The general rule is that if you are the first importer of the product to France, then you do need to register.  There are some exceptions  - for example Textiles do not require registration.  For accurate information regarding your EPR obligations, get in touch with a legal advisor.

Note: If the products you offer don't fall under the EPR regulations, the packaging you use for shipping may still be subject to the regulations.

Can Webinterpret register my company to be EPR France compliant?

Webinterpret does not offer this service. Some companies provide registration assistance and detailed compliance guides, such as Lizenzero (an official eBay partner dealing with packaging) or Ecosistant.

What will happen during registration?

1. Register in a Producer Responsibility Organization (PRO)

The following three PROs are authorized for sellers within the Extended Producer Responsibility (EPR) framework. 

Citeo: https://www.citeo.com/membership-and-unique-identifier?mtm_campaign=popin_uin

Léko: https://producer-app.affiliate.leko.eco/http://producer-app.affiliate.leko.eco/affiliate

Adelphe: http://adelphe.fr

2. Your PRO will conduct your registration to SYDEREP

3. You will obtain your Unique Registration Code (UPIN)

4. Provide the code to platforms that require it (for example eBay or Amazon)

How can I calculate the eco-participation fee?

If you are a producer or importer of furniture, electrical and electronic equipment in France you are required to add the recycling amount in the eco-participation field. The amount you pay depends on the cost of recycling each type of equipment and differs significantly based on the size and type of products. You can find the amount by registering with a relevant eco-organisme.

After registration: showing compliance

What is a Unique Registration Code (UPIN)?

Unique Registration Code (also called Unique Product Identification Number, UPIN or SYDEREP number) is a number provided by a French environmental agency ADEME to all companies that are compliant with the French recycling laws.

If you’re listing an item from an EPR category on eBay, make sure you include the required Unique Registration Codes (UPINs) in the following fields:

How to add UPIN to the items?

No matter if you have a small or large inventory. Adding the UPIN codes is easy because it's done at the account settings, and not at the item level. Starting from July 2023 the required information can be added directly through this link, which works for all eBay sites.

1. Go to My account settings page:

2. EPR FR Number page:

3. Page will show you error if you enter an invalid ID:

4. EPR FR Confirmation/Check:

You can read more about Extended Producer Responsibility on eBay here. 

Guide on how to register.

Amazon and eBay require this number from sellers. If you don’t provide EPR information, you may end up getting fined or blocked from selling.

If you would like to find out more, see the attached FAQ.

How to check if the UPINs were applied on French listings

If you would like to double-check, if the UPINs were applied on your French listings, please remember that this info is not visible for the buyers!  To access the EPR fields please follow those steps:

1. On www.ebay.fr  choose to edit an existing listing (which you've added to the Webinterpret uploader): click on Selling (Mes ventes), or go to the Listing tab (annonces) in Seller Hub (Hub vendeur). 

2. Go to the Seller Disclosures (Conditions du vendeur) section and click Select your conditions (Sélectionner vos conditions).

3. Choose Extended Producer Responsibility (Responsabilité élargie du producteur).

4. UPINs you've added on the csv file uploaded with Webinterpret will be visible in the corresponding field:

Sources:

https://www.ebay.de/verkaeuferportal/news/verkaeufer/2022-september/epr-frankreichExtended Producer Responsibility for business sellers
Packaging law in France: a guide for e-commerce
Complying with the French packaging law: done in no time!

• Unique Registration Code FAQ.pdf700 KB
• Eco-organismes_filieres_REP_EN_juillet2022 (2).pdf200 KB