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EPR Requirements: France

What is changing and what do I need to do?

Since January 01, 2022, Amazon is legally required to check if third-party sellers selling in France are compliant with their Extended Producer Responsibility (EPR) obligations for a number of product categories (for details, please refer to the table below), through the collection of valid EPR registration numbers (also referred to as Unique Identification Numbers – UIN). To prove your compliance to Amazon, go to Compliance Information for Extended Producer Responsibility (EPR) and submit your UIN. If you do not submit a valid UIN, Amazon will report and pay eco-contributions on your behalf and recover the fees from you. In addition, you may be required to take action to comply with take-back requirements. For details, go through the FAQs below.

What do I need to do to comply with EPR in France?

For an overview of what you need to do, please refer to the information materials provided by the Ministry for Ecological Transition (MoET - ecologie.gouv). If you are a producer, you need to:

  • Register with one or more eco-organizations (PROs – see details below) for each category of products you sell to obtain a UIN.
  • Report and pay eco-fees to the eco-organization(s) based on the number and type of products sold on a regular basis (e.g. quarterly, bi-yearly or yearly).

Note: In order to obtain a UIN from an eco-organization, you need to complete the registration process. This may include contracting fees, retroactive payment of eco-fees for previous years etc.

As an alternative to joining an eco-organization, you can set up an individual waste management system. However, note that this solution is often more complex and subject to approval by the French regulators. For more information about setting up individual system, please refer to the information provided by MoET at ecologie.gouv.

How do I determine if I am a producer in France?

According to Article L541-10 of the French Circular Economy Law, you are considered a producer if you are generating waste in France. You are a producer if you meet at least one of the following conditions:

  • You manufacture a product subject to EPR requirements in France and sell it domestically or
  • You import a product subject to EPR requirements into France or
  • You sell products under your own brand/name.

What EPR categories are relevant when selling in France?

In France, Amazon is legally required to check if you comply with your EPR obligations through the collection of valid UINs for the products you sell on Amazon.fr. As of 2022, this applies to 14 product categories that are sold on Amazon.fr. New categories will be launched in upcoming years. The below list provides an overview of all categories subject to EPR that you need to comply with if you sell these products on Amazon.fr (you will find details on eco-organizations for each category in the subsequent section):

# Launch Year EPR category Description
1 Prior 2022 Electrical and Electronic Equipment (EEE) Household products, lamps, fire extinguishers and professional electronic products
2 Prior 2022 Batteries Portable, automotive and industrial batteries
3 Prior 2022 Printed Paper Boxes and packaging of products (e.g. box containing a toy), shipping boxes, shipping labels, tapes, etc.
4 Prior 2022 Packaging Printed items such as user manuals, wall papers, gift cards, advertising inserts
5 Prior 2022 Furniture Household and professional furniture
6 Prior 2022 Textile Clothing textiles, household linens and shoes
7 Prior 2022 Tires Automotive, agrarian and heavy handling civil tires
8 Prior 2022 Chemicals Glue, paint, car polish, acetone, Vaseline, mastic
9 Prior 2022 Medical Equipment Needles, micro-perfusion, catheter, pen with retractable needle
10 Prior 2022 Mineral or synthetic lubricating or industrial oils Mineral or synthetic lubricating or industrial oils
11 Prior 2022 Sport and leisure goods Sport and Leisure products except the ones already falling in another EPR category
12 Prior 2022 DIY and gardening articles Do It Your and gardening products except the ones already falling in another EPR category
13 2022 Construction products Construction products destined to professional or households
14 2022 Toys Toys except the ones already falling in another EPR category (eg: EEE)
15 2023 Packaging used in catering industries Professional packaging used to serve or sales products to be consumed (eg: food packaging, pizza boxes) except the ones already falling in another category (eg: packaging)
16 2024 Non-biodegradable synthetic chewing gums Chewing gums non-biodegradable
17 2024 Disposable sanitary textiles (not re-usable) Non-reusable/disposable sanitary textiles including disposable wet wipes for hygiene or cleaning
18 2025 Fishing gear containing plastic Fishing gear containing plastic

Where can I learn more about the EPR categories in France?

For more information about EPR in France, go to the links below:

For questions on specific categories, the registration process and payment of eco-fees, you can reach out to the relevant eco-organizations (Producer Responsibility Organizations – PROs). Below is a list of approved PROs in France:

# EPR category PRO General information Registration
1 EEE Ecosystem (EEE, lamps, fire extinguisher) https://www.ecosystem.eco/fr/article/mon-statut#producteurs https://www.ecosystem.eco/fr/formulaire/adhesion-producteur
Ecologic (EEE, fire extinguisher) https://www.ecologic-france.com/professionnels/fabricants.html https://www.ecologic-france.com/contact.html
Soren (cat 7) (Photovoltaic solar panels) https://www.soren.eco/fabricant-operateur-producteurs-panneaux-solaires-photovoltaiques/ https://www.soren.eco/adhesion-soren/
2 Batteries Corepile https://www.corepile.fr/vous-etes/metteurs-sur-le-marche/ https://www.corepile.fr/vous-etes/metteurs-sur-le-marche/
Screlec https://www.screlec.fr/producteurs-et-metteurs-sur-le-marche-piles-et-accumulateurs/eligibilite-des-adherents/ https://www.screlec.fr/producteurs-et-metteurs-sur-le-marche-piles-et-accumulateurs/comment-adherer/
3 Papers Citeo https://www.citeo.com/devenir-client https://clients-emballages.citeo.com/fr/public/login/espace-adhesion
Léko https://www.leko-organisme.fr/services/entreprise-extranet/ https://producer-app.affiliate.leko.eco/affiliate
4 Packaging Citeo https://www.citeo.com/devenir-client https://clients-emballages.citeo.com/fr/public/login/espace-adhesion
Léko https://www.leko-organisme.fr/services/entreprise-extranet/ https://producer-app.affiliate.leko.eco/affiliate
5 Furnitures Eco-Mobilier https://espace-services.eco-mobilier.fr/ https://espace-services.eco-mobilier.fr/service/comment-adherer-a-eco-mobilier
Valdélia (profesionnal furnitures only) https://www.valdelia.org/recycler-ses-meubles-professionnels-usages/ http://www.valdelia.org/adherents-valdelia/devenir-adherent/
6 Textiles Refashion https://refashion.fr/pro/fr/faq-metteur-en-march%C3%A9 https://extranet.refashion.fr/inscription/
7 Tires GIE FRP https://www.gie-frp.com/faq/ https://www.gie-frp.com/contact/
Aliapur https://aliapur.fr/fr/reglementation-et-obligations.html https://aliapur.fr/fr/l-equipe.html
8 Chemicals Pyréo (distress flares) https://www.pyreo.fr/metteur-sur-le-march%C3%A9-de-feux-de-d%C3%A9tresse/ https://www.pyreo.fr/contact/
Eco DDS https://www.ecodds.com/faq/ https://www.ecodds.com/espace-adhesions/
9 Medical Equipments Dastri https://www.dastri.fr/faq/ https://www.dastri.fr/contact/
10 Mineral or synthetic lubricating or industrial oils CYCLEVIA https://www.cyclevia.com/ https://www.cyclevia.com/
11 Sport and leisure goods Ecologic https://www.ecologic-france.com/ecologic/filiere-asl.html https://www.ecologic-france.com/ecologic/filiere-asl.html
12 DIY and gardening articles Ecomobilier (non thermic products) https://recyclage-filieres.eco-mobilier.fr/ https://recyclage-filieres.eco-mobilier.fr/adhesion/
Ecologic (thermic products only) https://www.ecologic-france.com/ecologic/filiere-abj.html https://www.ecologic-france.com/ecologic/filiere-abj.html
EcoDDS (chemical products) https://www.ecodds.com/faq/ https://www.ecodds.com/espace-adhesions/
13 Packaging used in catering industries Citeo https://www.citeo.com/devenir-client https://clients-emballages.citeo.com/fr/public/login/espace-adhesion
Léko https://www.leko-organisme.fr/services/entreprise-extranet/ https://producer-app.affiliate.leko.eco/affiliate
14 Construction products No scheme approved yet
15 Toys No scheme approved yet
16 Non-biodegradable synthetic chewing gums No scheme approved yet
17 Disposable sanitary textiles (not re-usable) No scheme approved yet
18 Fishing gear containing plastic No scheme approved yet

What is take-back and what has changed?

Offering a take-back service is part of the EPR requirements in France’s Circular Economy law for EEE, furniture, chemicals and single use gas fuel cartridges. If you sell these types of products in France, you must provide your customers with the possibility to return their old similar product for recycling, at the customers’ doorstep, and free of charge.

As of January 01, 2022, you need to display take-back information when selling EEE, furniture, chemicals or single use gas fuel cartridges on Amazon.fr.

What are the types of take-back obligations?

There are two types of take-back obligations if you sell EEE, furniture and/or chemicals products:

  • 1:1 obligation: taking back used products from a customer on the condition that the customer has purchased a new product only for the selected category.
  • 1:0 obligation: taking back used products even if the customer has not purchased a new product.

You are subject to 1:1 take-back obligation by default if you commercially offer EEE, furniture and/or chemicals products to end-users in France. Whether a 1:0 take-back obligation applies to you depends on the characteristics of your physical stores. We recommend you to do your own legal assessment to find out if you are subject to a 1:0 take-back obligation.

Am I subject to take-back requirements and what do I need to do?

If you commercially offer EEE, furniture, chemicals or single use gas fuel cartridges in France, you are obliged to provide customers with take-back services of items free of charge. Since January 01, 2022, you also need to display take-back information when selling on Amazon.fr. Amazon will display the following question on the product detail page of the respective categories: “Our prices include the eco-fees on all the products concerned. You want to recycle your electrical or electronic device for free? Learn more.” After clicking on the link, customers can submit a take-back request to Amazon or will be directed to contact you via your seller storefront page. We therefore recommend to display your take-back information on your seller storefront page by using the following wording

WEEE: To recycle your old waste electrical and electronic equipment (WEEE), please notify the seller using the “Ask a question” button on the top right-hand corner. If you have any issues with notifying the Seller regarding your take-back request, please proceed to the Amazon Help Page. XXX (seller name) is registered with XXX (name of the scheme) for Electrical and Electronic Equipment sold in France. The registration number is 12345678 (seller’s UIN). XXX’s (seller name) authorized representative is XXX (authorized representative’s name, if any). For more information about recycling with Amazon, visit Recycling at Amazon.

Furniture: To recycle your old furniture, please notify the seller using the “Ask a question” button on the top right-hand corner. If you have any issues with notifying the Seller regarding your take-back request, please proceed to the Amazon help page. XXX (seller name) is registered with XXX (name of the scheme) for Furniture sold in France. The registration number is 12345678 (seller’s UIN). XXX’s (seller’s name) authorized representative is XXX (authorized representative’s name, if any). For more information about recycling with Amazon, visit Recycling at Amazonx.

Chemicals: To recycle your old chemicals, please notify the seller using the “Ask a question” button on the top right-hand corner. If you have any issues with notifying the Seller regarding your take-back request, please proceed to the Recycling at Amazon. XXX (seller name) is registered with XXX (name of the scheme) for Chemicals sold in France. The registration number is 12345678 (seller’s UIN). XXX’s (seller name) authorized representative is XXX (authorized representative’s name, if any). For more information about recycling with Amazon, visit Recycling at Amazon.

Single use gas fuel cartridges: To recycle your old single use gas fuel cartridges, please notify the seller using the “Ask a question” button on the top right-hand corner. If you have any issues with notifying the Seller regarding your take-back request, please proceed to the Recycling at Amazon. XXX (seller name) is registered with XXX (name of the scheme) for single use gas fuel cartridges sold in France. The registration number is 12345678 (seller’s UIN). XXX’s (seller name) authorized representative is XXX (authorized representative’s name, if any). For more information about recycling with Amazon, visit Recycling at Amazon.

Do I need to make changes to my product detail page?

No, you need to make changes to your seller storefront page. You can follow the above wording (under "Am I subject to take-back requirements and what do I need to do?") to include on your storefront.

To edit your seller store front page in Seller Central go to Your Information & Policies under Settings, in About Seller, edit the free form text field "About Seller Help Content".

Frequently asked questions – general requirements

We recommend that you refer to the FAQ provided by SYDEREP or refer to the PROs listed above, additional guidance can be found below.

1. I am not a producer and do not have a UIN on my own. What do I need to do?

If you are not a producer, please enter the following number in the Compliance Information for Extended Producer Responsibility (EPR): FR000000_00DIST. By providing this number, you declare that you are not a producer in that EPR category. Amazon reserves the right to contact you for additional details.

2. I am a producer. What happens if I do not submit a UIN to Amazon?

If you do not submit a valid UIN, Amazon will prepare reports on your behalf with details requested by the qualified PROs, declare and pay the applicable eco-contributions on your behalf, in accordance with our current policy link. Note that if you do not provide Amazon with the valid UIN for each category and do not want Amazon to remit EPR eco-contributions on your behalf as described above, you must stop selling EPR applicable products on Amazon.fr to customers with a shipping address in France.

3. I am a producer for some categories but not for others. What do I need to do?

If you are a producer of at least one product you sell on Amazon.fr, you will need to submit your own UIN in the applicable product category on the Compliance Information for Extended Producer Responsibility (EPR). If you are not a producer for any of your products, you can provide the default UIN (FR000000_00DIST) instead. The table below presents a few examples, assuming that you sell textiles and EEE on Amazon.fr.

Scenario What UIN to provide? Example
I am the producer of all products I sell on amazon.fr. Provide your own UIN(s) in all applicable product categories. I sell products in two product categories on amazon.fr: textiles and EEE. I am the producer of all textile and EEE products. I therefore provide my own UINs in both categories: one for textiles and one for EEE.
I am the producer of some products (e.g. 50%) I sell on amazon.fr. Provide your own UIN(s) in all applicable product categories. I sell products in two product categories on amazon.fr: textiles and EEE. I am the producer of some textile and EEE products. I therefore provide my own UINs in both categories: one for textiles and one for EEE.
I am not a producer of the products I sell on amazon.fr. Provide the default UIN (FR000000_00DIST) in all applicable product categories. I sell products in two product categories on amazon.fr: textiles and EEE. I am the producer of textile products. However, I am not a producer of EEE products. I therefore provide my own UIN for textiles. For EEE, I provide the default UIN to declare that I am not a producer in that category.

Note: We have omitted a reference to packaging UINs in these examples for better readability. Online sales of textiles and EEE typically make use of primary packaging and are therefore subject to EPR requirements for packaging.

4. Will I get a single UIN for all categories?

No, you will get a distinct UIN for each category you are selling and for which you are registered with a scheme. Each scheme will provide you with a different UIN, meaning you will have one UIN for each category. You need to provide Amazon with one distinct UIN per category

Note: For EEE, if you sell both household appliances and Photovoltaic (PV) solar panels, you need to register with both Ecosystem or Ecologic for household appliances and Soren for PV for solar panel. However, you will get the same UIN as you are selling within the same EPR category (EEE), and would only need to enter one UIN in the EPR compliance portal.

5. I'm registered for the necessary category, how do I provide Amazon with the registration numbers I have received?

You will need to work with the respective agency to access your registration information and locate the correct EPR number. The Registration Number can then be provided within the Compliance Information for Extended Producer Responsibility (EPR) France. Follow the link to the Compliance Information for Extended Producer Responsibility (EPR) in Seller central to upload the Registration Number(s), click on the Country for which you want to provide the Registration Number(s) and fill in the box

6. What are eco-modulated fees and how are they applied?

In order to incentivize eco-friendly product design, French PROs apply eco-modulation criteria which modulate the eco-fees per product which producers are required to pay. For instance, PROs may charge lower eco-fees for products with a high share of recycled materials. In contrast, they may charge more for products that cannot be repaired or disassembled easily. For details about eco-modulated fees, please refer to the pricing schedules of the PROs.

7. How much does it cost to register with a PRO?

Registration with most PROs is free of charge (except with Dastri). However, you will be required to pay a recurring reporting fee on a regular basis. The fees are set by the PROs and can reach from 0 to 200€. Please refer to the PROs’ pricing schedules for more details.

8. Do eco-organization(s) request retroactive payments when I register with them?

If you were not registered yet, some PROs may charge you eco-fees for products put in France in previous years. The period covered by retroactive payments varies by eco-organization but can cover up to three previous years. Please refer to the PROs’ for more details.

9. Is it mandatory for me to be registered with a Producer Responsibility Organization?

While Amazon can pay eco-contributions on your behalf and recover them from you, we encourage all sellers to be EPR compliant by themselves (FAQ on payment on your behalf below). This includes registration, declaration and reporting and payment of eco-contributions.

10. Do I need to pay for both primary (product packaging) and secondary (shipping) packaging?

Primary packaging (products’ own packaging): Yes, both Fulfillment by Amazon (FBA) or Self-Ship sellers need to pay for primary packaging. Primary packaging is the packaging unit used to wrap the product, for example, the branded box of a pair of shoes or the aluminum can containing a soft drink.

Secondary packaging (shipping packaging): Refer to country specific section above for further information. Secondary packaging refers to shipping boxes/bags used to protect the product during transport to the customer. This can be extended to filling material to protect the product and tapes to secure the package. Shipping labels are also a part of secondary packaging.

11. I sell exclusively on FBA. Do I need to comply for packaging?

Yes. Even if you exclusively sell on FBA, you still need to comply for the primary packaging of your products (i.e. packaging used to protect the product). However, Amazon will be considered the producer for the secondary packaging (shipping boxes).

12. How does Amazon validate my UIN?

We will validate your UIN against the French government’s portal SYDEREP within 5 business days after submission. We will notify you when the validation result is available. Please consider that Amazon will use your SIREN/SIRET number and your company name to validate your UIN. Please make sure that the data on SYDEREP matches the one you have provided to Amazon.

13. What is SYDEREP?

SYDEREP is an online portal for submitting EPR reports. The portal is maintained by French Agency for Ecological Transition (Ademe). Currently, SYDEREP is being redesigned. Until the beginning of 2023, two applications will coexist: the old one (SYDEREP V1) and the new one (SYDEREP V2). For more information, go to the link and go to SYDEREP V1 or SYDEREP V2.

14. My UIN shows as invalid. What do I need to do?

After you submit your UIN number Amazon will validate your submission with the appropriate government agency or PRO. It may take Amazon up to five business days to validate the registration number.

Once validated by Amazon, the status next to your number will change from “Submitted” to “Valid” or “Invalid + reason for invalid”. If the status is “Valid” no further action is required from you, and you can disregard these notifications. However, if the status is “Invalid”, please refer to the reason provided and take appropriate action.

If any of these conditions apply, resubmit the correct number. If none of these conditions apply, you can reach out to Selling Partner Support through Seller Central. In June 2022, we will provide you with an option to appeal offer suppressions and will share details later in Q2.

Frequently asked questions – Payment on my behalf

1. If I sell EPR Applicable Products on amazon.fr to customers with a shipping address in France, but do not provide Amazon with the valid Unique Identification Number, what actions will Amazon take on my behalf?

If you are selling EPR Applicable Products on amazon.fr to customers with a shipping address in France, but do not provide Amazon with the valid Unique Identification Number corresponding to those EPR Applicable Products, Amazon will take the following actions on your behalf:

  • Prepare declaration reports on your behalf, with details requested by the qualified Producer Responsibility Organizations selected by Amazon, such as quantities (number of units or weight of products) of your EPR applicable sales with mandatory details such as device type (such as refrigerator, baby clothing, chair), and product attributes (for example packaging material, materials of furniture). To prepare the reports, Amazon will use information provided in your listings or use default values in the absence of such information.
  • Submit reports for each applicable EPR product category at the end of reporting cycle (which may be quarterly, semi-annual or annual as per the category of the EPR Applicable Product).
  • Pay the applicable environmental eco-contributions in accordance with these Producer Responsibility Organization’s list of prices and the quantity (number of units or weight of products) on your behalf, and
  • Recover these amounts from you.

2. When will Amazon pay eco-contributions on my behalf to the qualified Producer Responsibility Organizations as determined by Amazon?

Amazon will follow a quarterly, semi-annual or annual reporting cycle for each EPR product category as defined by the qualified Producer Responsibility Organizations selected by Amazon. This means that at the end of each quarter for quarterly reports, six months for semi-annual and the year for annual reports, Amazon will pay eco-contributions on your behalf to these Producer Responsibility Organizations. Amazon will update the EPR Educational Page with reporting cycles for each EPR product category at a later stage.

3. Will Amazon recover the eco-contributions paid on my behalf from me?

Yes, Amazon will recover from you the eco-contributions paid on your behalf at the end of each reporting cycle as per the EPR product category. Eco-contributions depend on the list of prices of the qualified Producer Responsibility Organizations and the quantity (number of units or weight of products) of your EPR applicable sales. We will communicate the details of the charge back process at a later stage.

4. Will Amazon pay eco-contributions on my behalf after receiving my UIN?

No, Amazon will only pay eco-contributions on your behalf to qualified Producer Responsibility Organizations selected by Amazon for reporting cycles in which Amazon does not hold your valid UINs for EPR product categories applicable to you. Amazon will thus discontinue paying eco-contributions on your behalf from that reporting cycle (quarterly, semi-annual or annual as per the EPR product category) onwards. You will thereafter yourself pay your environmental eco-contributions to the Producer Responsibility Organization of your choice.

5. I have registered with a Producer Responsibility Organization to get my UIN, but have not received it yet. What should I do?

Keep checking the portal of your Producer Responsibility Organization for your UIN. Once you receive the UIN, provide it to Amazon immediately. Amazon will pay eco-contributions on your behalf to the qualified Producer Responsibility Organizations as determined by Amazon for reporting cycles in which Amazon does not hold your valid UIN for EPR product categories applicable to you.

6. Will Amazon pay eco-contributions on my behalf for sales made on other online stores than Amazon?

No, Amazon will only pay eco-contributions on your behalf for EPR applicable sales on amazon.fr.

7. Will Amazon pay eco-contributions on my behalf for EPR applicable sales shipped out of France from amazon.fr?

No, Amazon will not pay eco-contributions on your behalf for EPR applicable sales shipped out of France from amazon.fr. Amazon will only pay eco-contributions if you sell EPR applicable products to customers with a shipping address in France from amazon.fr. This also includes French overseas territories.

8. Will Amazon charge a service fee for paying on my behalf if I do not provide a valid UIN?

Amazon will not charge a service fee in the near future for this service. However, you will not benefit from any eco-modulation, if Amazon is paying on your behalf. You can only benefit from eco-modulated fees if you declare and pay eco-fees yourself. Please note that if Amazon adds a service fee for paying eco-contributions on your behalf for EPR applicable sales made from January 2023 onwards, you will be notified in advance.

9. Is Amazon paying eco-contributions on my behalf a temporary service?

Amazon will continue paying eco-contributions on your behalf as long as you do not provide Amazon with your UIN for EPR product categories applicable to you. This will help you continue your sales on amazon.fr.

10. How can I subscribe to Amazon’s service of paying eco-contributions on my behalf?

No subscription or sign up is required. If you are selling EPR applicable products on amazon.fr to customers with a shipping address in France, but do not provide Amazon with the valid UINs corresponding to those EPR applicable products, Amazon will by default pay corresponding eco-contributions to the qualified PROs on your behalf for sales made from January 2022 and recover these amounts from you. This includes cases wherein for any reason, you are unable to register with a PRO in any EPR product category in France and are unable to provide Amazon with the corresponding UIN.

Frequently asked questions - take-back requirements

If I don't offer a take-back service, what will happen?

It means that you are not compliant with the applicable regulation.

I am a reseller. Do take-back requirements apply to me?

Yes, if you offer the product categories subject to take-back, you need to provide customers with take-back free of charge.

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