French EPR Law
Starting from January 1st, 2022, Joom is legally required to check if merchants selling products in France are compliant with the French Extended Producer Responsibility (EPR) obligations. Therefore, Joom collects merchant valid EPR registration numbers - Unique Identification Numbers (UIN).
What Is EPR?
In general, the EPR is a regime under which product manufacturers or importers and introducers (also called “producers”) bear the financial and organizational responsibility to manage waste at the end of the life cycle of certain categories of products they produce or market.
Who Is the EPR Law Applicable To?
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 in France;
- You import a product subject to EPR requirements into France.
|Considering the above-mentioned conditions, every person who sells products to France could be considered as a producer for the French EPR purposes.|
In particular, the following categories of the products fall under the law:
- Packaging, including primary packaging (products’ own packaging), and secondary packaging (shipping packaging);
- Electrical and Electronic Equipment (EEE);
- Sport and leisure goods;
- Do-it-yourself and gardening articles;
|All the products containing any kind of packaging fall under this category.|
What to Do?
If under the French law you are considered as a producer, you need to:
- Register with one or more eco-organizations (PROs) for each category of products you sell to obtain a UIN. Please note, if you fall within the scope of several eco-organizations, you must request one UIN per PRO.
- Provide your UIN to Joom via Merchant Panel.
- Report and pay eco-fees to the eco-organization(s) based on the number and types of products sold regularly (e.g. quarterly, bi-yearly or yearly).
If you are not considered to be a producer of the applicable category of goods, and you do not have a UIN, you have to obtain the UIN from your supplier, the importer into France, and/or a locally registered producer from within your supply chain in France.
⚠️ PLEASE NOTE:
- If you sell to France the products that are falling within different categories mentioned above, you have to obtain UINs per each category, even if one eco-organization is responsible for these categories of products.
- Moreover, if you sell a product which parts are under different categories, you may need to obtain UINs per each category. For example, if you sell an Electrical and Electronic Equipment category product containing a battery, you may need to register and obtain a UIN for both Electrical and Electronic Equipment and Battery.
How to Register for EPR Purposes in France?
Below is the list of eco-organizations (PROs) where you have to register if you are considered as a producer. Click the organization name to go to its official website.
- Electrical and Electronic Equipment (EEE)
- Sport and leisure goods
- Do-it-yourself and gardening articles
- Ecomobilier (non thermic products)
- Ecologic (thermic products only)
- EcoDDS (chemical products)
- Toys - No approved PRO yet
How to Provide EPR Registration Number(s) to Joom?
Joom has updated the Merchant Panel for you to be able to add the relevant UIN number per category.
What if not Prove Compliance with the French EPR?
Joom is legally obliged to check if you comply with your EPR obligations in France and, if you do not, will impose an activity ban on sales to France.
In case you wish to continue selling your products in France, you are required to ensure your compliance with the French EPR law by completing the above listed obligations until 15 November 2022.
Where to Find More Information on the Mentioned Changes?
More information could be found through the following links:
- For general information about EPR in France: ecologie.gouv
- Link to the EPR Decree: legifrance.gouv
- ADEME (French authority in ecologic transition): ademe.fr
- FAQ by Syderep/ADEME: FAQ
Please sign in to leave a comment.