[This article has been updated]
Under the principle of Extended Producer Responsibility (EPR), manufacturers, importers and distributors in France are required to take responsibility for their products throughout the entire life cycle of those products and beyond. Every EU Member State must transpose the regulations and directives adopted by the EU into national law, and France’s high standards for EPR could guide other EU Member States in the future.
Read on to find out how France is handling EPR and the direction in which the country is moving!
EPR registration in France for quick readers
Far more product groups are covered by EPR in France than in other EU member states. In addition to batteries, packaging and electrical and electronic products covered by EPR across the EU, EPR in France also applies to toys, sport goods, textiles, furniture, and recreational craft, amongst other things.
Many aspects of the EPR requirements in France are also stricter than in other EU member states. For example, comprehensive eco-design plans must be drawn up, and failure to comply with France’s EPR requirements can result in severe penalties. Currently, this primarily affects textiles from ultra-fast fashion brands such as Shein and Temu. Strict regulations and financial penalties are planned to come into force at the start of 2026 and are currently being implemented.
How is France structuring its EPR?
The EPRs in France are an example of how a country’s legislation can go beyond EU requirements. France was the first EU country to introduce extended producer responsibility for textiles. Furthermore, compared with EU requirements, other EPRs in France are significantly stricter. The textile EPR organisation Refashion is responsible for this.
France is planning a comprehensive bonus-malus model under this scheme. Whilst sustainable manufacturers stand to benefit, fast-fashion labels and manufacturers will be required to pay when they place their products on the market. Advertising restrictions or bans are also planned.
Manufacturers, retailers, importers and exporters who offer their goods on the French market must in France therefore take into account more EPRs than in other EU Member States.
How are EU EPRs implemented in France?
The implementation of the three EU EPRs was mandatory in France, as in every other EU Member State, and has now been completed. These EPRs cover packaging, electrical and electronic equipment, and batteries. To comply with these requirements, an EPR number and registration in a central register are also required in France.
All manufacturers, sellers and importers who sell goods in France need an EPR registration number to ensure compliance and protect themselves legally.
If several different product groups are placed on the market, multiple registration numbers are required. In addition to registering with a take-back scheme, all manufacturers subject to these obligations are entered in the national register of ADEME (SYDEREP).
This includes, amongst other things, the following steps:
- Registration in the categories corresponding to the products
- Joining a Producer Responsibility Organisation (PRO) or setting up an individual, in-house system that fulfils the PRO’s obligations
- Providing the French EPR registration number wherever it is required (for example, on sales platforms and in annual reports submitted to ADEME)
This creates a comprehensive and structured system that enables clear documentation!
Online marketplaces and digital commerce
If products are sold via online platforms such as Amazon and eBay, the registration number must be provided. Due to the increased duty of online marketplaces to monitor compliance, the ID must be included in the terms and conditions or – if no terms and conditions are available – in another sales document. Otherwise, the platforms can and must exclude sellers or individual unregistered product groups from trading.
What must be reported under the EPR in France?
Under the EPR number for France, companies report the total quantities and weights of goods placed on the French market. Furthermore, EPRs in France require companies to specify the recycled content of their products. For items that stand out here due to poor repairability, short lifespan and environmentally harmful design – such as fast-fashion textiles – significant surcharges are planned for the future.
Annual collection and processing reports must be submitted to all relevant authorities, quoting the EPR number for France. For each reporting period, an environmental levy is also payable to ensure compliance with the EPR requirements in France; this is calculated by the authorities and is higher for negligent manufacturers.
Furthermore, EPR requirements in France include the preparation of eco-design plans for packaging and the obligation to take back certain products for recycling.
What EPR obligations can companies expect in France?
As already mentioned, companies generally join a waste management association so that they do not have to handle the disposal of their products themselves. These associations are known as ‘éco-organismes’. Companies pay contributions to these associations for the disposal of waste. The amount of the contributions is based on the volume of waste.
Membership of these waste management organisations entails further obligations in addition to the payment of contributions. For instance, companies were required to submit a Prevention and Eco-Design Plan (PPE) as early as 2023, which must include an action plan covering the following aspects:
- Reducing single-use packaging, increasing the use of reusable packaging and extending the lifespan of packaging
- Increased use of recycled raw materials in packaging
- Optimisation of packaging with regard to its recyclability
The requirements for the PPE and the heavy penalties for non-compliance or failure to submit the plan are an example of how strictly EPRs are sometimes interpreted in France and how far ahead France is in the field of environmental protection compared to the EU and other Member States.
The take-back obligation for certain types of products
As in other EU countries, under France’s EPRs, companies are obliged to take back certain products. These product groups include, for example, batteries and electrical and electronic equipment. Through this take-back obligation, France is implementing, amongst other things, the EU’s WEEE Directive and the EU Battery Regulation under its EPR scheme.
A further requirement in this context is that the recyclability of the products must be clearly labelled for consumers. Labelling of the aforementioned product groups is also mandatory in other EU Member States. However, France is unique in that it has created its own entirely distinct label – the Triman logo – for this purpose. Since 2022, it has even been mandatory to affix this label to all products falling under extended producer responsibility in France.
Specific features of EPRs in France compared to EPRs in other EU Member States
Failure to meet deadlines for the submission of annual reports, action plans and other requested documents is subject to particularly severe penalties for EPRs in France. The competent authorities therefore take a strict approach when monitoring EPRs in France, which is why companies should adapt to legislative changes at an early stage and take the necessary measures to comply with the law as soon as possible.
Furthermore, France is the EU country where by far the most product groups fall within the scope of extended producer responsibility. This applies, for example, to the following:
- EPR for textiles is already in force in France. Since 1 July 2023, EPR for textiles has also been in force in the Netherlands.
- To tackle the problem of a high number of unused and unrecycled yachts and pleasure craft, a mandatory recycling scheme for yachts and boats has also been introduced in France.
- Furthermore, EPR applies to the toys sector in France. Unlike in Germany, it is not a requirement for the toy to contain a battery. Even without an integrated battery, it falls under the EPR in France.
In addition, France has enacted EPR schemes for sports goods, as well as furniture and other household furnishings.
The special case of textiles: What changes are in store for EPR on textiles in France?
France is regarded as a pioneer in EPR for textiles and has been significantly tightening its approach since the start of 2026.
In January, the French Ministry for Ecological Transition commissioned the organisation Refashion to develop a plan for the introduction of penalty surcharges – specifically targeting fast-fashion labels.
This affects all brands, importers and online platforms that place clothing, home textiles or footwear on the French market – foremost among them Shein and Temu. The key instrument here is Refashion’s existing ecomodulation system, which is now to be used specifically as a sanctioning mechanism.
The following measures are being considered:
- Penalties for less sustainable products: Products with a low sustainability score will be subject to higher EPR fees – with a minimum charge of 5 euros per item, rising to up to 10 euros by 2030.
- Bonuses for sustainable design: Durable, repairable and recyclable products can benefit from reduced fees.
- Advertising ban: The law, due to be passed in June 2025, provides for a ban on advertising fast-fashion products that encourage excessive consumption.
Companies selling textiles in France should review their product strategies and eco-design measures in the short term, as the signs point to the EU following France’s lead in the area of EPR in the future.
Understanding and managing EPR in France
As can already be seen from the number of product groups covered by EPR in France, the requirements for companies placing their products on the French market are very high. Given these high requirements, it makes sense to seek guidance from experts in EPR in France.
We at Deutsche Recycling GmbH are happy to offer our services in this regard. From compliance checks to implementing measures to ensure compliance with EPR in France, we provide bespoke services and, in this way, help companies to focus fully on their core business and avoid costly penalties.
FAQ: EPR in France
What is EPR in France and who does it affect?
EPR in France (Extended Producer Responsibility) obliges manufacturers, importers and distributors to take responsibility for their goods throughout the entire product life cycle – even after they have been used. This applies to all companies placing products on the French market, regardless of whether they are based in France or abroad. France goes significantly beyond the EU’s minimum requirements and is considered the strictest EPR jurisdiction within the EU.
Which product groups are covered by EPR in France?
EPR in France covers far more product groups than the EU-wide minimum requirements. In addition to the categories mandatory across the EU – packaging, electrical and electronic equipment, and batteries – EPR obligations in France also apply to textiles, toys, sports goods, furniture and even yachts and pleasure craft. Companies that market several product groups require multiple EPR registration numbers for France accordingly.
How does EPR registration work in France?
EPR registration in France takes place in several steps: First, companies must identify the EPR categories relevant to their products and then join a recognised producer responsibility organisation (éco-organisme) or set up their own take-back system. Following registration, all manufacturers subject to the scheme are entered in ADEME’s national register (SYDEREP) and receive their EPR registration number for France. This number must be provided wherever it is required – for example, on online sales platforms or in annual reports.
What are the distinctive features of extended producer responsibility in France compared to other EU countries?
Extended producer responsibility in France is characterised by particularly stringent requirements and a large number of product categories covered. For example, companies must submit comprehensive eco-design plans (Prevention and Eco-Design Plans) and face heavy penalties for missing deadlines. Furthermore, France has introduced its own national labelling system, the Triman logo, which has been mandatory for all products subject to EPR since 2022.
Why is France’s EPR system regarded as a model for other EU countries?
France was the first EU country to introduce EPR for textiles and goes far beyond the EU’s minimum requirements in many areas. The comprehensive bonus-malus system, the large number of regulated product groups and consistent enforcement make the French EPR model a benchmark for European environmental policy. Experts and political observers expect the EU to increasingly look to France as a model when further developing its EPR regulations.
