Packaging 📦 - already due
You are obliged to register if you are distributing packaging that accumulates at the French end consumer.
For packaging you don’t need an authorized representative, you can register on your own.
💡 To be compliant with packaging in France you must follow these steps:
Participate in a recycling system in France
Either register with Léko or Citeo
- For french-customers registration on HP.
- For Non-french customers here is some helpful info regarding the registration form:
- Registration ID: Commercial register number, if you are sole proprietorship, enter your sales tax identification number (VAT ID) again
- EU-VAT-ID: VAT identification number (VAT-ID) of the company's registered office
- Registration office: Place of registration (e.g. Vienna Local Court); for sole proprietorship, please enter the place of the company's registered office
- Industry classification code: only mandatory for french companies
You will receive your UIN number around one week after your registration. The recycling scheme (eg Lèko or Citeo) takes care of the registration at ADEME and forwards you the respective number via E-Mail.
Regular quantity reporting & estimated costs 💸
As a member you have to report and pay your packaging quantities latest by the 28th February of the following year.
💡 If you sell under 10.000 units per year, you don’t need to report your exact quantities and pay a flat fee of around 80 € (excl. VAT).
If you sell >10.000 products in France, please follow this guide. (can be used for Citeo and Léko).
Labeling requirements - have to be implemented until Sep 2022
TRIMAN Logo
- Is mandatory if you sell in France, works as a universal recycling symbol in France (use in other countries is unproblematic)
- Must be placed on all household packaging with a sorting notice
- Detailed info can be found within the Leko description
-
Vector files for free use are available directly from Leko
!! You have to display the Unique Identification Number you will receive in your general terms and conditions or other contractual documents (with French customers) and on your website (e.g. in the imprint), among other things.
EEE 📱& Batteries🔋 - already due
Electrical equipment may generally only be sold in France after registration and issuance of the WEEE registration number.
The only exception: if you sell electrical equipment from other companies in France, that have already registered their products in France.
💡 To be compliant with EEE & batteries in France you must follow these steps:
Registration
If you have NO entity in France…
💡 If you have no entity in France, then you must appoint a foreign authorized representative who takes over the EPR obligations (registration at ADEME, obtaining EPR/UIN number, data declarations, etc.) on your behalf.
In general the authorized representative can be any french company. We recommend you to register at the recycling scheme ecosystem, who can also provide you with an Authorized Representative.
If you have an entity in France…
If you have an entity in France, you can register independently from an AR.
General Process:
- Register to ADEME the applicable EPR categories (EEE, batteries, etc) to generate an account and receive a SIREN number. The Siren number functions as the Login Number for Ademe.
- Join a PRO (=Producer Responsibility Organizaton)/eco-organisation (ecosystem or ecologic) by means of a membership contract in order to receive an UIN number.
- The PRO sends the new membership to Adème, which generates the UIN and communicates it within 48 hours.
- Add the UIN number to Syderep - ADEME.
Quantity reporting
Report once a year to ecosystem, they take care of all further duties: first submission when signing the contract, following by 31st Jan of the following year.
Ecyosystem Online Reporting Portal
Labeling requirements
Information & labeling obligations:
- Manufacturer/brand, serial number, "symbol of the crossed-out garbage can"
- If sticker is used must be compliant with DIN EN 50419
Info-Tri sorting notice:
- !! From 15th Dec 2022 onwards (transition period until 15th June 2023), electrical equipment or batteries must be marked with either the Triman logo or the crossed-out garbage can symbol in combination with a sorting notice.
- Placed either directly on product or product packaging or at least on user manual
- Products with no user manual + largest surface area of the product and the largest surface area of the packaging are less than 10 cm², the placement must be on the site instead.
- For an area between 10 cm² and 20 cm², the crossed-out garbage can without sorting notice is sufficient; however, here too, the affixing including sorting notice must be made on the website.
- The recycle schemes will provide you with detailed user guides and graphic templates.
Indication of the WEEE fee on invoices:
WEEE fees for every electrical product must be indicated separately on invoice for customers
Additional information:
You have to communicate your EPR/UIN registration number(s) in your terms and conditions or other contractual documents with French customers as well as on your website (eg imprint).
Further information on WEEE/batteries in France, can be found online our via contacting ecosystem/Corepile.
Information for consumers:
You have to inform the customers about their possibilities to drop off their old equipment for free at certain collection points.
Estimated costs 💸
Depending on types of equipment and sold quantity in France.
Authorized Representative fee: to be asked directly from authorized representative
Fees for WEEE
Minimum per quantity report: 50 €
Recycling fee according to quantity: WEEE price list
Fees for batteries
Minimum fees: 200 €
Recycling fee according to quantity: battery price list
💡 Special obligations for batteries:
You have to join a recycling system for batteries approved by the government, if you sell batteries/accumulators (loose or contained in equipment). A suitable system would be Corepile. After signing your contract you report once a year online to fulfill your obligations. (Price list is also on the website).