Waste: Procedures for implementing the EPR system for professional packaging

Following the extended producer responsibility (EPR) scheme applicable to household packaging, in place since 1992, French regulations, under the impetus of the European Union, have defined the terms and conditions of the new EPR scheme for professional packaging.

18 million tons of professional packaging circulate on the French market each year, including 8 million tons of single-use packaging. With the aim of reducing pollution and saving resources, each waste stream will have to meet reusability or recycling targets by 2030. To meet these circularity targets, and in line with European Regulation 2025/40 of December 19, 2024, on packaging and packaging waste, Decree No. 2025-1081 of November 17, 2025 amendsArticles R. 543-42 to R. 543-74 of the Environmental Code to define the scope of extended producer responsibility (EPR) for professional packaging.

What's changing for professional packaging holders:

In addition to the three options already available:

• carry out their own valuation,
• transfer them by contract to the operator of a recovery facility,
• transfer them by contract to an intermediary engaged in the collection, road transport, trading, or brokering of waste, with a view to their recovery,

Holders of professional packaging can now return it to an approved eco-organization or a waste management operator that has a contract with an approved eco-organization for the management of professional packaging waste.

Note: This packaging waste may be mixed with other business waste, but only if this does not affect its suitability for preparation for reuse, recycling, or other recovery operations in accordance with the waste treatment hierarchy.

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What's changing for professional packaging manufacturers:

Professional packaging manufacturers must now manage their packaging waste.

Note. For grouped (= secondary) and sales (= primary) packaging, theproducer is the first party to place the packaged product on the market: the party that packages the product, or has the product packaged under its brand name, or imports a packaged product. For transport packaging (= tertiary), the producer is the first party to place the packaging on the market.

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Note: A packaging manufacturer is any natural or legal person who manufactures packaging or a packaged product. When a natural or legal person has packaging or a packaged product designed d, or manufactured under their own name or brand, regardless of whether another brand is visible on the packaging or packaged product, that person is considered the manufacturer. (Definition taken from the PPWR regulation).

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Producers can meet this obligation by:

• either by joining (at company level) an eco-organization that is approved for the professional packaging sector before the packaging is first made available on the market as of July 1, 2026;
• either by submitting an application for approval that meets the requirements of the specifications for individual systems, no later than February 28, 2026, for approval on July 1, 2026, or three months before the packaging is first placed on the market if this occurs after July 1, 2026.

Packaging for mineral and synthetic oils, lubricants, and industrial oils, which is governed by the "Lubricating and industrial oils" EPR sector, is now excluded from the EPR for household and professional packaging.

The following are now excluded from the extended producer responsibility (EPR) for professional packaging:

1. packaging for chemical products that may pose a significant risk to health and the environment, governed by the "Chemical Products" EPR sector;
2. packaging for construction products or materials in the building sector, governed by the EPR sector "Construction products and materials in the building sector."

Note: For packaging in the agricultural supply sector, A.D.I.VALOR fulfills its EPR obligations in accordance with an agreement concluded with the Minister of the Environment before December 31, 2019, and for as long as this agreement is renewed.

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Which packaging is affected:

The decree of December 2, 2025, relating to product packaging used by households and/or professionals, defines the characteristics of professional packaging, i.e., packaging used to market products consumed or used specifically by professionals, as well as household packaging, i.e., packaging for products consumed or used by households.

The following packaging automatically falls into the categories of professional packaging or household packaging:

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Terms and conditions:

The initial effective date was set for January 1, 2026, but was then postponed to July¹, 2026.

However, contracts between approved eco-organizations and producers who have transferred their EPR obligations to them for packaging used to market products consumed or used by households, including those likely to be consumed or used outside the home, printed paper, with the exception of books, issued, including free of charge, by or on behalf of principals, and paper for graphic use, intended for end users who produce household and similar waste, in force on January 1, 2026, shall continue to have effect until their expiry.

Furthermore, the procedures for approved eco-organizations to take charge of managing catering packaging waste remain governed by the provisions of the Environmental Code applicable to them, in the version in force before November 18, 2025, until they are approved under the EPR scheme for professional packaging and, at the latest, until the expiry of their approval.

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