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Companies that manufacture certain products are subject to extended producer responsibility (EPR) for the management of waste from these products. Let's take a look at the principle of EPR and the obligations incumbent on manufacturers.
The principle of extended producer responsibility
The principle of EPR is based on the polluter pays principle. Under this principle, anyone responsible for placing a product covered by an EPR scheme on the market is responsible for its environmental impact throughout its life cycle.
The distributor of this product must therefore participate in the prevention and management of waste from this product: this is known as extended producer responsibility (EPR).
The products covered are grouped into sectors comprising products from the same family. The household packaging sector was the first EPR sector created in 1993. There are currently 19 sectors in France, but the law of February 10, 2020, on waste reduction and the circular economy, known as the AGEC law, provides for the creation of new sectors.
The person responsible for placing the product on the market
The Environmental Code defines a "marketer" or "producer" as any natural or legal person who manufactures or has manufactured a product that they make available on the national market under their own name or brand, or who imports or introduces a product intended for use in the territory onto the national market for the first time.
The manufacturer, importer, or distributor of a product covered by an EPR scheme is therefore considered to be the producer placing the product on the market. It is this producer placing the product on the market who is subject to the obligations arising from EPR.
Obligations arising from extended producer responsibility
Producers subject to EPR must participate in the collection and management of waste from the products they manufacture. To do so, they must:
- sets up an approved individual system (the producer manages the collection and recovery of waste from the products it places on the market); or
- is a member of an approved eco-organization.
The eco-organization then takes charge of managing the waste generated by the products in exchange for a financial contribution from the producer. The amount of the contribution varies according to the bonuses and penalties awarded based on the efforts made in the eco-design of the product.
The eco-organization provides members with a unique identification number (IDU) that is mandatory to prove compliance with these obligations.
Note: It is the responsibility of the company (not the establishment) to join an eco-organization, so the IDU is issued to the company.
The producer must then report annually to the eco-organization to which it belongs, providing data relating to the design and marketing of the products it manufactures.
Further information
The AGEC law and European Regulation (EU) 2025/40 of December 19, 2024, on packaging and packaging waste, known as the "PPWR" regulation, provide for the creation of an EPR system dedicated to professional packaging. Thus, any person who manufactures, imports, or distributes and who makes available for the first time on European territory packaging or a packaged product that is not considered household packaging is subject to this new system and must comply with EPR obligations.
The terms and conditions for establishing this sector were recently defined in the Environmental Code. According to an announcement by the Ministry for Ecological Transition, the creation of the sector in France, initially planned for January 2026, has been postponed to July1, 2026.
Other sectors, such as chewing gum and technical aids, are to be created in the near future.