Starting in 2022, if you sell in France and generate any waste, you will be obliged to confirm that you are Extended Producer Responsibility (EPR) compliant in France. This will require a registration with the relevant authority and/or compliance scheme, since they will be the party that can prove that you are compliant in France. This prove will be delivered in the form of a unique identifier.
This unique identifier will be generated for each and every waste stream you put on the market. For example, a producer selling an electronic device (EEE) with a built-in battery, will need 3 unique identifiers: 1 for WEEE, 1 for Batteries and 1 for Packaging.
Where to put it?
The unique identifier must be included in the Terms and Conditions of a producer and any other relevant contract and preferably on the website as well. The absence of any identifier in those documents may lead to a penalty which can be a maximum of 30.000 EUR. Gladly, the identifier will be active till a producer ends the contract, so the request for identifiers and the adjustment of documents and the website is an undertaking you will only have to do once.
Ademe, the current authority for WEEE and batteries, has not yet shared more detail on the obligation explained above. The reasoning behind this decision is quite clear; France is working towards having a circular economy, just as the Green Deal will enforce that in the entirety of the EU. As soon as more is announced we will provide an update on this. If you are a producer and need guidance on this topic, just reach out to us!
Pincvision for your Extended Producer Responsibility (EPR) obligations
Contact us in case you have any questions regarding Environmental compliance obligations. With our newsletter we will keep you informed about the developments regarding environmental obligations and enforcement, and other trade compliance related topics.
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Source: Ellen MacArthur Foundation
Joris te Pas
Environmental Compliance Specialist
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