Selling products in France involves much more than VAT, customs formalities or arranging transport. Many foreign businesses are also required to comply with Extended Producer Responsibility (EPR) in France, one of the most comprehensive environmental compliance systems in Europe.
Whether you sell through your own website, Amazon, Cdiscount, ManoMano or any other marketplace, failing to comply with French EPR legislation can lead to product listing suspensions, marketplace restrictions and administrative penalties.
VAT & Green Tax assists international businesses with EPR compliance throughout Europe. We help companies identify their obligations, register with the appropriate Producer Responsibility Organisations (PROs), obtain their Unique Identification Number (UIN) and manage ongoing reporting requirements in France and across the EU.
What is Extended Producer Responsibility (EPR) in France?
Extended Producer Responsibility is an environmental policy requiring businesses placing certain products on the French market to finance or organise the collection, recycling and treatment of the waste generated by those products.
France has implemented one of the most extensive EPR systems in Europe through the French Environmental Code (Code de l’environnement).
Under French legislation, producers include manufacturers, importers, distributors and, in many situations, foreign companies selling products directly to French customers.
This means that you do not need to have a French company, warehouse or permanent establishment to become subject to French EPR obligations.
Many international businesses discover these requirements only after a marketplace requests proof of compliance or blocks product listings.
For this reason, EPR compliance should always be reviewed before entering the French market.
Which products are covered by French EPR?
France currently operates more than twenty Extended Producer Responsibility schemes.
However, the three categories affecting most international businesses are:
- Packaging.
- Electrical and Electronic Equipment (WEEE).
- Batteries.
In practice, a single product can fall within several EPR schemes simultaneously.
For example, if your company sells a wireless electronic device packaged in cardboard with a rechargeable battery, you may have obligations relating to packaging, WEEE and batteries.
This is one of the most common compliance issues encountered by foreign businesses entering France.
Rather than analysing only the main product, businesses must also assess packaging materials, accessories, integrated batteries and their sales channel.
Packaging EPR in France
Packaging is one of the most important French EPR schemes.
French legislation adopts a broad definition of packaging, covering any item designed to contain, protect, handle, transport or present goods, regardless of the material used.
This means that compliance does not only concern the retail box.
Secondary packaging, transport cartons, plastic films, labels, fillers, protective materials, bags and other packaging components may also fall within the French Packaging EPR system.
France distinguishes between household packaging and commercial or professional packaging.
This distinction is particularly important for businesses supplying distributors, wholesalers or professional customers.
Many companies incorrectly assume that selling exclusively B2B exempts them from French Packaging EPR requirements.
That assumption is often incorrect.
Depending on the products sold and their intended use, professional packaging may also trigger compliance obligations.
Typical obligations include:
- Registration with the appropriate Producer Responsibility Organisation (PRO).
- Payment of eco-contributions.
- Annual reporting.
- Obtaining a French Unique Identification Number (UIN).
- Compliance with French sorting information requirements.
WEEE Registration in France
Electrical and Electronic Equipment (EEE) is another major EPR category.
In France these products fall within the DEEE regime, while internationally the term WEEE is more commonly used.
The French rules cover equipment requiring electric currents or electromagnetic fields to operate.
Typical examples include:
- Household appliances.
- IT equipment.
- Computer accessories.
- Lighting products.
- Measuring devices.
- Smart devices.
- Electronic toys.
- Solar panels.
- Electric mobility equipment.
Distance selling deserves particular attention.
French legislation may treat a foreign online seller as the producer when electrical products are sold directly to French end users.
Consequently, businesses established outside France frequently become subject to French WEEE obligations without realising it.
Waiting until Amazon or another marketplace requests a French UIN is usually too late.
Compliance should be assessed before products are placed on the French market.
Battery EPR in France
Battery compliance has become increasingly important following the entry into force of Regulation (EU) 2023/1542.
French legislation now incorporates these European requirements into its national EPR framework.
Battery obligations do not only apply to businesses selling standalone batteries.
They also affect companies placing products containing integrated batteries onto the French market.
Typical examples include:
- Consumer electronics.
- Power tools.
- Electric bicycles.
- Smart devices.
- Medical equipment.
- Toys.
- Measuring equipment.
- Industrial machinery.
Businesses should determine whether batteries are:
- Portable batteries.
- Industrial batteries.
- Electric vehicle batteries.
- Light means of transport batteries.
- Starter batteries.
Each category may involve different reporting obligations.
It is therefore common for one product to generate compliance obligations under:
- Packaging.
- WEEE.
- Batteries.
This is one of the reasons why French EPR compliance is considerably more complex than many businesses initially expect.
What is the French UIN and why do marketplaces request it?
The Unique Identification Number (UIN), known in France as the Identifiant Unique, is the official number confirming that a producer is registered under the relevant French EPR scheme.
This number is far more than an administrative reference. It demonstrates to marketplaces, distributors and public authorities that the business has fulfilled its producer registration obligations in France.
Online marketplaces play an increasingly important role in enforcing EPR compliance. Platforms such as Amazon, Cdiscount and ManoMano frequently require sellers to provide their UIN before allowing products to remain listed.
As a result, many foreign businesses only discover French EPR obligations after receiving a compliance request or finding that their products have been suspended.
For this reason, businesses should assess their EPR obligations before launching products in France, rather than waiting until a marketplace requests evidence of compliance.
French EPR obligations for foreign businesses
The exact obligations depend on the product, the applicable EPR scheme, the sales channel and the role the business plays within the supply chain.
However, most businesses will need to complete the following steps.
First, determine whether the company qualifies as a producer under French legislation. This requires analysing who first places the product on the French market and who is responsible for supplying customers in France.
Second, identify every applicable EPR stream. A single product may simultaneously fall within Packaging, WEEE and Battery regulations. Other product categories such as textiles, furniture, sporting goods, toys and DIY products may also be covered by separate French EPR schemes.
Third, register with the relevant Producer Responsibility Organisation (PRO), unless an approved individual compliance scheme is available. In practice, joining a PRO is the most common solution for foreign businesses.
Fourth, obtain the appropriate Unique Identification Number (UIN) for every applicable EPR category. One registration does not automatically cover all product streams.
Fifth, submit periodic reports detailing products placed on the French market. These reports usually include quantities, weights, materials and product categories.
Sixth, pay the corresponding eco-contributions. These contributions finance waste collection, recycling, public awareness campaigns and the overall operation of the French EPR system.
Finally, businesses should review product labelling and consumer information requirements, particularly where products are sold directly to consumers.
What are the risks of non-compliance?
Failure to comply with French EPR legislation can create administrative, financial and commercial risks.
From an administrative perspective, French authorities may impose penalties for failing to register, submit reports, obtain a UIN or comply with information obligations.
Financially, businesses may be required to regularise previous reporting periods, pay outstanding eco-contributions and update product labelling.
Commercially, the consequences can be even more significant.
Marketplaces may suspend product listings.
Distributors may refuse to purchase products.
Customers may require evidence of EPR compliance before placing orders.
For businesses expanding into France, EPR compliance should therefore be considered an essential market access requirement rather than an administrative formality.
How VAT & Green Tax can help
At VAT & Green Tax, we assist international businesses with French Extended Producer Responsibility compliance from start to finish.
We analyse your products, distribution model, sales channels and target markets to determine whether Packaging, WEEE, Battery or other French EPR obligations apply.
We also assist with producer registrations, PRO memberships, obtaining French UINs, ongoing reporting obligations and communication with marketplaces requesting proof of compliance.
Our services are not limited to France. We can also handle EPR in all the EU countries.
If your business sells products in France or plans to expand into the French market, reviewing your EPR obligations before you begin trading can help avoid unnecessary costs, compliance issues and marketplace restrictions.
If you have any doubts, you can reach out by sending an email to hola@vatgreentax.com
Frequently Asked Questions
What is Extended Producer Responsibility (EPR) in France?
French EPR requires producers placing certain products on the French market to finance or organise the collection and recycling of the resulting waste.
Do foreign companies need French EPR registration?
Yes. Businesses established outside France may still be considered producers if they sell products directly into the French market.
Do I need a French company to register for EPR?
No. Foreign businesses can have French EPR obligations even without a French subsidiary or permanent establishment.
Which products are covered?
Common categories include packaging, electrical and electronic equipment (WEEE), batteries, textiles, furniture, toys, sporting goods and DIY products.
What is a French UIN?
The Unique Identification Number confirms that a producer has registered under the relevant French EPR scheme and is frequently requested by marketplaces.
Can one product require multiple EPR registrations?
Yes. A product with packaging, electronic components and an integrated battery may require compliance under three separate EPR schemes.
What happens if Amazon requests my French UIN?
You should ensure your French EPR registration has been completed and provide the relevant UIN for each applicable product category.
What are the penalties for non-compliance?
Businesses may face administrative penalties, retroactive eco-contributions, marketplace restrictions and commercial disruption.
Can VAT & Green Tax assist with French EPR compliance?
Yes. We support businesses with French EPR registrations, ongoing reporting, Packaging, WEEE, Batteries and multi-country EPR compliance across the European Union.
