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Extended Producer Responsibility (EPR) in France

What is Extended Producer Responsibility (EPR)?

Extended Producer Responsibility (EPR) is an environmental policy that holds the producer of a product responsible for the product’s entire life cycle, from start to finish (including waste collection and treatment) to encourage mitigation of the environmental impacts of their products.

What is required under EPR for selling to France?

As of January 2022, under the Anti-Wastage & Circular Economy Law, sellers offering listings to France (either domestically or internationally) must comply with French EPR regulations, which apply to certain categories of products. These categories include packaging, electronic equipment, and batteries. The full list of relevant products can be found here

Registration of an EPR Unique Identification Number 

The regulatory requirements include registering for an EPR unique identification number for the appropriate musical instrument category, or another category you find most relevant to your sale item, through the French Environment and Energy Management Agency (ADEME). The registration takes place on the SYDEREP platform (v1 or v2 depending on product categories). When registering, sellers will be required to adhere to a relevant Producer Responsibility Organization (PRO) or to set up an equivalent individual system.

Once a seller obtains their EPR unique identification number, they must provide it to Reverb in their shop settings (Shop Settings > Tax Policies) and display it to buyers in their Shop Description. Reverb collects EPR numbers from applicable sellers and will also compile a list of volume sales of each seller subject to the EPR rules by product category.

Accepting Recycling of Certain Products

For certain categories of products, such as electrical and electronic equipment (EEE) and certain chemical products, sellers must also provide buyers with a way to return used products for recycling. The terms of these returns for recycling must be displayed by the seller to the buyer in a visible and easily accessible manner prior to a sale. 

To better understand if these important requirements relate to their shop and items and how to comply, sellers may consider speaking to a legal expert.

Disclaimer: This information provides an overview for educational purposes only and is not legal advice. It is not intended to create, and receipt of it does not constitute, a lawyer-client relationship. The authors, LLC, disclaims all responsibility for any and all losses, damages, or causes of action that may arise or be connected with the use of or reliance on these materials. Please consult a licensed lawyer in your area for legal assistance.

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