French EPR & Eco-Contribution Expertise

  • Household packaging and graphic paper (EMPAP)
  • Commercial and industrial packaging (separate EPR scheme since 1 January 2026 — Decree No. 2025-1081 of 17 November 2025)
  • Lubricating and industrial oils (LUB)
  • Chemical product contents and containers (PCHIM)
  • …and many other schemes, including batteries, light bulbs, furniture (EA) and building materials

Eco-contribution stems from the concept of Extended Producer Responsibility (EPR), which makes producers financially and operationally responsible for the waste generated by their products. In France, this principle was first introduced by Law No. 75-633 of 15 July 1975 on waste disposal and material recovery. Since then, several pieces of legislation have reinforced this framework, notably EU Directive 2008/98/EC, which sets out the EU’s general framework for waste management.

Since 12 August 2026, Regulation (EU) 2025/40 on packaging and packaging waste (the “PPWR”) has applied directly across all EU Member States. It specifically governs the packaging sector — with no national transposition required in France — and strengthens recyclability, eco-design and EPR-fee modulation requirements based on the environmental performance of packaging.

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Understanding Eco-Contributions

In a world where environmental protection has become a priority, eco-contributions — also known as EPR fees or producer responsibility fees — play a major role. These financial mechanisms encourage economic operators to adopt more environmentally responsible practices.

An eco-contribution is a financial contribution paid by producers, or by whoever places a product on the market, based on that product’s environmental impact. This fee is generally passed on in the product’s sale price, making the environmental cost of the purchase visible to the end consumer.

  • Producers

The term “producer” refers to the first party placing a product on the French market — that is, whoever manufactures, imports or distributes a product in France for the first time. Producers are therefore required to fund the management of waste generated by their products, by paying an eco-contribution proportionate to their environmental impact. They must also inform consumers of the existence and amount of this contribution. To meet these requirements, some companies join collective schemes, while others build their own in-house solutions.

Since 10 July 2026 (Law No. 2026-602 of 8 July 2026), any producer not established in France must also appoint an EPR representative (Article L. 541-10-9-1 of the French Environmental Code) for every EPR scheme it is subject to — a similar representation requirement exists, to varying degrees, in several other EU Member States, including Spain, Italy, Portugal and Germany. You can appoint FISCALEAD for that purpose! 

  • Consumers

Consumers play a key role in the success of eco-contribution schemes, as they are both the ones funding them and the ones benefiting from the actions they finance. Purchasing behaviour is directly shaped by this contribution, which encourages consumers to favour more environmentally friendly products.

  • Environmental Benefits

Eco-contributions encourage companies to reduce the environmental footprint of their products through eco-design. This results in less waste being generated and better material recovery. Eco-contribution schemes also support the development of a circular economy, in which waste becomes a resource for producing new goods.

  • Economic Impact

Eco-contribution represents an additional cost for businesses, which must factor this charge into their economic model. That said, this constraint can also drive innovation and improve competitiveness, prompting companies to rethink their production processes and optimise their supply chains.

  • Core EPR / Eco-Contribution Obligations

    • Registering with the relevant scheme and obtaining a unique identification number;
    • Displaying that unique identification number in your general terms of sale and on your e-commerce website;
    • Preparing and submitting a prevention and eco-design plan (“PPE”): an obligation set at scheme level, reviewed every five years and including an assessment of the previous plan, where applicable;
    • Depending on the scheme, take-back obligations for used products;
    • Of course, the various reports due to each Producer Responsibility Organisation (PRO), by the agreed deadlines and in the agreed data format.

  • Penalties

A producer failing to comply with these regulatory obligations is exposed to both financial and reputational sanctions.

The PPWR (Article 68) further requires each EU Member State to put in place an effective, proportionate and dissuasive penalty regime applicable to economic operators; in France, this aspect is still being transposed into national law (work under way at the DGPR, ADEME and DGCCRF) and is expected to strengthen the existing administrative sanctions regime under the French Environmental Code.

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Key Challenges of EPR Compliance and Eco-Contribution Payments

  • Producer Responsibility Organisations (PROs) and EPR Schemes

To meet their obligations, producers can either join a not-for-profit collective scheme — a Producer Responsibility Organisation (PRO), commonly referred to in France as an éco-organisme — or set up their own individual compliance system (a far less common option). PROs (or individual systems) must apply for approval against the scheme-specific specifications set by the public authorities. These specifications include targets for eco-design, collection and recycling and, where relevant, reuse and repair. Approval is then granted by the public authorities for a period of six years.

  • Identifying Your Liability (By Scheme)

Many companies are unaware that they are subject to these obligations, wrongly assuming that, because they carry out no manufacturing activity in France, they fall outside its scope. However, in the context of eco-contributions, the term “producer” refers to the first party placing a product on the French market — the manufacturer, importer or distributor putting it on the national market for the first time. Resellers operating solely within the French market are not affected, but many wholesale and e-commerce operators may well be. This “producer” status is now also assessed, scheme by scheme, against the EPR registration requirements introduced by the PPWR in every EU Member State where the product is placed on the market — not only in France.

  • Managing Multiple Schemes — and Multiple Data Formats — Within an ERP

One might assume there is a single PRO per scheme; in practice, that is rarely the case.

The challenge for companies that qualify as “producers” is managing, depending on their sector, one or several PROs across one or several schemes. Each PRO may set its own requirements regarding the data to be submitted and the level of detail and granularity required.

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How FISCALEAD Supports You With Eco-Contribution and EPR Compliance

FISCALEAD is on hand to, in particular:

  • Help you anticipate and organise the collection of the information and documents required to carry out an audit of your eco-contribution function;
  • Carry out an independent audit of your eco-contribution management — from your IT/ERP set-up (is your ERP correctly configured for it?) to your operational function (governance, cross-team efficiency, etc.);
  • Act as your EPR representative, preparing, compiling, checking and then submitting your filings to the relevant PROs: FISCALEAD acts as an EPR representative — directly or through its partner network — in several EU Member States, including France, Spain, Italy, Portugal and Germany, allowing you to centralise your EPR compliance and eco-contribution filings across these five markets with a single point of contact.
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Fondé par Marcie REYNO-DALLE et Alexandra LOUYOT, FISCALEAD est un cabinet d’assistance opérationnelle en fiscalité indirecte : Douane, Accises et TVA. Forte de nombreuses années d’expérience en cabinets de type big 4 comme en entreprises, notre équipe est aguerrie à de nombreux business models, industries et supply chains à l’international.

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Que vous fassiez appel à nos services déclaratifs ou de conseil opérationnel, notre obsession est que la fiscalité indirecte ne soit plus un frein à votre activité, mais vous ouvre de nouvelles opportunités.

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