EPR for commercial packaging (the French REP emballages professionnels scheme), or extended producer responsibility applied to packaging for professional use, requires companies that place such packaging on the French market to finance and organise its collection and recycling. In practice, this means joining a packaging producer responsibility organisation, submitting a packaging EPR declaration and paying a packaging eco-contribution. But behind these three steps lies the real challenge: data. To declare correctly, you need to know the tonnages, materials, recycled content rates and type of packaging placed on the market - information that largely sits with your suppliers.
By Gautier VeyssetIndustry specialist writer at Tracklab · LinkedInUpdated 13 Oct 202613 min read5 sources citedThis guide is for Quality, Purchasing, Regulatory and Supply Chain teams in manufacturing and the food industry. After covering the regulatory framework, it focuses on what few resources address in depth: how to gather, structure and make declaration data reliable.
Extended producer responsibility (EPR) is a mechanism that transfers to the company placing a product on the market the responsibility - technical and financial - for its collection and treatment at end of life.
Applied to packaging, it means a company cannot simply sell a packaged product: it contributes to managing the waste that the packaging generates. It does not collect or sort the waste itself, but finances the scheme through an eco-contribution paid to an approved producer responsibility organisation.
Packaging EPR is organised at national level by the Environmental Code and reinforced by the AGEC law. Historically, the household packaging scheme shaped the system in France. EPR for commercial packaging (industrial and commercial packaging) extends this scope to packaging used or consumed by businesses. Various packaging producer responsibility organisations are approved to run these schemes.
The PPWR Regulation (Regulation (EU) 2025/40) harmonises packaging design requirements at European level: recyclability, recycled content, reduction at source, labelling. It also sets EPR within a common framework, but EPR remains a national system: each Member State keeps its own schemes and producer responsibility organisations. In other words, the PPWR sets what the packaging must be; French EPR organises who pays and how declarations are made.
“Producers shall have extended producer responsibility under the schemes established in accordance with Articles 8 and 8a of Directive 2008/98/EC and with this Section for the packaging, including packaging of packaged products, that they make available for the first time on the territory of a Member State […].”Regulation (EU) 2025/40, Article 45, paragraph 1 · EUR-Lex, official text
EPR and the PPWR do not replace each other: the PPWR harmonises design, EPR finances end of life at national level. The same packaging can therefore fall under both approaches at the same time.
The question is not “who manufactures the packaging?” but who places the packaging or the packaged product on the market. This is the notion of “producer” within the meaning of EPR.
In practice, responsibility moves up the supply chain: the company placing products on the market must be able to substantiate the data, including data from suppliers located abroad.
Commercial packaging is packaging used or consumed by a business (manufacturer, retailer, restaurant operator) rather than by a household. Household packaging is packaging distributed to the end consumer through retail. The distinction is decisive: it determines which scheme to declare under and which producer responsibility organisation to contact. The same product can generate both types of packaging - hence the value of classifying each flow before declaring.
Transport packaging (pallets, films, cases) and grouped packaging fall under EPR for commercial packaging when intended for professional use. Note the nuance: the company that manufactures and sells this empty packaging to businesses may be the producer; for a company that uses it to ship its own products, the obligation falls on the company placing the packaged products on the market. Have your specific case confirmed by the relevant producer responsibility organisation.
The classification as “commercial packaging” and the role (company placing products on the market, importer, distributor, packaging manufacturer) determine both the obligation and the declared scope. Clarifying this upfront avoids declaring the wrong flow.
The company must join an approved packaging producer responsibility organisation or, failing that, set up an individual system. Membership comes with a unique identification number (IDU), to be shown on the documents required by the regulations.
The packaging EPR declaration covers the packaging placed on the market: type, material, number of units, weight, use. It is periodic and requires rigorous tracking of quantities over the declared period.
The packaging eco-contribution is the amount due according to the applicable fee schedule and the packaging declared. It finances collection and treatment.
Reusable packaging is subject to specific tracking rules: reuse must be declared and documented separately, particularly for industrial and commercial packaging.
The four obligations are linked: without reliable data on tonnages, materials and reuse, it is impossible to produce an accurate declaration or to pay the expected eco-contribution.
The 4 EPR obligations, in order
Each step depends on the previous one: without reliable packaging data, both the declaration and the bill are wrong.
The eco-contribution is calculated using a fee schedule by material (plastic, cardboard/paper, glass, metal, etc.), applied to the declared weight or number of units. There is no single rate: the amount depends on the material, the format and the year of the fee schedule. The applicable fee schedule varies by scheme and producer responsibility organisation - to be checked for your material and your producer responsibility organisation.
The fee schedule includes modulations:
For a company declaring large volumes, modulation changes the total. Two packaging items of the same weight can generate different contributions depending on their eco-design. This is why composition and recycled content rate data are not technical details: they directly influence the amount paid. This reasoning extends that of supplier data in the packaging sector.
The eco-contribution is not a simple line on an invoice calculated on gross tonnage. Recyclability and recycled content modulate it: the better you document this data, the better you control the amount.
This is the operational core of the subject. A reliable declaration relies on data that is accurate, dated and traceable, only part of which is internal.
| Required data | Internal source | Supplier source | Update frequency |
|---|---|---|---|
| Tonnage placed on the market (by material) | Purchasing / Supply Chain / ERP | Supplement if it cannot be calculated internally | For each declaration period |
| Main material and composition | R&D / Quality | Technical data sheet, supplier declaration | For each new item or specification change |
| Number of units and unit weight | Purchasing / logistics | Technical data sheet | For each format change |
| Rate of incorporated recycled material | Purchasing / R&D | Material certificate, attestation | Annual |
| Recyclability / sorting disruptors | R&D / Quality | Technical data sheet, eco-design attestation | For each material change |
| Reuse status (reusable packaging) | Supply Chain | Supplier declaration | Annual |
| Packaging function (sales, grouped, transport) | Purchasing / Supply Chain | Packaging specification | For each new flow |
| Unique identification number (IDU) and membership data | Regulatory | Not applicable | At each renewal |
The finding is simple: half of this data comes from outside. Without a structured collection channel, the declaration becomes a manual reconstruction, with a high risk of error.
Most errors do not stem from a lack of knowledge of the fee schedule, but from data that is not centralised, not dated or not linked to the right packaging.
Many manufacturers confuse the two workstreams. They overlap without replacing each other:
| Point | EPR for commercial packaging | PPWR |
|---|---|---|
| Nature | National system financing end of life | European regulation on design and information |
| What it requires | Membership, declaration, eco-contribution | Recyclability, recycled content, labelling, substances |
| What it changes | Who declares and how much is paid | What the packaging must be |
| Key data | Tonnages, materials, reuse | Composition, recycled content rate, substances |
What overlaps: packaging data. Composition and recycled content rate are used both for modulating the eco-contribution and for the PPWR declaration of conformity. What remains separate: the PPWR does not replace the national scheme, and EPR does not exempt you from any design requirement. Increasingly, a single data collection feeds both.
The bottleneck is almost never the calculation: it is the collection. Three levers help you move beyond makeshift solutions.
A supplier portal provides a single channel to request, collect and update data and evidence (technical data sheets, attestations, material certificates). It replaces endless email chains and creates a record of who declared what, and when.
Linking each packaging item to its supplier, finished product, documents and deadlines makes it possible to find the composition, recycled content rate and associated evidence in a few minutes. It is this master data that feeds the declaration - not a file rebuilt by hand.
Packaging data is only valid with its date and version. Tracking expiry dates and sending reminders before data becomes obsolete avoids declarations based on outdated information.
A spreadsheet does not natively handle document versions, deadlines, the link between packaging, supplier and product, or the extraction of data buried in heterogeneous PDFs. Excel can kick off a data collection; it cannot carry the compliance of a packaging portfolio over several declaration cycles.
Tracklab follows this approach: centralising supplier and product data, automating document collection, tracking deadlines and using AI to process documents. It is neither an ERP nor a production or inventory management tool. To lay the foundations, regulatory supplier document management is the base to put in place.
EPR compliance is first and foremost a document traceability problem. The collection channel and the master data matter more than the fee schedule.
EPR for commercial packaging is not just a membership fee: it is a data exercise. Three decisions shape compliance:
The next concrete step: check whether, for a given packaging item, you can find its material, weight, recycled content rate and supplier evidence in a few minutes. If the answer is no, that is the first workstream to open - before the declaration forces you to. The same data foundation will support your PPWR compliance and, for wood and paper packaging, your EUDR approach for the supply chain.
EPR for commercial packaging arrives on 1 January 2027, alongside the PPWR obligations. Our two free tools help you frame the timeline and gather supplier data.
All the deadlines of Regulation (EU) 2025/40 on a single timeline, and the checklist of actions to start now, article by article.
The step-by-step method to obtain PPWR evidence from your suppliers (PFAS, substances, recyclability, recycled content), with the questionnaire and evidence matrix ready to send.
Enter your details to access the download immediately.
The files open in Google Drive. For the spreadsheet, Google offers to make a copy in your own Drive.
Yes. As soon as a packaged product is placed on the French market, the obligation applies, regardless of where the packaging comes from. The importer bears a responsibility equivalent to that of the company placing products on the market, which means collecting data from suppliers outside France.
Not declaring does not remove the obligation. The Environmental Code provides for administrative penalties (fines, periodic penalty payments) as well as back-payment of the contributions due, particularly in the event of failure to register or incorrect information. The amounts depend on the facts and the procedure: to be checked against the texts and with ADEME for your situation.
For packaging, there is no general rule requiring it to be shown separately: its cost can be included in the selling price or presented separately, provided invoicing rules and your contractual commitments are respected. One thing is certain: re-invoicing does not exempt you from your obligation to declare and pay the producer responsibility organisation, and the amount must not be presented as a tax.
The household scheme covers packaging distributed to the end consumer; the commercial scheme covers packaging used or consumed by businesses. The scope, the producer responsibility organisation and the declaration procedures may differ: hence the importance of classifying each flow before declaring.
No. The packaging EPR tax is a common misnomer: it is an eco-contribution, paid to a producer responsibility organisation to finance collection and recycling. It is neither a tax nor an earmarked levy.
The timeline depends on your scope. Food service packaging falls under a scheme that has applied since March 2024; the extension to commercial packaging is announced for 1 January 2027 according to ADEME, with membership to be anticipated. These dates should be checked for your scheme and your producer responsibility organisation.
The official texts and tools this guide is based on.
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