Introduction to EPR French Packing Law

"EPR compliance is the first step, product packaging first."

No matter what product you sell in Germany or France, every store must register the corresponding country's packaging law according to the company. There are various agent prices of EPR in the market, why some agent prices are particularly low, and some agent quotations are particularly high? How do we sellers identify and decide whether to pay for agency services with big price differences?

Like VAT compliance, EPR compliance is not just a registration process, but also includes declaration, product labeling and pasting, and payment of environmental protection fees.

A single packaging method, the market price gap is also very large, the following Xiaobian will introduce the complete EPR packaging law compliance services include what services and what matters need to pay attention to.

1、EPR Packaging Law compliance services mainly include:

Packing method registration fee: No official fee.

Ecological organization recovery fee: according to the ecological organization (recycling company) announced fees.

Agent service fee: that is, the agent's service fee. The agent provides registration information sorting, registration submission, printing sign guidance, declaration service, and communication service with recycling company.

2、The amount of French packaging recovery bill is determined:

In the first year, the recovery fee contracted with the recycling company is calculated based on the estimated annual sales volume of the merchant in the first year (new account in 2022) or the actual annual sales volume of the previous year (old account before 2021);

The recovery bill after the first year is the principle of more return and less compensation for the prepaid recovery invoice of the previous year after the declaration of the sales volume of the previous year (the minimum charge is 80 euros).

3、Date of collection invoice:

If the trader's recovery charge is less than or equal to EUR 10,000 (excluding VAT), the invoice will be issued on 30th June each year;

If the recovery fee is higher than €10,000 (excluding VAT), the invoice can be issued on June 30 of each year or every quarter.

In the first year of registration, traders with a recovery charge of less than 10,000 yuan (excluding VAT) can issue a recovery invoice at the time of signing; Traders with a recovery charge of more than 10,000 yuan (excluding VAT) can choose to issue a one-off invoice or at the end of each quarter.

4 、Callback payment deadline:

Payment shall be made within 30 days from the date of receipt of the invoice. Late payment of the invoice shall be subject to penalty. The penalty shall be calculated by 40 Euro + corresponding to the recovery fee * the penalty rate for the overdue time.

* After reading the above introduction, after the seller gets the packaging registration number (valid unique identifier), at the end of March to the end of April 2022, the agent needs to pay the recycling company a recovery fee based on the estimated sales volume in 2022. Most agents/sellers will pay the recovery fee based on 80 euros, and it is possible that most agents' one-year service will end here. But for EPR compliance services, this is just the beginning.

5、Renewal time:

The effective service period of EPR compliance is 1 natural year, which means that no matter when the contract with the recovery company comes into force in the current year, the service period of the year will end on December 31. This means that EPR registration will take effect in January.  

For example, the French packaging law in which the ecological organization (recycling company) requires written confirmation of renewal before October 31 of each year, 10-31 after the notification of the default renewal of the following year.

6 、Recovery cost:

The fixed minimum fee and recovery fee parameters may vary from year to year. The recovery company will publish the fees for the following year on its website 3 months in advance.

7、  Packing declaration:

Packaging declaration is the most important part of EPR compliance and an important factor in testing the professionalism and price differences of an EPR agent. The recycling declaration of the previous year should be completed before March 1 of the next year. If the recycling company thinks it is necessary, it will require additional materials to prove the authenticity of the declared data.

The recovery declaration must be made in strict accordance with the Reporting Assistance Manual of the recycling company. Any incomplete, incorrect and non-compliant declaration can be corrected and re-declared within 60 days. 

The recycling company provides three declaration methods (each method has increasing difficulty in calculation) :

The first, the minimum recovery of simple declaration. If the amount of recycling placed in the French market is small (below the threshold set by a recycling company, which will be updated annually by the recycling company, the amount of this product will be 10,000 in 2022), the trader may choose to declare a fixed recovery fee, which does not require the declaration of specific sales information, and the minimum fixed recovery fee is 80 euro (excluding VAT).

The second method is to declare according to the product sectoral declaration. This mode can be used when the quantity of goods released by traders to the French market is lower than the quantity declared by the sectoral declaration (the door of this sectoral sectoral declaration is also updated by the recycling company every year). In this declaration mode, you need to take into account the quantity to be released by the sectoral commodity. The quantity and specification of packaging materials are used to declare and calculate the recycling charge (please consult us for specific calculation method). 

Third, DECLARATION PER CSU (Consumer Selling Unit): This declaration method needs to declare the weight and material of recycled products released in each consumer unit, that is, it needs to consider the impact of ecological adjustment.