Extended Producer Responsibility in France – Q&A with Léko

Extended Producer Responsibility (PRO) is covered by provisions of the European Packaging and Packaging Waste Directive 94/62/EC. In practice, EPR requires producers (which includes brands, importers, or manufacturers) to finance packaging waste collection.

This is managed on a national level, by approved organisations. In France, Léko is one such Producer Responsibility Organisation (PRO).

In this guide, they share what businesses selling products in France must know about the EPR registration process, fees, Triman, and other packaging waste instructions.

EPR requirements in France

If you represent a company that manufactures or imports packaged products on the French market for the end consumer you are a Producer regardless of the quantity of products you sell.

To comply with the regulation as a producer you can either develop your own individual system and take care of the end-of-life of all your products’ packaging by yourself, or, you can delegate your responsibility as a “Producer” by joining a state-approved eco-organization like Léko.

Léko is authorized to collect eco-taxes from companies called “Producers” All contributions collected by Léko will finance the prevention, collection, sorting, reuse and recycling of household packaging.

This scheme was implemented in France more than 30 years ago. Penalties for producers in case of non-compliance with their EPR obligations are administrative fines foreseen by the law.

Article L541-9-5 of the Environmental Code states up to 1,500 EUR per unit or per ton of product for a natural person 7,500 EUR a legal entity, and another administrative fine of up to 30,000 EUR.

Registration procedure

The registration process is quick and easy:

Step 1: Go to Leko’s website

Step 2: Click on “Join” at the top right of the page

Step 3: Select if you are a producer or contract manager

Step 4: Follow the registration procedure

Producer Responsibility Organisations (PROs) in France

All Producer Responsibility Organisations (PROs) classified by the EPR systems in France can be found on the Les filières à Responsabilité Élargie du Producteur website.

When it comes to product packaging EPR schemes, the PROs are the following:

• Léko
• Citeo
• Adelphe (Adelphe is part of Citeo).

Markings

Sorting signage requirements

New sorting signage have been introduced in France in September 2022.

1. Easy identification using colour codes: Green for glass, Yellow for other packaging (just like the colour of French sorting bins).

2. Clear explanations using icons and short texts (or both)

3. Multi-country adaptation (without text)

Note: Examples of Triman and sorting signs can be found here.

What is Triman?

It’s better to mention the sorting signage and the Triman logo – not only the Triman because the Triman is part of the sorting signage. For context, the Triman is the logo of the little man with the 3 arrows.

Does all product packaging require sorting instructions?

With the introduction of these sorting instructions, we’re also talking about an extension of the sorting instructions, since from now all household packaging goes into the sorting or glass garbage can, and all types of household packaging must carry the sorting instructions.

Is Triman mandatory?

It is mandatory for Producers to display sorting instructions on their household packaging from September 9, 2022.

Is the Green Dot accepted in France?

The order banning the Green Dot has been cancelled, the Green Dot can no longer be sanctioned and is no longer prohibited as such.

Costs

When you join Léko, your membership fees depend on the amount of packaging you put on the market by year. The membership also gives access to the sorting signage license and to our tool for assessing the recyclability of packaging online called Circulate.

We also provide strong support for our members when needed on various subjects:

1. Sorting signage check

2. Compliance

3. Declaration process

4. Regulatory updates in France and the EU

How can Léko help companies selling in France?

With Léko, producers can manage compliance with their EPR obligations for household packaging in France. We can help them with eco-design, R&D, reuse and sorting awareness projects.

Léko is also a partner of RecycleMe, an international circular economy consulting firm which helps with regulatory, operational and technical support.

You can learn more on this page.