You have probably heard of eco-participation or the EPR tax, but do you sometimes feel overwhelmed by the complexity of environmental regulations?

You are not alone.

Extended Producer Responsibility (EPR), often misunderstood, is more than just a tax. If you are a finance or compliance manager and need to understand in detail what this system implies for your company, you've come to the right place.

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• The Extended Producer Responsibility imposes a financial obligation on companies that introduce products to the French market for the first time, to participate in the management of recycling and the recovery of waste from their end-of-life products.
• This financial contribution, called eco-contribution, varies greatly depending on the products you sell, as the recyclability of the materials used in your products has an impact on the actual costs of recycling.
• The products subject to EPR are currently divided into 19 Schemes. Prevention, collection, sorting, reuse and recycling of waste are managed by Producer Representative Organisations, approved by the State. Penalties for non-compliance can be up to 75,000 euros.
• EPR offers companies the opportunity to play an essential role in preserving the environment.

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Eco-participation or EPR tax? Let's clarify.

The eco-participation, also known as eco-contribution, is the financial contribution from the buyer of a new product towards financing the recycling of that product at the end of its life.

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The eco-contribution, often wrongly called "EPR tax", is not a tax because it is not paid to the public authorities. All eco-contributions are paid to Producer Representative Organisations, non-profit companies approved by the State. These Producer Representative Organisations, whose role is to collect, sort, reuse and recycle waste, do not make any profit on the eco-contributions paid by companies. All of the eco-participation is dedicated to the missions entrusted by the Public Authorities.

Please note

• The eco-participation is included in the sale price and, as such, is subject to VAT.
• It must be passed on to the customer in the same amount (who must be informed if it is electrical or electronic equipment or a piece of furniture)
• The amount of the eco-participation cannot benefit from any discount or rebate.
• It applies to all products placed on the market, including those given away free of charge.

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Eco-participation: Is my company affected?

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The EPR system is based on the "Polluter Pays" principle. In other words, anyone who manufactures, distributes or imports a product must contribute to its end-of-life recycling costs. 

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You are considered a "Producer" within the meaning of EPR if you are the first to place a product on the market in France for the national market, regardless of whether you are a manufacturer, distributor, reseller, retailer, importer, French or foreign company. Extended Producer Responsibility therefore obliges you to contribute financially to the recycling of your products.

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The State has created 25 EPR Schemes, and in 2024, 19 are operational. These Schemes group together large families of products to facilitate their sorting, recycling or reuse. Producer Representative Organisations approved by the State manage specific Schemes. They are responsible for waste treatment and undertake to comply with specifications including collection and recycling targets.

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This obligation arises from the AGEC law of 2022, which promotes the circular economy. The latter not only encourages the reuse of resources and the reduction of waste, but also encourages eco-design in the manufacture of products.

The EPR system improves the environmental impact of companies and reduces recycling costs, thus benefiting society as a whole.

If you market products covered by several Schemes, you will need to join as many Producer Representative Organisations as there are, who will collect the eco-contribution for the end-of-life management of the products concerned.

Take the example of a watch manufacturer: if it integrates a battery or a connected function into its product, it is responsible not only for the end of life of the watch, but also for that of the battery, any instructions and its packaging.

As a result, depending on the nature of your products, you may be subject to several EPR Schemes simultaneously for a single product.

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Eco-contribution: What will my financial contribution be used for?

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France is actively organizing its recycling Schemes, with 25 of them by 2025. According to ADEME, this initiative has made it possible to manage 9.4 million tonnes of waste in 2021. The objective now is to extend this organization to the European level, in order to harmonize a market of nearly 350 million consumers.

Environmental regulations are constantly changing. Anticipating these changes can be beneficial for any company.

Eco-participation is not just a cost; it represents an opportunity to contribute to a sustainable future. As entrepreneurs, our role is essential, not only for our companies but also for the planet. 

Particularly in internal communication, clearly communicating these efforts to your teams reinforces their commitment and fosters a responsible corporate culture. And this is true even if it is a regulatory obligation, which could be perceived as a trivial action by the consumer-citizen.  It also attracts new strategic talents, essential to the development of your company.

Eco-participation: How much will it cost me?

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The eco-contribution amount is determined by a scale set each year by the Producer Representative Organisations. It varies depending on the cost of waste treatment. Thanks to the Anti-Waste for a Circular Economy (AGEC) law, this amount will be reduced if the product incorporates environmental criteria (bonus) or increased if the product is highly polluting (penalty). This is what is known as eco-modulation.

Eco-participation scales are regularly revised by Producer Representative Organisations. In 2024, eco-participation costs were aligned with the actual recycling costs, impacting companies' finances and environmental strategies. 

There are several methods for managing the costs associated with recycling and sustainable product design. 

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Firstly, reducing the use of materials that are difficult to recycle from the design stage can generate significant savings.

The toy giant Playmobil, a major consumer of plastic, has been using plant-based plastics and packaging made up of at least 90% recycled cardboard and 100% recycled paper since spring 2024.

Secondly, investing in clean technologies that consume less energy and resources is another effective approach.

Thirdly, transparency about your recycling efforts not only helps to comply with regulations, but also improves your reputation. 

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Eco-participation: How and why to comply

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Environmental regulations are constantly changing. Anticipating these changes can be beneficial for any company.

These complex calculation methods require constant vigilance on the part of companies to adapt to changes and avoid penalties. Producer Representative Organisations are obliged to publish their scales, which are accessible online on their respective websites.
To remain compliant, it is essential to comply with the declaration, eco-contribution payment and annual documentation obligations.

The risks of non-compliance can lead to severe fines of up to 75,000 euros, or even prison sentences and business shutdowns.

CompliancR is a self-service digital platform that offers you all the services to meet your EPR obligations, from the automatic calculation of eco-contributions for your products to the declaration of placing on the market with Producer Representative Organisations, including joining the Schemes on which you depend and creating your UINs (Unique Digital Identifier).

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