Professional packaging EPR: what industrial companies need to know

From January 1, 2027, all professional packaging will be covered by an Extended Producer Responsibility (EPR) scheme in France. Industrial companies that place packaged products on the market, import packaging, or make certain packaging available for the first time may be concerned.

But concretely, who has to pay? Which packaging? And what does this change for a factory?

1. What is professional packaging EPR?

The principle is simple: the producer must finance the end-of-life of the packaging it places on the market.

To do so, it must transfer its responsibility to an approved producer responsibility organization — or set up an individual system when authorized to do so — and then pay an eco-contribution calculated according to the packaging concerned.

This contribution notably helps finance the prevention, reuse, sorting and recycling of professional packaging waste.

The new scheme, initially planned for July 1, 2026, will ultimately be operational on January 1, 2027. The companies concerned must therefore anticipate their compliance.

2. Which packaging is concerned?

The EPR scheme applies to professional packaging, i.e. packaging for products consumed or used by professionals.

In industry, this may notably include:

• stretch films and covers;
• plastic pouches and bags;
• cardboard boxes and crates;
• drums, cans and other containers;
• transport packaging;
• grouped packaging;
• pallets and certain reusable packaging;
• cushioning and protective materials.

Warning: the material alone is not enough

Plastic packaging may be concerned, but the key question is who is legally the producer of that packaging.

Packaging already covered by another EPR scheme does not fall under this general scheme.

3. Is an industrial company necessarily concerned?

No.

Simply using packaging and generating packaging waste at its site does not automatically mean that the company is the EPR producer.

It is necessary to look at how the packaging is placed on the market and who is considered the producer under the European regulation.

For transport, service or primary production packaging, the producer is notably the manufacturer, importer or distributor that makes the packaging available for the first time under the conditions set out in the regulation.

For already packaged products, responsibility may instead fall on the company that places the packaged product on the market.

Example

A factory purchases plastic film from a French manufacturer and uses it to ship its products.

→ The fact that the factory subsequently generates the waste does not automatically mean that it is the EPR producer of the film.

Conversely, if the same company packages its own products in packaging and places them on the market, it may be the EPR producer for that packaging.

Each type of packaging and its route to market must therefore be analyzed.

4. Who has to pay?

It is the EPR producer who must finance extended producer responsibility.

In practice, the company concerned:

1. identifies the packaging for which it is the producer;
2. joins an approved producer responsibility organization;
3. declares the packaging placed on the market;
4. pays the corresponding eco-contribution.

The eco-contribution may be adjusted according to the environmental characteristics of the packaging, with notably bonuses or penalties provided for in the specifications.

For the new professional scheme, Citeo Pro, Léko Pro and Twiice were approved in 2026.

5. What about waste present at the factory?

This is an important distinction.

EPR producer

→ because it places packaged products or certain packaging on the market.

Waste holder

→ because it uses packaging and subsequently generates waste at its site.

It may therefore have an EPR obligation and, in parallel, obligations to manage its own waste.

EPR must contribute to financing the management of professional packaging waste according to the arrangements provided for by the scheme. However, this does not mean that all collection and treatment services automatically become free for the company holding the waste.

6. What does a company concerned by the scheme have to do?

For an industrial company, the process can be summarized in 5 steps:

1. Inventory its packaging

List the packaging used and/or placed on the market:

• plastic;
• cardboard;
• metal;
• wood;
• glass;
• composite packaging, etc.

2. Identify its use

For each type of packaging, determine in particular whether it is:

• sales packaging;
• grouped packaging;
• transport packaging;
• reusable or single-use packaging.

3. Identify the EPR producer

Determine who is legally responsible for placing each packaging on the market.

4. Join a producer responsibility organization

From January 1, 2027, the producers concerned must have transferred their obligation to a producer responsibility organization or have initiated the necessary process for an individual system.

5. Declare and pay

The company must declare the quantities concerned and pay the corresponding eco-contribution.

7. Why is plastic packaging particularly concerned?

The regulations aim in particular to reduce packaging waste, increase reuse and improve recycling.

The professional packaging scheme sets recycling and reuse targets. For plastic packaging, the recycling target is 50% in 2028 and 55% in 2030.

The scheme specifications also provide for contribution modulation that can encourage certain environmental characteristics, including the use of recycled plastic material.

A reduced EPR contribution thanks to recycled plastic

From 2027, producers of professional plastic packaging may benefit from a bonus when they incorporate recycled plastic material (RPM) into their packaging.

The bonus is calculated based on the quantity of eligible RPM actually incorporated, resin by resin.

The applicable amounts are:

• €450/t of RPM when the recycled material comes from another EPR scheme;
• €550/t of RPM when it comes from the same EPR scheme as the packaging concerned.

The RPM must notably come from post-consumer waste, comply with the proximity principle, and come from a recycling process whose mass yield is at least 50%. Certain products are also excluded.

What supporting documents should be requested from the supplier?

To substantiate the eligibility of the RPM, the industrial company must ask its packaging supplier for:

• the post-consumer origin of the material;
• the mass yield of the recycling process (≥ 50%);
• compliance with the proximity principle;
• the traceability of the quantities of RPM incorporated.

These elements must be available to be provided to the EPR organization when the declaration is made.

Example

A company places 1 tonne of HDPE packaging on the market containing 20% eligible RPM from another EPR scheme.

It can declare 200 kg of RPM, corresponding to a €90 bonus (200 kg × €450/t), which reduces its EPR contribution.

At 100% eligible RPM, the theoretical bonus would be €450 for this tonne. The actual amount paid then depends on the eco-contribution schedule of the chosen EPR organization: this schedule sets the applicable EPR contributions for the different packaging types and materials.

The bonus is then deducted from the contribution due.

To determine the amount applicable to its company, the industrial company must therefore identify its EPR organization, consult its contribution schedule and declare the quantities of eligible RPM together with the required supporting documents.

For industrial companies, this means the issue is not limited to “paying the EPR contribution”: packaging choices, recyclability, reuse and the quality of waste sorting are becoming increasingly important economic and regulatory issues.

8. What should industrial companies do before 2027?

The most useful approach is not to wait until January 2027.

An industrial company can already establish a simple packaging inventory:

This inventory makes it possible to determine which packaging actually falls within the EPR scheme, who is legally responsible and which quantities will need to be declared.

Key takeaways

For an industrial company, professional packaging EPR comes down to three questions:

1. Which packaging is concerned?

→ All professional packaging falling within the scheme, except packaging already covered by another EPR scheme.

2. Who is the producer?

→ This depends on the type of packaging and how it is made available on the market. It is not necessarily the company that physically manufactures the packaging.

3. What does the producer have to do?

→ Join an approved EPR organization or establish an individual system where permitted, declare the relevant packaging and pay the corresponding EPR contribution.

The new professional packaging EPR scheme will become operational in France on January 1, 2027. Industrial companies should therefore start identifying their packaging, material flows and EPR responsibilities now.

Official sources

• ADEME – Professional packaging EPR scheme
• French Ministry for Ecological Transition – Implementation of professional packaging EPR from January 1, 2027
• EU Regulation (EU) 2025/40 – definition of the producer
• Légifrance – Decree No. 2025-1081 of November 17, 2025