French Extended Producer Responsibility (EPR) regulations have undergone significant revisions in 2024, particularly affecting sellers of paper packaging materials. Amazon Europe has issued warnings that non-compliance may result in product delistings, prompting urgent attention from affected businesses.
Policy Update: Paper Category Merged Into Packaging
Effective January 1, 2024, France eliminated separate EPR registration for paper products, consolidating them under the packaging category. This change, enacted through Decree No. 2023-305 passed by the French Parliament in April 2023, renders previously valid paper UIN (Unique Identification Numbers) obsolete. The amendment combines extended producer responsibilities for household packaging and paper manufacturers under unified regulations.
Impact on Sellers: Four Compliance Scenarios
The policy change creates distinct compliance requirements depending on sellers' current registration status:
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Scenario 1: Existing French Packaging UIN
Sellers with valid French packaging UINs require no immediate action. -
Scenario 2: Only French Paper UIN
Paper-specific UINs will become invalid. Producer Responsibility Organizations (PROs) are expected to issue replacement UINs covering both packaging and paper by late February 2024. These must be uploaded to Amazon's EPR compliance portal before December 31, 2024. -
Scenario 3: Dual UIN Holders
Sellers possessing both packaging and paper UINs will have their paper registration revoked while maintaining valid packaging compliance. -
Scenario 4: No Current UIN
Unregistered sellers must immediately initiate French EPR category registration to avoid compliance violations.
Critical Deadline: Avoid Automatic Enrollment
Sellers must carefully monitor Amazon's prepayment service timelines. Failure to submit required UINs within designated periods triggers automatic enrollment in Amazon's prepayment system, resulting in additional fees.
Compliance Transition Guidelines
To facilitate smooth adaptation to the updated regulations, sellers should consider these measures:
- Initiate compliance verification processes without delay
- Contact assigned Producer Responsibility Organizations for UIN status confirmation
- Promptly update EPR information in Amazon Seller Central
- Monitor official policy updates from French authorities and Amazon
- Consult specialized compliance services when necessary
These regulatory changes present both challenges and opportunities for cross-border e-commerce operators. Proactive compliance measures remain essential for maintaining marketplace access and competitive positioning.