REP: eco-contribution and unique identifier for importers

Extended producer responsibility, EPR, is established by Articles L. 541-9 et seq. of the Environmental Code, supplemented by Law No. 2020-105 of February 10, 2020, known as AGEC. The principle is simple: whoever places a product on the French market finances its end-of-life, including collection, sorting and recycling. The law calls a producer anyone who places a product on the national market for the first time. When manufacturing takes place outside the European Union, that producer is you: the importer established in France. The Chinese factory is never subject to the obligation.

This rule surprises many first-time importers. You buy from a factory, you pay freight, customs: and there is a third financing, calculated on your volumes and paid to state-approved organizations. It is arranged before the first sale, not upon container arrival. The obligation is attached to your legal entity and your Siren, not to your supplier or your freight forwarder.

Each product family has its own channel, managed by state-approved eco-organizations. A consumer goods importer most often encounters the following.

The same product can fall under several channels: a packaged toy concerns the toy channel and the packaging channel. You must then join as many eco-organizations as there are channels involved, with a separate declaration and invoice for each. The full list is long, from medicines to pleasure boats: take inventory product by product before the first order.

The eco-contribution is due from the first placing on the market in France. It is calculated on quantities: tonnages, materials, packaging types or number of units depending on the channel. It does not depend on the customs value. You periodically declare to your eco-organization what you have placed on the market, and the eco-organization invoices you according to its scale.

The declaration frequency, monthly, quarterly or annual, depends on the signed contract and volumes. The scales vary from one channel to another and change each year: according to packaging materials, according to product type, with modulations that reward eco-design. Also keep the distinction between households and professionals: a product sold to individuals, with its packaging, follows the rules of household flows.

Last confusion to clear up: the eco-contribution is neither a customs duty nor VAT. Nothing is paid on this account at customs clearance. It is declared and settled afterwards, directly to the eco-organization.

Since the AGEC law, every producer must register with the national register administered by ADEME before their first placing on the market. Registration is done online, using your Siren, and results in a free unique identifier starting with the letters FR. A single number covers all your schemes and remains attached to your company.

This number is not decorative. Eco-organizations cannot sign a contract with a producer without an identifier, and since 2023 it has been among the mandatory details on your invoices. Your customers and partners can verify it with ADEME: a false or reused number is an offense. Request it as soon as the import becomes serious, before the first sale, not after.

Every imported product arrives packaged: cardboard, film, label, cushioning. If these packages go to households, they fall under the household packaging scheme and each material is declared by tonnage. The packaging eco-contribution is therefore calculated on the actual detail of your packaging, not on a global estimate. Ask the factory for the grammage per material and include it in your specifications.

In France, products subject to sorting rules bear the Triman logo and the sorting instruction, mandatory on the packaging. In Europe, Regulation (EU) 2025/40 on packaging and packaging waste replaces Directive 94/62/EC and has been applicable since August 2026: it harmonizes packaging EPR across the Union. If you sell in several member states, you register in each of them.

Sorva is a brokerage and sourcing firm. On each file, our Chinese-speaking team in Guangzhou collects from the factory the data your declarations require: packaging materials and grammages, weight, nature of products, logo and sorting instruction to place. We help you list the affected schemes and assemble the regulatory file before the container departs, so that placing on the market is not a moment of discovery.

In most cases, you pay no fees: you open a file, we negotiate the goods for you and we take a commission on their ex-works value. Your eco-contributions remain managed with your eco-organizations: we provide you with clean and verified data that feeds them.