2017 changes to annual packaging declarations in France – what you need to know

This is on top of amendments to the thresholds for fixed fee options and sector specific submissions, to take effect from 1 January 2017.

The changes were introduced after their members (which include well-known consumer brands like Mars, Danone, Adidas and Dell) continuously criticised the heavy administrative burden of the annual data submissions that require a detailed material declaration per packaging component, for each package placed on the French market. Producers are charged a fee per weight of material and a fee per unit based on weight bands.

This major reform of Eco Emballages’ system may also have been precipitated by the possible arrival of a second packaging compliance scheme in 2018, which would introduce much needed competition and cost options to the French compliance market.

Here are five points UK company members of Eco Emballages, or those thinking they may be obligated for packaging in France, need to know:

1. Threshold introduced on fixed fee option for small producers

France does not have a threshold for packaging waste obligations, and the complex data management requirements and costs have been a barrier for small companies to comply with French packaging legislation. Eco Emballages has now introduced an official threshold to what previously had been its minimum annual cost.

Le forfait is a fixed fee option for companies that place fewer than 10,000 sales units on the French market. These companies can now pay EUR 80 annually to Eco Emballages and need not submit a declaration. This allows small producers to become compliant without facing undue administrative burdens.

2. Threshold will be raised for sector specific declarations

La déclaration sectorielle is a simplified sector specific declaration by major product families. This is a significantly easier way to declare data by using a unit rate based calculation model, allowing companies to avoid weighing and maintaining complex packaging material data.

The sector specific declaration had previously been an option for companies selling fewer than 180,000 sales units on the French market, but this threshold will be raised to 500,000 from next year. The sectors cover numerous goods from food and beverages, health and beauty products, home improvement, clothing and other miscellaneous items.

Companies calculate their fees by applying a sector rate to the smallest consumer unit sold, for example:

A food company sells a 6-pack of yoghurts. The smallest consumer units (CU) are the individual yoghurt pots. The sales units (SU) of the 6-pack (20,000) would now have to be calculated by 6.

SU 20,000 x 6 = 120,000 CU. This is below the 500,000 threshold and a sector specific declaration can be used.

The sector rate for Dairy products is EUR 0.0085 per CU. 120,000 x EUR 0.0085 = EUR 1020. This would be the packaging compliance fee for those items, and does not require companies to use packaging weights. Sector specific rates are set by Eco Emballages and reflect the typical cost per materials used for products under each sector.

3. Introduction of a simplified declaration method - La déclaration par Unité de Vente Consommateurs (declaration by consumer unit)

This is perhaps the biggest change, and marks a significant shift in Eco Emballages’ data requirement. The new declaration will remove the need to declare packaging per component, and instead allows companies to report the total weight per packaging material for the total consumer units of each product.

Columns for product descriptions and codes largely remain, as does Eco Emballages’ Bonus and Malus requirements – applying a reduction or increased fee based on specific packaging recyclability criteria. Overall the declaration form is easier to read and more intuitive – Eco Emballages estimates that this will reduce the workload of annual submissions by 50%.

The next data submission to Eco Emballages is due by 28 February 2017. For now, companies can choose whether to use the new or old declaration format, as changes take effect 1 January 2017, leaving producers little time to amend current data management practices.

4.  A new packaging compliance scheme in France?

A recent press release from BVSE (Federal organisation for secondary raw materials and waste management) in Germany announced that Reclay Group is establishing a new packaging compliance scheme in France.

LÉKO, which is part founded by Reclay subsidiary Valorie SAS, expects approval from Ademe (French Environment and Energy Management Agency) in January 2017, and would start operating as a packaging compliance scheme from 2018.

LÉKO is supported by 650 companies representing 20% of the market, and hopes to address decades of criticism of the monopoly system from producers and French municipalities. LÉKO promises customer friendly and simpler data submissions, transparent fee structures, and an increase to resource efficiency and recycling targets in France.

5.  Where do I find more information?

Eco Emballages has provided information on their website, including a useful simulator tool of the new declaration.

Ecosurety will present a summary and discuss impacts of the changes in our upcoming webinar on Packaging compliance in France and Germany – you can book your place here.

Changes in 2017 to national packaging legislation and systems in Germany, France, Norway and Italy will be discussed at our upcoming International Compliance Seminar in London, along with practical sessions on assessing your obligations abroad, future EU and UK strategies for waste management and an external speaker from EXPRA (Extended Producer Responsibility Alliance). Book now to reserve your place.

How can Ecosurety help?

We can offer consultancy to help producers understand their requirements in Europe, with support solutions including impact assessments, compliance strategies, regulatory monitoring, data management and distributor compliance support.

Please contact our team of specialists if you are offering goods for sale in France by emailing info@ecosurety.com or calling 0845 094 2228. 

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