The Extended Producer Responsibility (EPR) scheme for Household Packaging and Graphic Papers (EMPAP) involves all companies that market packaged products intended for French households, whether they are manufacturers, importers, or distributors under their own brand. These professionals must comply with annual reporting obligations and pay eco-contributions calculated based on the weight and nature of the packaging placed on the market. The pricing system includes bonus-malus mechanisms aimed at encouraging eco-design and reducing the environmental impact of packaging.
Organizations Concerned by the EPR EMPAP Scheme and Their Obligations
Who Must Declare Their Packaging?
Not all companies are concerned, but there are many because the professionals involved are those who place packaged products on the French market intended for households within the scope of the packaging scheme. This qualification includes manufacturers who produce packaged consumer goods, importers who introduce packaged products from abroad, and distributors who market under their own brand. Online sales platforms facilitating market placement are also considered producers in the regulatory sense.
This EPR scheme does not provide for any minimum volume threshold, applying its obligations from the first package marketed. If you are an artisan selling a few jars of jam per month in glass jars, you must theoretically register, just like a large agri-food group distributing millions of units annually.
The Annual Declaration and Mandatory Signage
Compliance involves obtaining a unique identifier (IDU) via the SYDEREP platform. It is the eco-organization to which the company adheres that registers it with SYDEREP and communicates its IDU. This identifier aims to track declarations and link each producer to its eco-organization. The annual declaration, to be submitted before March 31, details the tonnages of packaging placed on the market the previous year, distinguishing each material (cardboard, glass, plastic, aluminum, steel).
Furthermore, packaging must bear the Triman logo accompanied by sorting instructions, informing the consumer about the waste destination. This signage becomes mandatory on all communication media related to the product when it cannot appear directly on the packaging for technical reasons. Companies subject to the EPR that neglect this obligation face administrative sanctions, beyond the penalties related to non-payment of contributions.
The Calculation System of Eco-Contributions for the EPR Packaging and Graphic Papers
Rates According to Materials and Recyclability
Eco-contributions are calculated based on the weight of packaging placed on the market, with rates varying significantly depending on the material and its recyclability characteristics. Glass benefits from advantageous rates due to its simple and infinite recycling. Multilayer plastics bear high contributions reflecting their difficulty in being recycled. For comparison, corrugated cardboard packaging generally costs a few cents per kilogram, while a complex plastic film can reach several tens of cents for the same weight.
The bonus-malus system refines this pricing by granting reductions to virtuous packaging. A product incorporating at least 50% recycled material benefits from a financial bonus, as do mono-material packaging that simplifies sorting and recycling. Conversely, unnecessary over-packaging or complex assemblies incur maluses that significantly increase the annual bill.
Examples of Contributions for Different Packaging
Nothing beats a fictional case for understanding: let’s take the example of a yogurt producer who markets 10 million polystyrene (PS) pots of 125g each, or about 1,250 tons of packaging, will pay several tens of thousands of euros annually according to the applicable PS rate. The same quantity packaged in returnable and reusable glass pots would benefit from a substantial reduction, or even a partial exemption depending on the deposit system’s terms.
Another example of eco-contributions for a company concerned by the EPR EMPAP is that of an e-merchant. It ships 50,000 parcels annually in 500g cardboard boxes with crumpled paper cushioning (i.e., 25 tons) and must pay a few thousand euros, an amount that could decrease by 10 to 15% by opting for recycled cardboard and eliminating the external plastic protective film. These design choices directly impact profitability, especially for low-margin products sold in large volumes.
EPR EMPAP Eco-Organizations and Optimization
Approved Actors
Three eco-organizations are approved until December 31, 2029 for the EMPAP scheme: Citeo, Adelphe, and Leko. Citeo is omnipresent in the household packaging sector, managing the vast majority of it. This eco-organization ensures the national coordination of selective collection, finances sorting centers, and provides support to local authorities to offset their operational costs. Adelphe, a subsidiary of Citeo, specializes in the food and beverage sectors. Leko positions itself as a third alternative by offering differentiated rates and personalized support.
Companies can compare rates, associated services (training, eco-design advice, declaration assistance), and customer support responsiveness before making their choice. This comparison is particularly relevant for structures placing several hundred tons on the market annually, where a few cents per kilo can generate substantial savings.
Levers for Optimizing Packaging Costs
To reduce costs, it is mainly necessary to reduce the weight of packaging in this EPR scheme, but this requires finding the balance between lightening and sufficient strength for transport and handling. A biscuit manufacturer that reduces its cardboard boxes by 10% reduces its annual contribution accordingly without compromising product protection.
The switch to better-valued materials also transforms the economic equation. Replacing a complex plastic film with recyclable kraft paper can halve or even triple the unit cost of eco-contribution. Retail brands that massively reformulate their packaging see annual savings in six figures and significantly improve their environmental communication to consumers sensitive to these issues.
