Declaration of reuse of professional packaging
Date of last update: 06-10-2024
Are you placing packaged products for professionals on the market? Declare them to the Reuse Observatory.
Starting from 2023, any producer placing at least 10,000 units of packaged products on the market per year is subject to a reuse obligation and must make an annual declaration of their packaging data starting in 2024.
A producer is understood to be a professional who packages or has their products packaged for market placement, or any importer of a packaged product placed on the market in France.
While waiting for the implementation of Extended Producer Responsibility (EPR) schemes for all packaging, you must declare these packagings via the Fench National Reuse Observatory of ADEME. The declaration for 2024 data from 2023 is now closed. The declaration for 2025 data from 2024 will take place between February and April 2025.
For more information on these obligations, consult Decree No.2022-507 of April 8, 2022, regarding the minimum proportion of reused packaging to be placed on the market annually.
Are you concerned by the declaration?
Producers are subject to the declaration obligation if they place more than 10,000 units of packaged products per year on the market. If you are affected, you must declare your industrial and commercial packaging placed on the market in 2024 to the Reuse Observatory in 2025.
Packaging of products not concerned:
You do not need to declare to the Observatory:
- your packaging related to the houslehold packaging and graphic paper sector ;
- your packaging related to food services packaging sector ;
- your packaging related to chemical products sector ;
- your packaging related to the building products sector ;
- your packaging that you have already declared to a collective structure (including Adivalor).
To remember
Who declares?
The declaration is made by a legal entity corresponding to a SIREN, which is a French legal entity business identification number, for each of these subsidiaries.
When?
Between February and April 2025. The specific dates will be communicated at the end of the year 2024.
Where?
An online questionnaire will be available on this page when the declaration period is open.
Need help?
A help guide and a contact email are available on this page during the declaration period.
For more information
Any packaging included within the remit of a currently approved producer responsibility organisation for packaging should not be declared to the Reuse Observatory via this questionnaire.
The currently approved producer responsibility organisations for packaging are as follows:
- The ERP sector for Houshold packaging (HP) ;
- The ERP sector for food services packaging (FSP) ;
- The ERP sector for chemical products (CHEMP) ;
- The EPR sector for construction industry building products and materials (family 2c of article R543-289 of the French Environmental Code (Code de l'Environnement)).
Any packaging coming within the scope of these four EPR sectors should not be directly declared via this upcoming questionnaire. This data is to be passed on to your producer responsibility organisation.
Since 2024, collective structures can offer to collect data on professional packaging (excluding those from household packaging and graphic papers, food services packaging, chemicals products and construction industry building products and materials sectors) from their members. They will be obliged to transmit the collected data to the Reuse Observatory.
If you have already made your declaration to a collective structure, you do not need to declare your data again to the Reuse Observatory.
A declarant is a legal entity corresponding to a SIREN.
In the case of a group with several subsidiaries with different legal entities, you may choose to declare at the group level or for each of these subsidiaries identified by a SIREN.
If you have multiple establishments, you must make your declaration for all your establishments. Declaration at the SIRET level is not possible.
The placing of industrial and commercial packaging (ICP) on the market corresponds to the transport of one or more packaged products and an act of purchase/transfer (whether in return for payment or free or charge) of the packaged product or products between two entities with different SIRET numbers.
These packaging materials will need to be tracked and declared starting from 2024 by companies subject to reuse obligations (Decree No. 2022-507)
Containers dedicated to processes and handling within a site are not packaging materials placed on the market to be tracked by a company.
The types of data that will be requested from declarants via the secure online questionnaire are as follows:
- Identity of the declaring SIREN (including the total annual revenue declared in 2024)
- Primary sector of activity
- Quantities of industrial and commercial packaging (ICP) placed on the market in the previous year (N-1), in units of packaging:
- Total quantity of ICP placed on the market in the previous year (N-1);
- Proportion of reused ICP placed on the market in the previous year (N-1).
Declaration of food services packaging
In 2025, producers no longer need to declare their catering packaging to the Observatory. It must now be declared through the approved producer responsibility organisation CITEO Pro.
You will find all the information by downloading the study on the accounting of packaging reuse (ADEME, February 2023). A FAQ and a 20-minute explanatory video are also available to you. For household packaging, you can also consult your producer responsibility organisation.
An update of the study is in progress and will be completed in the fourth quarter of 2024. Some corrections and explanatory elements will be added to the study published in 2023, following feedback from the initial declaration.
A producer who markets fewer than 10,000 units of packaged products per year can also declare their packaging on a voluntary basis.