Everything you need to know about Unique Identification Numbers (UIN) in EPR schemes

As of 1 January 2022, every producer subject to one or more EPR schemes is required to have a Unique Identification Number (UIN) for each scheme concerned. This number is issued by ADEME and confirms that you have registered with the SYDEREP declaration tool for EPR schemes. Find out how to obtain one, declare it, and avoid incurring penalties. 

Everything you need to know about Unique Identification Numbers (UIN) in EPR schemes

As of 1 January 2022, every producer subject to one or more EPR schemes is required to have a Unique Identification Number (UIN) for each scheme concerned. This number is issued by ADEME and confirms that you have registered with the SYDEREP declaration tool for EPR schemes. Find out how to obtain one, declare it, and avoid incurring penalties. 

A Unique Identification Number (UIN) provides proof that a producer is duly registered with the SYDEREP declaration tool for an EPR scheme.

ADEME issues a UIN to a producer for a single scheme. The producer holds as many UINs as there are schemes concerned by the products it places on the market, including their packaging.

This provision of France’s AGEC Law (Anti-Waste Act for a Circular Economy) came into force on 1 January 2022 (article L. 541-10-13 of the Environmental Code).
As of that date, the seller of a product is required to provide its unique EPR identification numbers when asked to do so by a buyer. If the seller is not a producer itself within the meaning of EPR, it must obtain these identification numbers from its supplier (article L. 541-10-10 of the Environmental Code).

 

Companies concerned: definition of the producer status

Any company that places products subject to EPR on the market (manufacturer, distributor, importer) within the national territory, whether within an individual compliance scheme or a collective scheme (producer responsibility organisation), is considered a producer.

To find out more about the concept of ‘producer’ within your specific scheme, go to the «Producers concerned » section on each of our EPR scheme pages.

The case of marketplaces 

The term ‘marketplace’ refers to all the electronic interfaces defined in   L. 541-10-9.

A marketplace has producer status: 

  • If it places products on the market under its own brand;
  • For the quantities it places on the market on behalf of third parties, UNLESS it holds proof that these parties have already fulfilled their obligations – in other words, that they hold a UIN for the scheme(s) concerned. 

To find out more about the case of marketplaces, visit our FAQ.

 

How can I find out whether a company has a Unique Identification Number?

Consult the list of producers with one or several UINs. Filter by company name, SIRET (French business establishment identification number) or UIN. 

Search for a producer

How to obtain a UIN

You will receive a UIN after joining a producer responsibility organisation (PRO) or creating your individual compliance scheme.  

Via your PRO 

If you are part of a collective scheme, the PRO you have joined will handle registering you with the declaration tool for EPR schemes (SYDEREP) and will send you your UIN. You cannot register as an individual.  
All categories of products offered for sale must be covered by this membership. In some cases, you may need to join several PROs for a given scheme.  
So we encourage you to contact  a PRO in charge of the scheme that concerns you. 

On setting up an individual compliance scheme 

In the case of an individual scheme, ADEME will send the UIN to the producer accredited by the ministry. 

Information to submit 

When you join a PRO or set up your individual compliance scheme, you will be required to provide the following information:  

  • Company name,
  • For French companies: legal category, SIRET (French business establishment identification number), and NAF code
  • For EU companies: Intra-Community VAT number
  • For foreign companies: Intra-Community VAT number or, if you do not have one, your identification numbers as defined in article R. 123-221 of the Commercial Code or, for, a non-resident company, your registration number issued by the tax authority in your country of residence.
  • Complete postal address (street number and name, locality, post code and country), telephone number, and website address (if any),  
  • The accreditation categories concerned by your membership.
     

If you wish, you may assign: 

  • a facilitator to complete the formalities for individual membership of a PRO
  • an authorised representative to take on responsibility for fulfilling your EPR obligations  

In both cases, as a minimum you will still have to send your facilitator or your authorised representative the information listed above, as they will need it in order to register you and obtain your UIN. 

Eco-organisme et système individuel : que choisir ?

Vous êtes producteur et vous devez vous mettre en conformité avec les filières REP ? Nous vous expliquons toutes vos options pour faire le bon choix. 

Choisir entre un éco-organisme et un système individuel

Providing your Unique Identification Numbers

You must provide your Unique Identification Numbers in your general terms and conditions of sale.   

In addition, the Environmental Code stipulates that:  

"Any producer fulfilling its EPR obligations shall indicate the UIN in the document relating to its general terms and conditions of sale or, should it not have such a document, in any other contractual document provided to the buyer” (article R. 541-173 of the Environmental Code).

“Any producer operating a website shall provide its UIN under the same conditions as the information stated in article 19 of [French] law no. 2004-575 of 21 June 2004 on confidence in the digital economy. The seller of a product subject to the EPR principle shall, at the buyer's request, provide the buyer with the UIN under which the producer fulfilling the EPR obligations for that product is registered” (article L. 541-10-10 of the Environmental Code).

 

Withdrawal of Unique Identification Numbers and potential penalties

Your Unique Identification Numbers may be withdrawn in the following cases: 

  • If you are in a collective scheme, the UIN may only be deleted at the initiative of the PRO with the responsibility for making such a decision Deletion takes effect if you are not a member of another PRO.
  • If you are in an individual compliance scheme and you discontinue your activities or your accreditation expires, the deletion of your UIN is handled by ADEME. 

When your UIN is deleted, you will be taken off all the lists of UINs for the schemes concerned.

If your Unique Identification Number is withdrawn and you stop meeting your obligations, you may be liable for the penalties stipulated in article  L. 541-9-5 of the Environmental Code 

The usual penalties are: 

  • a fine of up to €30,000,
  • a daily penalty, in addition to the fine, of up to €20,000 per day, which may be imposed from a specified date until your obligations are met. 

To find out more about the applicable penalties, go to the website of the Ministry for the Ecological Transition.

 

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