No packaging included in the scope of a currently approved EPR eco-organization for packaging should be declared to the Reuse Observatory via this questionnaire. There are currently approved eco organizations for packaging in the following sectors: 

• The EPR household packaging and graphic paper

• The EPR professional packaging professional catering, between March 12, 2024 and December 31, 2024

• The EPR chemicals industry 

• The EPR building industry (family 2c of article R543-289 of the Environment Code). 

No packaging falling within the scope of these 4 EPR should be declared directly to the Reuse Observatory. This data must be transmitted to your EPR eco-organization.

For all matters relating to the declaration to your EPR eco-organization, we invite you to contact directly the EPR eco-organization(s) to which you belong. 

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 following types of data will be requested from registrants via the Reuse Observatory's secure online questionnaire:

• Identity of the declaring company, in particular
  • Country of residence
  • SIREN (or identification number for companies not based in France)
  • NAF code (or main business sector for companies not based in France)
  • Total annual sales declared in 2024 (or, if the accounting year does not allow this, in 2023)
• Quantities of professional packaging put on the market in 2024, in packaging units :
  If you declare data for industrial and commercial packaging and catering packaging, the questionnaire will ask you to enter your packaging quantities, distinguishing between these two categories of packaging.
  • Total quantity of professional packaging ;
  • Proportion of reused professional packaging
•  Registrant contact information

Reused packaging is packaging designed to be reused and which has at least one second use (see definitions in Article R543 43 and Article R541-350 of the French Environment Code). Reused packaging must be recyclable (Article L541-1 of the Environment Code).

You can find all the information you need by downloading the Counting methodologies for packaging reuse in France Version 2 (ADEME, November 2024). The accounting methodology for professional packaging is detailed in Summary 7 of the ADEME accounting study.

An update of the accounting study, originally published in February 2023, was carried out during 2024. Some clarifications and examples have been added following feedback from the first statement.

There are two types of professional packaging:

• Industrial and commercial packaging used or consumed by professionals - excluding catering professionals
• Catering packaging

Industrial and commercial packaging (ICP) are primary/secondary/tertiary product packaging used to market products consumed or used by professionals and not already covered by EPR for household packaging), with the exception of those consumed or used by professionals engaged in catering activities (Article L541-10-1 of the Environment Code). Examples: pallets, drums, totes, crates, straps, strapping, palletizing film, crates, drums, bottles, jars... They are listed in a Cartographie des couples produit / type et matériaux d'emballages published by ADEME (only available in French). It should be noted that this perimeter will, if necessary, be redefined to bring it into line with that of the EPR ICP planned for 2025.

Catering packaging are primary packaging used to market products consumed or used by catering professionals for food products whose mass or weight is strictly greater than the values indicated in the appendix to the July 20, 2023 Perimeter Order.

Note: The placing on the market of professional packaging corresponds to the transport of one or more packaged products and an act of purchase/transfer (in return for payment or free of charge) of the packaged products between two entities with different SIRETs. Containers dedicated to processing and handling within a site are not included.

The formula for calculating the proportion of reused professional packaging (or reuse rate) is as follows:

Reuse rate = Number of reused packs / total number of packages
In which Total number of packages = number of reused packages + number of new reusable packages + number of single-use packages

Producers must be able to track these three packaging quantities (reused, new reusable, single-use) to calculate their reuse rate and declare their packaging.

You can declare your packaging on a voluntary basis.