2024 Declaration of reuse of professional packaging
Date of last update: 02-14-2024
Are you placing packaged products for professionals on the market? Declare them to the Reuse Observatory before April 30, 2024.
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, the French National Reuse Observatory of ADEME is implementing a transitional solution for the declaration in 2024 for affected producers, regarding professional packaging placed on the market in 2023.
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. Producers that place less than 10,000 units of packaged products per year on the market may declare their packaging on a voluntary basis.
If you are affected, you must declare to the Reuse Observatory your professional packaging placed on the market in 2023, excluding:
- Your packaging covered by household packaging EPR;
- Your packaging covered by chemical products EPR;
- Your packaging covered by products and materials for construction EPR;
- 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?
The declaration is open from February 15 until April 30, 2024.
Where?
A secure online declaration is available on this page.
Need help?
Consult the declaration support guide downloadable on this page.
If you need additional assistance, you can contact our support via email at the following address: assistance-declaration-reemploi@ademe.fr
Before declaring
Exclusions
You are a member of an approved producer responsibility organisation for packaging?
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 EPR sector for Household packaging (HP);
- The EPR 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 three EPR sectors should not be directly declared via this upcoming questionnaire. This data is to be passed on to your producer responsibility organisation.
Are you part of a collective organisation?
In 2024, collective organisations ("structure collective in French in the decree No.2022-507) may take care of the collection of their members' professional packaging data (with the exception of data concerning household packaging (HP), chemical products (CHEMP) and construction industry building products and materials). They will be obliged to transmit the collected data to the Reuse Observatory. If you have already made your declaration to a collective organisation, you should not declare your data again to the Reuse Observatory.
Declaration by the headquarters
A declarant is a legal entity corresponding to a SIREN (French legal entity business identification number). 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. It is not possible to declare at the level of an establishment (SIRET, French business establishment identification number).
What is meant by 'placing on the market' professional packaging?
The placing of industrial and commercial packaging (ICP) or food services packaging (FSP) 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.
What information do you need to declare starting from February 15, 2024?
Declarants are asked to provide the following data via the secure online questionnaire:
Declarant's identity
Turnover
Business sector
Quantities of industrial and commercial packaging (ICP) and food services packaging (FSP) placed on the market in 2023, in packaging units:
Total quantity of ICP and FSP packaging placed on the market in 2023
Proportion of reused ICP and FSP packaging placed on the market in 2023
How to calculate your reused packaging placed on the market?
You will find all the information by downloading the study on the accounting of packaging reuse (ADEME, February 2023). For household packaging, you can also consult your producer responsibility organisation.