Declaration of reuse of professional packaging
Date of last update: 02-05-2025
Do you market packaged products for professionals ?
Declare them to the Reuse Observatory.
From 2023 onwards, any producer placing at least 10,000 units of packaged products on the market per year will be subject to a re-use obligation and must submit an annual declaration of its packaging data.
Producer means a professional who packages or has packaged his products with a view to placing them on the market, or any importer of a packaged product placed on the market in France.
For packaging not falling within the scope of an approuved Extended Producer Responsibility organization in France, you must declare this packaging via the Reuse Observatory. The 2024 declaration of 2023 data is now complete, and the results are available via at Report of the 2024 declarations (only available in French). The 2025 declaration of 2024 data will take place between January 20 and May 31 2025.
To find out more about these obligations, see Decree no. 2022-507 of April 8, 2022 on the minimum proportion of reused packaging to be placed on the market each year.

How to declare in 3 steps

Seeking for help ?
If your question is not answered here, do not hesitate to contact our support team:
assistance-declaration-reemploi@ademe.fr.
Are you concerned by this declaration?
You must declare to the Reuse Observatory if you meet the following 4 conditions :

You are a producer as defined in the French Environment Code.
A producer is any person who, on a professional basis, packages or has packaged his products with a view to placing them on the market, any importer whose products are marketed in packaging or, if the producer or importer cannot be identified, the person responsible for first placing these products on the market (Article R. 543-43 of the French Environment Code).

You market at least 10,000 units of packaged products per year
Producers responsible for placing at least 10,000 units of packaged products on the market per year are concerned by the accounting and declaration of packaging reuse regardless of your turnover.

You market packaging for products consumed or used by professionals
This declaration to the Reuse Observatory concerns only the professional packaging sector not yet covered by an EPR sector:
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Industrial and commercial packaging used or consumed by professionals (excluding catering professionals) placed on the market between January 1st 2024 and December 31 2024 ;
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Catering packaging put on the market between January 1st 2024 and March 11 2024.

You have not already declared your professional packaging to a Collective Structure
Since 2024, collective structures have been able to offer to collect data on their members' professional packaging (packaging that does not fall within the scope of an EPR eco-organization). They will be obliged to transmit the data collected 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.

Products non-concerned
Packaging falling within the scope of an approved packaging EPR eco-organization does not have to be reported to the Reuse Observatory. You must declare data for the following packaging to your EPR eco-organization:
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your packaging covered by the EPR sector of household packaging and graphic paper ;
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your packaging covered by the EPR sector for catering packaging placed on the market between March 12, 2024 and December 31, 2024 ;
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your packaging covered by the EPR sector of chemical products ;
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your packaging covered by the family 2c (article R543-289 of the French Environment Code) of the EPR sector for the building industry.
Complementary resources
Presentation webinar
Webinar of January 24, 2025 - Dailymotion

Declaration presentation document
Webinar of January 24, 2025 - PDF

Frequently asked questions
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.
Yes, the producer must declare as long as they place more than 10,000 packaged product units on the market per year, regardless of their revenue.
Declaration Obligation
All producers responsible for placing at least 10,000 packaged product units on the market per year, regardless of their revenue, are subject to the obligation to declare reuse based on the packaging reuse accounting method.
This applies to all producers who package or have their products packaged for market placement, any importer whose products are marketed in packaging, or, if the producer or importer cannot be identified, the entity responsible for the first market placement of these products.
Reuse Targets
Any company placing at least 10,000 packaged product units on the market per year is subject to minimum reuse rate targets, which apply over different timeframes:
Observation year | Revenue range | ||
---|---|---|---|
Less than 20 M€ | Between 20 M€ and 50 M€ | More than 50 M€ | |
2023 | - | - | 5% |
2024 | - | - | 6% |
2025 | - | 5% | 7% |
2026 | 5% | 7% | 8% |
2027 | 10% | 10% | 10% |
To fulfill their obligations, producers have two options:
- Through their producer responsability organization if organizations are accredited for their packaging scope.
- Individually or by participating in a collective structure.
A producer calculates their annual packaged product units based on the following scope:
- Packaging placed on the French market;
- All household and professional packaging;
- All types of packaging (sales, grouped, or transport) and packaging materials;
- Single-use, new reusable, and reused packaging.
The following are excluded from this calculation:
- Exported packaging;
- Packaging subject to a reuse ban (R.541-350, III of the Environmental Code).
You can declare your packaging on a voluntary basis.
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
Professional catering packaging declaration
Catering packaging placed on the market between March 12, 2024 and December 31, 2024 must be declared to the approved eco organization CITEO Pro. Contact your EPR eco-organization for further 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.
For further information
Decree no. 2022-507 of April 8, 2022
Decree relating to the minimum proportion of reused packaging to be placed on the market annually.
Report of the 2024 declaration (2023 data)
Only availbale in french. This report provides an overview of packaging reuse (both household and professional) in France in 2023, based on data reported by producers and eco-organizations.
2023 packaging reuse data dashboard
Only availbale in french. The dashboard presents the key indicators for packaging reuse and repurposing for the year 2023