Extended producer responsibility: the importer's obligations
This is the obligation almost nobody sees coming. By placing a product on the French market, an importer becomes legally a « producer » — with a registration to obtain and contributions to pay, quite apart from CE marking and product conformity.
Updated September 2026
Importing is producing
Extended producer responsibility rests on a simple principle: whoever places a product on the market funds that product's end of life. The definition of « producer » is wider than the word suggests.
It covers three profiles: the domestic manufacturer selling under its own brand, the importer of products manufactured abroad and marketed in France, and the distributor selling under its own label. Buying in China to resell in France places you in the second category, with no exemption tied to company size.
This obligation is separate from product conformity. A perfectly compliant, correctly CE-marked article remains subject to it. The two subjects share neither their basis nor their interlocutor.
The unique identifier, and where it must appear
Every producer subject to a scheme must register and obtain a unique identifier, issued by the environment agency. It has been mandatory since 2022 and evidences that registration.
One point often surprises: you do not get one, but one per scheme concerned. A company importing an electrical appliance in a cardboard box falls under at least two schemes, and therefore two identifiers.
And it does not stay in a drawer: the identifier must appear on your invoices, your terms of sale and your website. It is the most visible checkpoint, and the one that most quickly gives away an unregistered business.
The schemes that concern an importer
The list has widened considerably. Those an importer meets most often:
- Packaging, which catches almost everyone — the shipping carton and the sales packaging both fall under it
- Electrical and electronic equipment, from small appliances to professional kit
- Batteries and accumulators, including those built into a device
- Textiles, footwear and household linen
- Furniture
- Toys, sports and leisure articles, and DIY and garden articles
A single reference can fall under several schemes at once: an electronic toy sold in a cardboard box with batteries concerns four.
What it costs, and what ignoring it costs
In practice the producer joins an approved eco-organisation for the scheme concerned, declares the quantities placed on the market and pays a proportionate contribution. The scale depends on the product, its weight and recyclability criteria — a modulation arrangement adjusts the contribution according to recycled content.
The unit amount is generally modest. That is not where the risk lies.
The risk is failing to register: it exposes you to administrative penalties, and above all it shows. Online marketplaces are required to verify their sellers' identifiers, and some suspend non-compliant accounts. Discovering the obligation through a suspended account costs infinitely more than complying upstream.
Frequently asked questions
- Does extended producer responsibility concern an importer?
Yes. The regulation classes as « producer » whoever places a product on the French market, which expressly includes the importer of products manufactured abroad. Buying in China to resell in France is therefore enough to be subject to it, with no exemption tied to company size or import volume.
- What is the unique EPR identifier?
A number issued by the environment agency to every producer subject to an extended responsibility scheme, mandatory since 2022. It evidences registration. You obtain one per scheme concerned, and it must appear on invoices, terms of sale and the website.
- How many identifiers do I need?
As many as there are schemes covering the products placed on the market, packaging included. The count rises quickly: an article that carries a battery, travels in a carton and falls into a separately regulated category accumulates three at once. Each scheme entails its own registration and its own annual declaration.
- Which schemes most often concern an importer?
Packaging first of all, since both the shipping carton and the sales packaging fall under it. Then electrical and electronic equipment, batteries and accumulators, textiles and footwear, furniture, toys, sports and leisure articles, and DIY and garden articles.
- Is extended producer responsibility the same as CE marking?
No, they are independent obligations. CE marking attests that the product meets the safety requirements of the European texts applicable to it; extended responsibility organises the funding of its end of life. The two share neither their basis, nor their interlocutor, nor their timetable — and satisfying one in no way discharges the other.
- What is the risk of not registering?
Administrative penalties, and a commercial consequence that is often more immediate: online marketplaces are required to verify their sellers' unique identifier, and some suspend non-compliant accounts. The cost of compliance bears no comparison with that of an interrupted sales channel.
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