France EPR

What is France EPR Batteries

France has maintained mandatory battery EPR since 2009, when the EU Batteries Directive 2006/66/EC was transposed into French law through Decree 2009-1139 of 22 September 2009, embedding battery EPR obligations into the Environmental Code (Articles R.543-124 onwards). The framework was substantially updated by the AGEC law (Law 2020-105 of 10 February 2020) and further aligned with the new EU Battery Regulation through the law of 22 April 2024, which gave full effect to Regulation (EU) 2023/1542 in France from 18 August 2025. Oversight is provided by ADEME (Agence de la transition écologique), which manages the national EPR register SYDEREP and issues Unique Identification Numbers (UINs) to registered producers. Enforcement sits with ADEME and the DGPR (Direction générale de la prévention des risques), which approve PROs, maintain public producer lists, and impose administrative fines under Article L.541-9-5 of the Environmental Code. From 1 January 2026, battery waste management operators in France are required to contract with an approved eco-organisation or a producer with an approved individual system for the management of battery waste. Take-back of batteries at no cost by all battery distributors — regardless of their size — has also become mandatory.

Does This Apply to E-Commerce & Online Sales

Yes. French battery EPR obligations apply to all producers placing batteries on the French market, including foreign brands selling directly to French consumers via e-commerce. Distance sellers with no French establishment are explicitly captured and must act through an authorised representative established in France. The UIN must appear on invoices, general terms and conditions, and the French domain of the producer's website. Online marketplaces including Amazon.fr, eBay.fr, and Zalando actively verify UINs against the SYDEREP database and restrict or block listings for sellers who cannot provide a valid UIN. Each EPR stream — batteries, WEEE, packaging, textiles — generates its own separate UIN. Amazon and eBay have required battery UINs from sellers since 2022, making practical enforcement of this obligation well established.

Who is the "Producer" under France EPR?

Under the French Environmental Code and Regulation (EU) 2023/1542, a producer is any company that, in the course of commercial activity, places batteries — whether standalone or incorporated into products — on the French market for the first time. This covers:

1. Manufacturers or brand owners based in France that first place batteries on the market under their own name.
2. Importers or intra-EU acquirers bringing batteries into France for the first time under their own name — liability attaches at customs clearance or arrival, unless the product is already registered upstream.
3. Private label owners whose brand name appears on batteries manufactured by third parties.
4. Distance sellers with no French establishment who sell batteries or battery-containing products directly to French consumers.
5. Economic operators who prepare batteries for re-use or repurposing — treated as producers for the second life of the battery.

There are no de minimis thresholds — placing even a single battery-containing product on the French market triggers producer obligations.

Who Must Register for EPR Batteries in France

All producers placing batteries on the French market must join an approved PRO (eco-organisation) and register through that organisation. The PRO registers the producer with ADEME's SYDEREP system, which then issues the UIN. The two approved PROs for portable batteries are:

• Corepile (corepile.fr) — approved for 2022–2027
• Screlec / Batribox (screlec.fr) — approved status extended to 2025, with new approvals from 18 August 2025 onwards

Ecosystem (pro.ecosystem.eco) covers batteries alongside EEE and lamps and is an alternative route for producers placing multiple product types on the French market. Upon joining a PRO, producers must declare products placed on the French market for the last 3 years at initial registration, and then declare annually on an ongoing basis.

France EPR Battery Registration Threshold

There is no de minimis threshold for battery EPR registration in France. The obligation applies from the first battery placed on the French market, regardless of company size or volume. The UIN is valid for one year only and must be renewed annually. Registration with SYDEREP is carried out exclusively through the PRO — producers cannot register directly with ADEME without a PRO. Both Corepile and Screlec require a minimum annual contribution of €200 excluding VAT, regardless of volumes placed on the market.

Batteries Covered (and Excluded)

France's battery EPR scheme covers all battery types placed on the French market, aligned with the five categories of Regulation (EU) 2023/1542 from 18 August 2025: Portable batteries Batteries under 5 kg not designed for industrial or vehicle use. Includes batteries in consumer electronics, power tools, household devices, and toys. Most commonly encountered category for e-commerce sellers. Light Means of Transport (LMT) batteries Batteries used in e-bikes, e-scooters, e-mopeds, and similar light electric vehicles. Included within the portable battery category under French EPR definitions prior to 2025; now a separate category under the EU Battery Regulation. Automotive (SLI) batteries Starting, lighting, and ignition batteries used in vehicles. Industrial batteries Batteries used in industrial applications and stationary energy storage systems. EPR for industrial batteries was extended under the EU Battery Regulation from 18 August 2025. Electric vehicle (EV) batteries Batteries used in electric cars and heavy electric vehicles. Key exclusions:

• Batteries designed for military or space equipment — outside scope entirely
• Batteries in nuclear installations — excluded
• Second-life batteries where the operator performing re-use or repurposing becomes the new producer

Producer Responsibility Organization (PRO)

France's approved eco-organisations for batteries are: Corepile — one of the two approved PROs for portable batteries (agrément 2022–2027). Corepile manages nationwide collection infrastructure, issues eco-modulation discounts for batteries meeting sustainability criteria, and handles SYDEREP registration on behalf of members. Minimum annual contribution: €200 ex. VAT. Screlec / Batribox — the second approved PRO for portable batteries. Screlec was the first French eco-organisation to implement discounted fees for batteries meeting eco-criteria. Minimum annual contribution: €200 ex. VAT. Ecosystem — covers batteries alongside household EEE, lamps, and professional EEE. Ecosystem manages the SYDEREP registration on behalf of its 5,400+ members and can represent producers across multiple EPR streams through a single membership. From 18 August 2025, new approvals for eco-organisations covering industrial and EV batteries were expected to be announced. Producers in these categories should confirm current approved organisations with ADEME directly.

EPR Registration in France

The registration process for battery producers in France is as follows:

1. Determine whether your business qualifies as a producer and identify which battery categories you place on the French market.
2. If established outside France, appoint an authorised representative (mandataire) established in France with a French SIREN number, before initiating any registration.
3. Select and join an approved PRO — Corepile, Screlec, or Ecosystem — and pay the one-off joining fee.
4. Declare batteries placed on the French market for the last 3 years as part of the initial registration process.
5. The PRO uploads your details to ADEME's SYDEREP register. ADEME issues your UIN, which serves as proof of EPR registration.
6. Display the UIN on your French website, invoices, and general terms and conditions of sale.
7. Submit annual declarations covering batteries placed on the French market during the previous calendar year, and pay eco-contributions accordingly.
8. Renew the UIN annually — it is valid for one year only.

Authorized Representative

Foreign companies selling batteries directly to French consumers without a French legal establishment must appoint an authorised representative (mandataire) established in France. The representative must hold a French SIREN number and is responsible for maintaining the written mandate, signing the PRO contract, submitting declarations and payments, and receiving ADEME correspondence on behalf of the producer. Legal responsibility for the accuracy of declarations and compliance with the Environmental Code remains with the producer, not the representative. Important development: In December 2025, the European Commission proposed suspending the authorised representative requirement for EU-established companies until 2035. This proposal has not been formally adopted as of May 2026. For non-EU producers, the requirement is not affected and continues to apply under the French Environmental Code.

What Data Must Be Reported

Producers must declare the following data to their PRO annually:

• Total weight (kilograms) of batteries placed on the French market during the previous calendar year, broken down by battery category (portable, LMT, SLI/automotive, industrial, EV)
• Battery chemistry type where relevant to eco-modulation calculations
• Brand names under which batteries were placed on the market
• At initial registration: quantities placed on the market for the preceding 3 years
• Collection and recycling performance data, compiled and reported by the PRO to ADEME on behalf of members

Annual declarations are submitted to the PRO, which forwards data to ADEME via SYDEREP. Producers must maintain financial and technical records for 6 years for potential ADEME audit.

First Reporting Period & EPR Reporting Deadlines

Battery EPR has been mandatory in France since 2009. The new EU Battery Regulation obligations took full effect from 18 August 2025. Key dates:

• 2009: Battery EPR mandatory in France under Decree 2009-1139.
• 18 August 2025: EU Battery Regulation (2023/1542) fully replaces the former Batteries Directive in France. New five-category structure applies.
• 1 January 2026: Battery waste management operators required to contract with an approved eco-organisation.
• Annual: Declarations of batteries placed on the French market during the previous year, submitted to the PRO. Deadline timing is set by each PRO and typically falls in Q1.
• Annual: UIN renewal — the UIN is valid for one year only and must be renewed each year after payment of contributions.
• 18 February 2027: Battery passports mandatory for industrial batteries (>2 kWh) and EV batteries.
• 18 August 2027: Due diligence obligations in force (delayed under Omnibus IV).

Labels & Marketing Claims

Crossed-out wheeled bin symbol From 18 August 2025, all batteries must display the separate collection symbol covering at least 3% of the area of the largest side of the battery, up to a maximum of 5 × 5 cm. Chemical symbols Batteries containing more than 0.002% cadmium must be marked Cd. Batteries containing more than 0.004% lead must be marked Pb. Capacity marking Portable and rechargeable batteries must display capacity information. QR code From 18 August 2026, all batteries must carry a QR code. For LMT, industrial (>2 kWh), and EV batteries, this links to the Digital Battery Passport from 18 February 2027. CE marking Mandatory from 18 August 2024. UIN display The battery UIN must appear on the French website (.fr domain), invoices, and general terms and conditions of sale in France. This is a specific French requirement independent of the EU Battery Regulation labelling rules. Triman logo The Triman logo and consumer sorting instructions are mandatory on battery products sold in France, on their packaging, or on their online product pages, as required by the AGEC law. Language requirements Consumer-facing information on batteries sold in France must be provided in French. Environmental claims The Empowering Consumers for the Green Transition Directive (2024/825/EU) must be transposed by March 2026, after which unsubstantiated green claims will be prohibited across the EU including France.

EPR Eco Fees & Eco-Modulation

France's battery eco-contribution structure is weight-based, calculated per kilogram of batteries placed on the market by category. Both Corepile and Screlec publish tariff schedules on their websites. Key fee parameters:

• Minimum annual contribution: €200 excluding VAT per producer (Corepile and Screlec)
• Per-kilogram contributions: vary by battery category and chemistry — exact rates are published in each PRO's tariff (barème)
• Eco-modulation discounts: Screlec was the first French eco-organisation to implement reduced fees for batteries meeting specific eco-criteria related to sustainability characteristics. The fee reduction is relatively modest but increases for large volume producers.

From 2025, eco-modulation bonuses and penalties are applied to French battery eco-contributions in line with the requirements of Regulation (EU) 2023/1542, which mandates eco-modulation based on battery category, chemistry, rechargeability, and recyclability.

Risks, Penalties & Common Mistakes

1. Operating without a UIN. Selling batteries or battery-containing products in France without a valid UIN exposes companies to administrative fines under Article L.541-9-5 of the Environmental Code — up to €7,500 per unit for legal entities, plus fines of up to €100,000 for operating without registration. Amazon.fr, eBay.fr, and Zalando actively verify UINs and block non-compliant listings.
2. Forgetting that the UIN expires annually. The UIN is valid for one year only. Failure to renew results in an invalid UIN, listing restrictions on marketplaces, and potential fines.
3. Failing to declare the last 3 years at registration. Producers joining a PRO for the first time must declare volumes placed on the French market for the three preceding declaration years. Failure to regularise past years is a compliance breach.
4. Not appointing an authorised representative. Foreign companies without a French establishment must appoint a representative with a French SIREN before any registration can proceed.
5. Assuming one UIN covers all EPR streams. Each EPR stream (batteries, WEEE, packaging, textiles) generates its own separate UIN. A battery UIN does not cover WEEE obligations or vice versa.
6. Missing the mandatory UIN display. The UIN must appear on the French website, invoices, and general terms. Missing display is independently sanctionable under the Environmental Code.
7. Missing the 1 January 2026 obligation. Battery waste management operators must contract with an approved eco-organisation. Non-contracted operators face sanctions under the updated French decree.

What E-Commerce Sellers Should Do Now

1. Confirm whether your products contain batteries — standalone or incorporated into devices — and whether they are being sold to French consumers.
2. If established outside France, appoint an authorised representative (mandataire) with a French SIREN number before initiating registration.
3. Join Corepile, Screlec, or Ecosystem as your approved PRO for batteries, and complete the initial declaration covering the last 3 years of volumes placed on the French market.
4. Receive your battery UIN from ADEME via your PRO.
5. Display the UIN on your French website (.fr), invoices, and general terms and conditions.
6. Provide your battery UIN to Amazon.fr, eBay.fr, Zalando, and any other marketplace where you sell battery-containing products.
7. Submit annual declarations and pay eco-contributions based on the PRO's tariff schedule. Renew the UIN annually.
8. Apply the Triman logo and sorting instructions to battery products and their packaging sold in France.
9. Verify that all batteries carry the crossed-out wheeled bin symbol, CE marking, capacity information, and French-language consumer information as required.
10. Plan for the QR code requirement by August 2026 and the Digital Battery Passport for industrial and EV batteries by February 2027.

FAQ

• Is battery EPR mandatory in France?

Yes. Battery EPR has been mandatory in France since 2009. From 18 August 2025, the new EU Battery Regulation (2023/1542) applies in full, replacing the former Batteries Directive. All producers placing batteries on the French market must join an approved PRO, obtain a UIN via SYDEREP, file annual declarations, and pay eco-contributions. From 1 January 2026, battery waste management operators must also contract with an approved eco-organisation.

• Do foreign brands selling online into France need to register?

Yes. Distance sellers with no French establishment are explicitly captured as producers under French battery EPR law. They must appoint an authorised representative with a French SIREN number before any registration can proceed. Amazon.fr, eBay.fr, and Zalando have verified battery UINs since 2022 — non-compliant sellers face listing restrictions.

• What is the UIN and how long is it valid?

The Unique Identification Number (UIN) is issued by ADEME via the SYDEREP register after a producer joins an approved PRO and pays contributions. It serves as proof of compliance and must appear on the French website, invoices, and general terms. The UIN is valid for one year only and must be renewed annually. Each EPR stream generates its own separate UIN.

• Is there a minimum threshold below which registration is not required?

No. There is no de minimis threshold for battery EPR in France — placing even a single battery on the French market triggers the registration obligation. The minimum annual contribution to Corepile or Screlec is €200 excluding VAT, regardless of volumes.

• Do I need to declare past years when joining a PRO?

Yes. At initial registration, producers must declare the quantities of batteries placed on the French market for the three preceding declaration years. This regularisation requirement applies regardless of how long the company has been operating without registration. Outstanding eco-contributions for past years must also be paid.