Kaufland.fr – EPR guidelines for France

The EPR (Extended Producer Responsibility) guidelines regulate manufacturers’ responsibility to collect, recycle and dispose of products in certain categories.

Who has to register for the EPR guidelines in France?

In France, you must register if you are a seller who falls under the “manufacturer” category.

Who is a “manufacturer”?

According to article L541-10 of the French environmental code, you are considered to be a manufacturer if you put products on the market in France and fulfil at least one of the following conditions:

1. You produce products in France which are regulated by the EPR, and put these on the French market.2. You import products to France which are regulated by the EPR.3. You sell products with your own brand or your own name.

What do I have to do to fulfil the extended producer responsibility requirements in France?

Step 1: Register with PROs

Register with a Producer Responsibility Organisation (PRO) for each EPR product category for which you sell products; you will then receive your IDU number. The PROs are known as “éco-organismes” in France.

Please check with the relevant PRO or our service partner take-e-way to see if you need an authorised representative for a specific category.

Product categories which fall under EPR guidelines in France

	EPR category	Sub-category	PRO (name and link)
1	Electrical and electronic equipment (EEE)	Heat exchangers, screens, monitors, devices with screens larger than 100 cm², lamps, large appliances, small appliances, IT and telecommunications equipment, photovoltaic modules, pedal-assisted bicycles	1. Ecosystem 2. Ecologic 3. Soren
2nd class	Batteries (PA)	All types of portable batteries and rechargeable batteries	1. Corepile 2. Batribox
3	Packaging (EMPAP)	Household packaging, printed paper or graphic arts paper	1. Citeo2. Adelphe 3. Leko
4	Food packaging for professional use (EPRO)	Primary packaging for food	1. Citeo Pro
5	Furniture (EA)	Living room furniture, occasional furniture, bedroom furniture, bedding, office furniture, kitchen furniture, bathroom furniture, garden furniture, seating furniture, technical, commercial and contract furniture, upholstered furniture and bedding, textiles, decorative items	1. Ecomaison 2. Valdelia (professional only)3. Valobat
6	Textiles (TLC)	Clothing textiles, home textiles, footwear	1. Refashion
7	Tyres (PNEU)	Tyres	1. Alipur 2. GIE FRP 3. Tyval
8	Chemicals (PCHIM)	pyrotechnic products, fire extinguishers and fire-fighting equipment, hydrocarbon-based products, adhesives, sealants and repair products, material treatment and coating products, products for specialised maintenance or protective measures, general chemical products, solvents and thinners, biocides and phytopharmaceutical household products, household fertilisers	1. Pyreo 2. Ecopae 3. EcoDDS
9	Medical piercing accessories (DISP-MED)	Disposable lancets and lancet devices as well as lancet sleeves, pen needles, needles only, micro-pumps, transfer sets, catheters, all-in-one catheters, pens with fixed or retractable needles, syringes with fixed needles, injection devices, self-testing lancet devices, insertion aids without electrical and electronic components, insertion aids with electrical and electronic components, pumps with electrical and electronic components	1. Dastri
10	Tobacco and accessories (TABAC)	Cigarettes, loose tobacco, pipe tobacco, tobacco for water pipes, cigars, cigarillos, chewing tobacco, snuff, tobacco for heat-not-burn devices, oral tobacco	1. Alcome
11	Mineral or synthetic lubrication and industrial oils (LUB)	Oils for internal combustion engines and turbines, oils for gearboxes, oils for moving mechanisms, oils for compressors, multi-purpose oils, oils for hydraulic systems and shock absorbers, oils for electrical applications, oils for heat treatment, non-soluble oils for metalworking, oils used as heat transfer fluids	1. Cyclevia
12	Sport and leisure goods (ASL)	Bicycles, sporting goods and accessories	1. Ecologic
13	Do-it-yourself (DIY) and gardening items (ABJ)	Painting tools, power tools and equipment, DIY supplies including hand tools (other than the first two categories), products and equipment for garden maintenance and landscaping	1. EcoDDS 2. Ecologic 3. Ecomaison 4. Valobat
14	Construction products and materials (PMCB)	Mineral-based products and materials: Concrete and mortar or their constituents, lime, stones such as limestone, granite, sandstone and lava, burnt or raw earth, slate, bituminous mixtures or constituents for the manufacture of bituminous mixtures (excluding bituminous waterproofing membranes), aggregates, ceramics2. Other construction products and materials: Materials made of: metal, wood, plaster, plastics, bituminous membranes, glass wool, rock wool, mortar, coatings, paints, varnishes, resins, as well as preparation and application products, including their containers (except EPR chemical products), joinery products incorporating glass, glazed walls and related construction products, construction products of plant or animal origin, or other materials not listed in any other category	1. Ecominero 2. Valobat 3. Ecomaison 4. Valdelia
15	Toys (JOUET)	Toys, models, puzzles and board games	1. Ecomaison
16	Non-biodegradable synthetic chewing gum	non-biodegradable synthetic chewing gum	No PRO currently available.
17	Disposable hygiene textiles (TSUU)	Wet wipes for personal and domestic use, personal protective equipment, bed linen and clothing, paper hygiene products not falling under categories 1 and 2, hygiene and personal protective products	No PRO currently available.
18	Fishing equipment with plastic components	Fishing equipment containing plastic	No PRO currently available.

Step 2: Saving your IDU number(s) in the Seller Portal

As soon as you have received your IDU number(s) from the PRO and they are available in the ADEME Register, enter your IDU in the Seller Portal.

1. Shop settings: To make your products from the affected EPR categories available for sale on Kaufland.fr, enter your IDU number for each category in the Seller Portal in the Shop Settings in EPR compliance.

2. Legal notice: Please also list your registered IDU numbers in your legal notice. To do this, go to Legal texts in the Shop Settings.

Step 3: Quantity report to PRO

Sellers must regularly report the volume sold per category to their Producer Responsibility Organisation (PRO). The reported sales volumes (based on the number of items, volume or weight of the products sold) serve as the basis for calculating the environmental fees, which must be paid to the PRO by the due date. Depending on the PRO thresholds, sellers may be subject to either a simplified or a more detailed reporting scheme. For further information, please contact your responsible PRO or your service partner.

Step 4: Payment of eco-contributions

In addition to the quantity declaration, sellers must pay eco-contributions to their PROs, which can be read from the PROs’ individual price tables. These contributions are used to provide financial support for recycling and waste disposal programmes. The amount of the eco-contribution varies depending on the product category based on your sales volume report. As a seller, you are responsible for the accurate reporting and timely payment of contributions. For further information, please contact your responsible PRO or your service partner.

Step 5: Returns service

When is there an obligation to take back old products?

If you offer products from the following categories commercially in France, you are obligated to offer customers a take-back service for similar old products:

• Electrical and electronic appliances (including light bulbs)
• Batteries
• Packaging
• Furniture
• Tyres
• Products with chemicals
• Disposable gas cartridges
• Sport and leisure goods
• DIY and gardening items
• Toys

How are the take-back obligations regulated?

There are two types of take-back obligations if you are a seller in France selling products from the categories mentioned above:

By default, you are subject to a 1:1 take-back obligation if you sell the above-mentioned products commercially to end consumers in France. Whether you are subject to a 1:0 take-back obligation depends on the characteristics of your brick-and-mortar shops (e.g. the size of your in-store sales area). Seek legal advice to find out whether you are subject to a 1:0 take-back obligation.

Where do I have to enter the information for the take-back service?

You must provide information about take-back options in your general terms and conditions (GTCs) in the Seller Portal. To do so, go to “Legal texts” in the shop settings and click on the “Terms and Conditions” tab.

You are responsible for obtaining information about the take-back options offered by your responsible PRO.

What take-back policy do I need to offer for the relevant products in France?

As a seller, you must specify whether you offer take-back at the place of delivery, at a collection point or via free return shipping. Please also specify the corresponding take-back policy in your general terms and conditions (GTCs).

There are various options for taking back used products. Below you will find specific information on the take-back procedures for France, depending on the take-back options that you offer:

1. Take-back at the place of delivery:
   • If a customer buys a new product, you can take back the old product free of charge upon delivery of the new product.
   • Your GTCs must include information about take-back at the place of delivery and whether you offer this service.
2. Collection points for take-back:
   • You can refer customers to one of the collection points organised by environmental organisations to take back their old products. Here are some useful links:

Overview of the different product categories and the corresponding collection points for each EPR category in France	PRO	Link
Electrical and electronic equipment (EEE)	Ecosystem	Collection points for EEE
	Ecologic	Collection points for EEE
Batteries	Corepile	Collection points for batteries
	Batribox	Collection points for batteries
Packaging	Citeo	Collection points for packaging
	Adelphe	Collection points for packaging
Furniture	Eco-Mobilier	Collection points for furniture
Textiles	Refashion	Collection points for textiles
Tyres	Alipur	Collection points for tyres
Chemicals	EcoDDS	Collection points for chemicals

Alternatively, you can refer to the nearest waste disposal site or the “Encombrants” service of the respective municipality.

3. Free take-back via a return shipping label:
   • You have the option of offering free take-back of products via a return shipping label. 
   • The exact instructions for using the return shipping label and whether you wish to offer this option must be specified in your general terms and conditions.

Further obligations for EPR in France

1. Triman label for products and packaging

The Triman label is used to inform consumers that your products are recyclable and subject to specific sorting regulations. It is an essential part of the Extended Producer Responsibility in accordance with article L.541-9-3 of the Code de l’environnement. You can find more information here.

When is labelling mandatory?

All products sold to end consumers that fall under the extended producer responsibility (with the exception of glass beverage containers) must be labelled with the Triman logo and the corresponding Info-tri labels.

Where do the labels need to be affixed?

The Triman logo and the Info-tri labelling must be visibly affixed to the product, the packaging or in the documentation supplied with the product. For products with an area of less than 10 cm², the labelling can also be indicated on a digital medium (e.g. QR code).

What sanctions apply in the event of non-compliance with labelling obligations?

Failure to comply with the labelling requirements may result in administrative penalties in accordance with Article L.541-9-4 of the Environmental Code.

Can I replace the Triman logo?

Under certain conditions, sellers may replace the Triman logo with other symbols regulated in the European Union, provided they also inform consumers about the sorting obligations. Please contact the relevant PRO for more information.

2. Index for repairability and durability

What is the repairability index?

Repairability Index – Indice de réparabilité

The repairability index is mandatory for certain products and provides a rating on a scale of 0 to 10 to help consumers assess the repairability of the products they buy. The aim is to prevent disposing of products prematurely and to conserve natural resources. Please request the repairability index data for the products you offer directly from the manufacturer.

The index is mandatory for the following products:

• Corded vacuum cleaners
• Cordless vacuum cleaners
• Robotic vacuum cleaners
• Household dishwashers
• High pressure cleaners
• Smartphones
• Electric lawn mowers with cable
• Electric lawn mowers with battery
• Electric robotic lawnmowers
• Laptops
  

How is the repairability index calculated?

The repairability index is calculated on the basis of five criteria:

1. Documentation: Availability of technical documents for repair service providers and consumers.
2. Dismantlability:Ease of dismantling the product and the tools that this requires.
3. Availability of spare parts: Obligation of the manufacturer to ensure the availability and rapid delivery of spare parts.
4. Price of spare parts: Ratio between the price of spare parts and the product price.
5. Spezifische Kriterien: Special criteria that apply to the particular product category.

The repairability index is calculated from the scores of the individual criteria and reduced to a scale of 0 to 10. The detailed assessment shown in the table below must be made available to the consumer by the seller at the time of purchase.

How do I add the repairability index for selling with Kaufland Global Marketplace?

You can upload the information for the repairability index via CSV file, Marketplace Seller API or manually in the Seller Portal. The repairability index is provided with two important attributes:

• Score: The score is given as a numerical value and automatically displayed as a pictogram on the product details page (PDP) to enable a quick and clear assessment of repairability.
• Calculation table: The calculation table is provided as a PDF file. This table can be viewed on the product details page (PDP) by clicking on the repairability index, providing consumers with detailed information on the rating and the underlying criteria.

Attribute ID	Details
3831	Repairability Index (Shared Set)
3840	repairability_index_calculation (Calculation PDF table for repairability)

What is the durability index?

Durability Index – Indice de durabilité

The durability index has been mandatory for certain electrical and electronic products since 10th February 2020 and was introduced by Article 16-II of Law No. 2020-105, which deals with combating waste and promoting the circular economy. This index provides a rating on a scale of 0 to 10 and informs consumers about the sustainability of the products in question.

The aim of the sustainability index is to raise consumer awareness of how they can extend the life and use of their appliances. The hope is that customers will then be motivated to buy more reliable products that are less prone to failure and damage and are easier to repair.

The index is currently mandatory for the following products:

• Televisions
• Washing machines (top- and front loaders)

How is the durability index calculated?

The durability index for each product model is calculated on the basis of two main criteria:

• Repairability of the devices: This aspect takes into account the accessibility of the technical documentation, the ease of disassembly and the availability and price of spare parts.
• Reliability of the devices: Factors such as resistance to stress and wear, ease of maintenance and the existence of a commercial guarantee and quality process are taken into account.

The durability index is calculated from these two ratings and expressed as an overall rating from 0 to 10. The detailed assessment presented in the table below must be made available to the consumer by the seller at the time of purchase.

How do I add the durability index for selling with Kaufland Global Marketplace?

You can upload the information for the durability index via CSV file, Marketplace Seller API or manually in the Seller Portal. The durability index is provided with two important attributes:

• Score: The score is given as a numerical value and automatically displayed as a pictogram on the product details page (PDP) to enable a quick and clear assessment of durability.
• Calculation table: The calculation table is provided as a PDF file. This table can be viewed on the product details page (PDP) by clicking on the durability index, providing consumers with detailed information on the rating and the underlying criteria. The durability index is provided with two important attributes:

Attribute ID	Details
3833	Durability Index (Shared Set)
3841	durability_index_calculation (Calculation PDF table for durability)

Help with questions about the indices

If you have any questions about the repairability and durability indices, the following resources are available to you:

• Epargnons Nos Ressources: Here you will find comprehensive, general information about the indices, including the criteria and calculation methods.

What should you do if you are both a seller and a manufacturer?
If you are a seller who also manufactures your own products and are unsure how to obtain the repairability and durability indices, we recommend that you contact your Producer Responsibility Organisation (PRO) directly (read more under “Step 1: Registering with PROs”). These organisations can provide you with valuable information and support to help you identify the necessary data and calculate the indices correctly. You can also use the resources mentioned above to find out more.

3. Eco-Design Plan

The Eco-Design Plan is a central component of sustainable product development. It contains strategies for avoiding waste and optimising the environmental compatibility of your products. When drawing up your eco-design plan, you work closely with your responsible Producer Responsibility Organisation (PRO).

4. Eco-participation in France

Eco-participation is a key component of Extended Producer Responsibility (EPR) in France. It requires reporting and passing on waste management costs along the entire marketing chain of a product that is subject to extended producer responsibility.

In regard to eco-participation, which obligations do I have as a seller?

1. Manufacturers and sellers are obligated to bear the waste management and recycling costs of their products. This is done by charging an eco-participation fee, which is added to the item price and shown separately.
2. Manufacturers and sellers are obligated to state the unit disposal costs of separately collected waste on customer invoices. These unit costs correspond to the waste management costs of this waste and may not be discounted.
3. The eco-participation must be shown separately for each item, both on customer invoices and on the marketplaces.

How can I enter the eco-participation information in my offers?

You have three options for entering eco-participation information for Kaufland.fr:

5. EPR Management by Kaufland

Support for missing IDU numbers on Kaufland.fr

On Kaufland.fr, sellers must comply with French EPR requirements, including providing a unique identification number (IDU number) for each product category offered. To help sellers achieve compliance, Kaufland Global Marketplace offers the EPR Management by Kaufland service, which provides IDU numbers for selected categories.