France EPR UIN Registration Detailed Explanation

In France, packaging regulations impose strict supervision on enterprises. Any enterprise selling products in France must comply with these regulations. This article analyzes 10 common questions about the French Packaging Law to help sellers gain a clear understanding.

For cross-border business, compliance comes first. At present, Amazon, AliExpress, and TEMU have all mandated sellers to complete EPR compliance; otherwise, products will be forcibly removed from shelves.

EPR compliance has become an irresistible trend, and the French Packaging Law is one of the common requirements for sellers. According to the EU Packaging Waste Directive, any enterprise selling packaged goods to final consumers in France must register its packaging with a French recycling scheme.

Since there are many categories of French EPR, and the Packaging Law is required by almost all sellers, this issue provides a detailed explanation of the French Packaging Law for you.

What is the French Packaging Law?

The French Packaging Law is part of the Extended Producer Responsibility (EPR) regulations, aiming at sustainable development, waste prevention and management.

It requires any enterprise selling packaged goods to final consumers in France to register its packaging with an approved French recycling scheme. This rule applies to all packaging sold in France, regardless of its country of origin, with the following requirements:

1.1 Registration and Licensing Requirements

All enterprises selling goods cross-border to France, including those based outside France (such as cross-border sellers), must comply with the French Packaging Law.

1.2 Unique Identification Number (UIN)

Since 2022, the French Environment and Energy Management Agency (ADEME) has assigned a Unique Identification Number to all companies complying with French recycling laws. This number is obtained from the French recycling scheme where the company registers its packaging license and is used to verify compliance.

1.3 Packaging Marking Obligation

France has introduced the Triman logo, a unique recycling symbol for recyclable packaging in France. Foreign companies selling goods to French consumers are also required to use this logo.

1.4 Recycling and Reuse

French packaging waste must be separately collected and enter the recycling process. Similar recycling systems apply to electronic products, batteries, textiles, etc., which must also be registered with competent authorities and recycling schemes.

1.5 Fees and Responsibilities

Manufacturers, importers and retailers pay recycling fees based on annual volumes. These fees support the French recycling system and ensure proper disposal of packaging waste.

How to Determine Whether Registration Is Required?

You can judge based on your business type and product sales:

• Producer: Required to register if you package products originating in France, or products under your brand, unbranded or private-label products.

• Importer: Required to register if you import packaged goods from abroad for resale in France.

• Retailer: Required to register for service and transport packaging, or if acting as an importer.

• E-commerce Platform: Required to register if products sold by third-party sellers on your platform have not declared EPR for packaging.

Currently, Amazon, AliExpress, TEMU and other platforms have forced sellers to register for the French Packaging Law. Non-compliance may lead to product removal or even store suspension. Some categories are subject to direct withholding and payment by platforms.

Is Self-Registration or Platform Withholding More Cost-Effective?

According to official requirements, to stop using platform withholding services, you must submit a valid UIN and pass verification.

Taking the French Packaging Law as an example:

• Self-registration cost = Registration fee + Recycling fee

• Amazon withholding cost = Amazon service fee (24.99 + 3% of recycling fee) + Recycling fee

For sellers with low sales volume, withholding is more cost-effective. As sales volume increases, self-registration becomes more economical. Sellers can calculate their break-even point; beyond that threshold, self-registration is recommended.

In addition, platform withholding is only a transitional compliance solution. Full French EPR compliance requires affixing the Triman logo. During customs or EU inspections, the Triman logo usually requires supporting certification. Sellers using platform withholding do not have their own French EPR certificate number and may face risks or penalties due to non-compliance.

In summary, in terms of both environmental tax costs and regulatory requirements, self-registration is more cost-effective and ensures complete and secure compliance in the long run.

What is the Triman Logo?

The Triman logo is France’s official recycling symbol. Starting from January 1, 2022, it replaced the Green Dot logo, standardizing and expanding the scope of products requiring marking.

Its purpose is to help consumers better understand waste sorting. Products and packaging marked with Triman are collected in dedicated waste bins. Without the logo, products will be treated as general waste.

Which Products Need the Triman Logo?

All packaging must be printed with the Triman logo. Every independently sold product destined for France must display the logo on its packaging.

The complete marking consists of four parts:

1. Triman logo

2. Country code (not required if only sold in France)

3. Label indicating the recyclable part of the packaging (for packaging only, not the product)

4. Waste bin label: green bin for glass, yellow bin for non-glass materials

How to Achieve Full Compliance with the French Packaging Law?

Standard compliance requires four steps:

1. Register with an approved recycling company
In France, the UIN registration code and recycling service are provided by the same organization. After submitting materials, you will receive a UIN.

2. Upload LUCID number to e-commerce platforms
Upload your EPR number to the corresponding section as required by the platform. Allow time for review.

3. Purchase recycling weight and file regular declarations
Report the weight of packaging materials sold in France to ADEME annually and pay corresponding environmental responsibility fees.

4. Print the Triman logo
All product packaging sold in France must bear the Triman logo and recycling instructions to be legally marketed.

What Is the French Packaging Law Registration Process?

1. Prepare registration materials.

2. Submit registration application with required documents.

3. Estimate types and volumes of packaging materials and develop a recycling plan.

4. After registration, declare the weight and type of sold packaging materials at the beginning of each year based on the previous year’s sales. JJR can assist with the process.

Required materials: company information, business license, contact details, product information, etc. (Specific documents are subject to the service provider’s requirements.)

How to Upload EPR Registration Numbers to Platforms?

8.1 Amazon

Log in to your seller account via:
https://sellercentral.amazon.de/spx/myc/epr-compliance?ref=hp_compport_epr1
Enter the UIN for French Packaging Law in the compliance portal, submit and wait for review.

8.2 TEMU

Log in to Cross-border Seller Center →
【Account Management】 →
【Entity Details】 →
【Extended Producer Responsibility Qualifications】 →
【Add Registration Number】

Select Country/Region: France, choose qualification type, enter the French EPR registration number, then click 【Submit for Review】 → 【Confirm】.

UIN format: FR + 6 digits _ 6 digits + letters

8.3 AliExpress

Submit EPR compliance number per store via:
【Account & Authentication】 > 【My Information】 > 【European Environmental Fee Registration & Declaration】

Or direct link:
https://gsp.aliexpress.com/apps/epr/addspm=5261.26487584

How Long Is the French Packaging Law Valid?

The Packaging Law follows a calendar year cycle (January 1 – December 31). Validity expires on December 31 of the same year regardless of the registration month.

Ecological organizations (recycling companies) usually require written confirmation of renewal by October 31 each year. No response after that date means automatic renewal.

Failure to renew on time will result in invalidation of the EPR number and applicable cancellation fees. Sellers must still complete declarations and pay fees before account cancellation.

Note: 2025 EPR renewal is now underway. Please complete renewal or cancellation promptly to avoid store disruptions.

How to Choose a France EPR UIN Registration Service Provider?

1. EPR service fees generally include: registration fee + declaration fee + regular environmental recycling fees. Pay attention to reminders and collection notices from recycling companies.

2. Before purchasing services, ask three key questions:

￮ How much recycling weight is included?

￮ Is declaration based on actual purchased recycling weight?

￮ How long does it take to obtain the UIN?
Clarify service contents to avoid unexpected costs.

3. Choose providers with transparent pricing and official agency qualifications. Prefer those with direct access to local PROs and recycling institutions for reliability.

Environmental supervision in France is strict, and EPR requirements across Europe are becoming increasingly stringent. Cross-border sellers are advised to fulfill compliance obligations to avoid disruptions to normal store operations.