Introduction to EPR
Extended Producer Responsibility (EPR) legislation is part of a Europe-wide initiative to protect the environment by improving waste management, limiting the use of landfills, and stimulating innovation in recycling. These measures make sellers responsible for the entire life cycle of their products.
The Law against Waste and for the Circular Economy, dated February 10, 2020, established the legal framework for extending the liability of producers, importers and sellers for the entire life cycle of products they sell to buyers based in France, including their end-of-life.
Since July 1, 2022, all marketplaces, including eBay, have been legally required to make sure that sellers are complying with EPR regulations. By getting in line with these laws you’ll be showing your customers that you’re supporting recycling initiatives in France and playing your part in contributing to a circular economy.
From October 1, 2022, eBay takes action on listings that don’t comply with the regulations, including paying the ‘eco-participation fee’ on your behalf and invoicing it back to you, as mentioned in eBay User Agreement update in August, 2022.
Business sellers who list new items in certain categories on ebay.fr will need to add extra information to their listings.
To comply with this law, you’ll need to provide the following information when creating listings for your new items in certain categories:
If you do not have the EPR information to add to a listing:
- If you are not the producer or first importer of the item in France, reach out to its producer if the item is produced in France or to its 1st importer of the item in France.
- If you produce the item in France or import the item in France you need to register with the relevant Producer Responsibility Organizations (PRO).
- If you pack and ship the item, you will regardless have to register with one of the packaging/shipping PROs.
A Producer Responsibility Organization (PRO) or “eco-organisme” is a company approved by the public authorities, within the framework of Extended Producer Responsibility, to manage the end-of-life of the equipment they put on the market (collection, sorting, recycling, and recovery of waste).
To understand which PROs you have to register with in order to contribute to the recycling of your products, you can:
- Check the indicative list of relevant recycling eco-organismes below
- Visit the French Agency for Ecological Transition (ADEME) website: in English or in French
- Consult your legal advisor
- Reach out to a third party representative
Registration allows you to contribute to the recycling of your items by paying a recycling fee based on your declaration of volumes sold to France-based sellers. Some third party vendors can help you quickly register with several eco-organisms and get the UIN.
Eligible categories
| EPR categories schemes | Relevant recycling PROs (eco-organismes)* |
|---|---|
| Electrical and Electronic Equipment (EEE) | ecologic-france.com ecosystem.eco/en soren.eco (photovoltaic panels only) |
| Furnishing items (including upholstered seat or sleeping products and textile decorative items) | ecomobilier.fr / ecomaison.com valdelia.org |
| Packaging | citeo.com leko-organisme.fr adelphe.fr |
| Textiles (clothing products, new footwear or household linen, new textile products for the home) | refashion.fr/pro/fr |
| Batteries and accumulators | corepile.fr screlec.fr |
| Contents and containers of chemicals | ecodds.com ecosystem.eco/en (fire extinguishers only) pyreo.fr (flares only) |
| Printed papers and papers for graphic use | citeo.com |
| Construction products or materials | valobat.fr ecomobilier.fr / ecomaison.com (non inert only) ecominero.fr (non inert only) valdelia.org (inert only) |
| Toys | ecomobilier.fr / ecomaison.com |
| Sports and leisure articles | ecologic-france.com |
| DIY and garden items | eco-mobilier.fr / ecomaison.com ecologic-france.com (internal combustion engine equipment only) ecodds.com (paint accessories only) |
| Mineral or synthetic, lubricating or industrial oils | cyclevia.com |
| Tires | aliapur.fr/fr gie-frp.com avpur.re (La Réunion only) ardag.site-fr.fr (Guyane only) entreprisesenvironnement.com (Martinique only) tdaguadeloupe.fr (Guadeloupe only) |
| Tobacco | alcome.eco |
| Boats | recyclermonbateau.fr |
| Medications / drugs | cyclamed.org |
| Syringes / auto-tests | dastri.fr |
| Vehicles | No eco-organism mandated |
| Foodservice packaging | Planned for 2023 |
| Chewing gums | Planned for 2024 |
| Sanitary textiles | Planned for 2024 |
| Fishing | Planned for 2025 |
| Industrial packaging | Planned for 2025 |
Unique Identification Number (UIN)
eBay has set up fields for the information required under each of these obligations during the listing process.
You can find your UINs (also called "SYDEREP" number, or UDI in French) by either contacting the producer in or first importer into France or, if you are the producer in or first importer into France, by registering with the adequate PROs. These UINs prove that you are registered and that you contribute to recycling for your item.
If you’re listing an item concerned by an EPR category, make sure you include the required UIN(s) in the following fields:
- Producer Product ID — proof of registration of the producer in or first importer into France of the product with a relevant eco-organisme, if the item is covered by the EPR. For example you input:
- A UIN from the Furniture vertical (EA — “élément d’ameublement”) for a Furniture item
- A UIN from the Electronics/Appliance vertical (3E or “équipements électriques et électroniques”) for an Electronic or Appliance item
- A UIN from the Textile vertical (TLC — “textiles”) for a clothing or piece of linen
- Product Package ID — proof of registration of the producer in or first importer into France of the product packaging with an eco-organisme of the packaging sector.
- This field is where you input the UIN from the packaging vertical (EMBM — “emballage ménagers”) for the primary packaging of the item (for example the blister or the product box).
- Shipping Package ID (if applicable) — proof of registration of the producer in or first importer into France of the shipping package with an eco-organisme of packaging sector.
- This field is where you input the UIN from the packaging vertical (EMBM — “emballage ménagers”) for the secondary packaging of the item (for example the cardboard box used for shipping). It is likely the same as the Product Package ID if you are registering for both.
- Product Document ID (if applicable) — proof of registration of the producer in or first importer into France of any paper documentation added with the item/parcel with an eco-organisme of the paper sector.
- This field is where you input the UIN from the printed paper vertical (PAP — ‘’papier imprimé”) for the leaflet that might be contained or sold with your product (e.g. instruction manual).
How to add UINs
When you create or update a SINGLE listing
- On www.ebay.fr choose either to create a new listing or to revise an existing listing: сlick on Selling (Mes ventes) or go to the Listing tab (Annonces) in Seller Hub (Hub vendeur).
- Go to the Seller Disclosures (Conditions du vendeur) section and click Select your conditions (Sélectionner vos conditions).
- Choose Extended Producer Responsibility (Responsabilité élargie du producteur).
- Enter your item’s unique identifiers in the relevant UIN fields:
- Producer Product ID (Code produit du fabricant)
- Product Package ID (Code de l'emballage du produit)
- Shipping Package ID (Code de l'emballage d'expédition)
- Product Document ID (Code du document du produit)
- Confirm by clicking Done (Terminé).
When you create or update listings in BULK or through APIs
1. On www.ebay.fr, to create a new listing or revise an existing one, сlick on Selling (Mes ventes) or go to the Listing (Annonces) tab in Seller Hub (Hub vendeur).
2. Select all listings that you want to update and click on Update selection (Modifier la sélection).
3. Select Modify several listings simultaneously (Modification de plusieurs annonces simultanément).
4. Go to the Listing details (Détails de l’annonce) section and click Seller disclosure (Conditions du vendeur).
5. Select Replace with (Remplacer par) for the relevant UIN fields:
- Producer Product ID (Code produit du fabricant)
- Product Package ID (Code de l'emballage du produit)
- Shipping Package ID (Code de l'emballage d'expédition)
- Product Document ID (Code du document du produit)
Then enter the value in the corresponding field. You can also here select your own Business Policies in the corresponding field, if you created any.
6. Confirm by clicking Done (Appliquer).
None of those UINs will appear on the listing. They are however used by eBay to acknowledge that the item is compliant with French EPR laws. eBay checks each UIN against the database of ADEME to confirm its authenticity.
Eco Participation fees
If you’re listing in specific categories (e.g. Furniture, Appliance, Electrical and electronic equipment (EEE) — not exhaustive), enter the recycling amount in the Eco Participation field. The amount will be automatically displayed on the view item page.
You can find the Eco fees amount for your product by either contacting your supplier (producer in or first importer in France) or, if you are the producer or importer in France, by registering with a relevant eco-organism (PRO). Through the registration process, the eco-organism will provide the relevant fees grid for the categories concerned. Thе eco-contribution is indicated by the eco-organism based on past declarations and payments.
How to add the Eco Participation fee when you create or update a single listing:
- On www.ebay.fr choose either to create a new listing or to revise an existing listing: сlick on Selling (Mes ventes) or go to the Listing tab (Annonces) in Seller Hub (Hub vendeur).
- Go to the Seller Disclosures (Conditions du vendeur) section and click Select your conditions (Sélectionner vos conditions).
- Choose Extended Producer Responsibility (Responsabilité élargie du producteur).
- Add a value to the Eco fee (Frais d'éco-participation) field if you were subjected to a fee.
- Confirm by clicking Done (Terminé).
You can also add the Eco Participation fee when you create or update listings in BULK or through APIs, the process is similar to filling out the UIN field.
Repair score
The repair score lets buyers know how easy it will be to maintain or repair a product. The product will get a rating of 1 to 10, where 1 is seen as not very repairable and 10 as highly repairable.
You can display the repair score in the Photo Gallery of your listing. You should also add the scoring grid used to determine the repair score in the Photo Gallery or item description to help buyers understand your product's rating.
You can find the repair score for your product by contacting your supplier (producer/importer in France).
The repair score applies to the following categories:
- Washing machines with windows
- Smartphones
- Laptops
- Televisions
- Electric lawnmowers
- Top-loading washing machines
- Dishwashers
- Vacuum cleaners
- High pressure cleaners
According to the law, this list may evolve in the future. To learn more visit the Ministry of Ecological Transition (Ministère de la Transition Écologique) website. Information in English is provided at the end of the page.
Take-back policy
When listing in the below categories, you're obliged to take back the buyer’s used product free of charge depending on the turnover thresholds and if the buyer is based in France.
- Electrical and electronic equipment
- Furniture elements, including upholstered seating or sleeping products
- Contents and containers of chemical products (if your annual turnover associated with this category exceeds 100,000 euros)
- Single-use fuel gas cartridges
- Pyrotechnics and fire extinguishers
- Toys, sports and leisure articles, and garden and DIY articles (if your annual turnover associated with this category exceeds 100,000 euros)
This obligation is different between smaller and larger old items (indicative only, please ask the PRO (eco-organisme) for exact requirements):
- Smaller items can be disposed of by your buyers by dropping them in collection points, you just need to indicate these collection points in your policy.
- Larger items require you to organize a service to collect those bulky items at the address of the buyer. Some dedicated carriers offer those services and manage the disposal of those items in agreement with the PROs. It can happen on delivery of the new item.
Setting up take-back policies for your listings
How to create your take-back policy on the eBay desktop site
1. Log on to www.ebay.fr with your login credentials.
2. Under My eBay (Mon eBay), select Summary (Récapitulatif).
3. Select the Account (Compte) tab.
4. Go to Selling (Mes ventes) and select Seller disclosures (Conditions du vendeur).
5. Select Create (Créer) and choose Take-back of old items (Reprise des anciens produits).
6. Enter the contents of your disclosure and select Save (Enregistrer).
Please note: Once you created and saved your policy, don’t forget to link it to all listings you want to apply it to.
How to create or or update a SINGLE listing with a take back policy
1. On www.ebay.fr choose either to create a new listing or to revise an existing listing: сlick on Selling (Mes ventes) or go to the Listing (Annonces) tab in Seller Hub (Hub vendeur).
2. Go to the Seller Disclosures (Conditions du vendeur) section and click Select your conditions (Sélectionner vos conditions).
3. In the field Take-back of old items (Reprise des anciens produits), select the take-back policy you want to apply to the listing.
4. Confirm by clicking Done (Appliquer).
How to create or or update listings with a take back policy in BULK or through APIs
1. On www.ebay.fr choose either to create a new listing or to revise an existing listing: сlick on Selling (Mes ventes) or go to the Listing (Annonces) tab in Seller Hub (Hub vendeur).
2. Select all listings that you want to update and click on Update selection (Modifier la sélection).
3. Select Modify several listings simultaneously (Modification de plusieurs annonces simultanément).
4. Go to the Listing details (Détails de l’annonce) section and click Seller disclosure (Conditions du vendeur).
5. In the field Take-back of old items (Reprise des anciens produits), select Replace with (Remplacer par) and choose the take-back policy you want to apply to your listings.
6. Confirm by clicking Done (Appliquer).
Using Excel files to manage EPR information fields in your listings
How to create new listings in bulk by uploading an Excel file
1. Log on to www.ebay.fr with your login credentials.
2. Go to the Reports (Rapports) tab in Seller Hub (Hub vendeur).
3. In the Uploads (Chargements) tab, follow the steps required to download, complete and publish the file.
Depending on the selected categories, the corresponding columns where you’ll have to enter your data, will show, if applicable.
How to update existing listings in bulk by uploading an Excel file
Listings without variations
1. Сreate a new file called “Revise”, aimed to update one or more existing listings. This file must include the following columns:
- Action: Revise
- ItemID (listing data)
- TakeBackPolicyID (required as part of the EPR regulations)
- ProductCompliancePolicyID (required as part of the EPR regulations)
- EcoParticipationFee (free values to fill in)
- ProducerProductID (free values to fill in)
- ProductPackageID (free values to fill in)
- ShipmentPackageID (free values to fill in)
- ProductDocumentationID (free values to fill in)
2. Use a new row for each listing you want to update.
3. Once you’ve entered all relevant data, save the file as a CSV format. You will then need to upload this file on your eBay account.
4. Log on to www.ebay.fr with your login credentials.
5. Go to the Reports (Rapports) tab in Seller Hub (Hub vendeur).
6. In the Uploads (Chargements) tab, upload the template.
You can check if the file has been uploaded correctly by clicking on Download results (Résultats du téléchargement) at the page bottom. For each revised row (each listing), a report will confirm if the update has been successful (“success”) or not (“error”), specifying the error.
Listings with variations
For listings with variations (i.e. different sizes, weights, colors — for one item), you can follow the same process, creating a Revise file. You’ll then have parent rows and children rows for each item ID.
- The parent rows will indicate the following EPR data:
- TakeBackPolicyID
- ProducerProductID
- ProductPackageID
- ShipmentPackageID
- ProductDocumentationID
- The children rows will indicate the EcoParticipationFee.
Important: The parent row will appear in Action Revise, while the children rows will be in Action Add.
The file upload process is the same as for the general file. To review the results of uploading files on eBay, go to the Reports (Rapport) tab, then open the Uploads (Chargements) tab.
You’ll be able to see a list of the most recently completed uploads. For each one of them, you can download the upload results. A new file will then open, showing for each listing whether or not the update was completed correctly.
There are 3 possible results:
- Success: the data has been correctly added/updated.
- Warning: the data has been added/updated correctly, and eBay is sending you an informative warning only.
- Failure: the data has not been added/updated correctly, an error code and a reason will be shown.
Useful links
Law
The French Agency for Ecological Transition (ADEME)
- Website (in English)
- Website (in French)
- Information from ADEME on EPR (in French)
- List of PROs (in English)
- List of PROs (in French)
The Ministry of Ecological Transition