Professional sales packaging:
bottles, blister packs, ampoules, tubes, sachets, individual cardboard boxes and other packaging used exclusively in professional channels.
EPR scheme for professional packaging
Twiice’s solutions for the healthcare sector
Healthcare packaging combines demanding requirements for sterility, product protection, traceability and regulatory compliance. Multi-material structures and validated packaging systems can limit straightforward substitutions.
Twiice helps healthcare stakeholders identify the flows that can change without compromising product safety and prepare for the EPR scheme for professional packaging (EPRO).
Does EPR apply to companies in the healthcare sector?
Healthcare companies are subject to the scheme as soon as they place products on the French market in packaging covered by the EPR scheme for professional packaging (EPRO).
However, the diversity of distribution channels makes classification particularly sensitive: pharmacies, hospitals, clinics, testing laboratories, healthcare professionals, specialist distributors and patients may all receive products from the same portfolio.
One of the first challenges is therefore to identify precisely which packaging falls under the professional packaging scheme and which falls under another scheme, and then to determine who is responsible for placing it on the market.
Packaging in scope
Depending on their function, their destination and the applicable regulatory criteria, EPR may cover, in particular:
Grouped packaging:
cardboard boxes, grouping boxes, plastic crates, trays and other formats used to group several units.
Transport packaging:
pallets, pallet-wrapping film, covers, protective materials, cushioning, crates and other packaging used to secure logistics flows.
Not sure about your situation?
Our packaging flow analysis helps you identify precisely your status as a producer placing packaging on the market and the packaging flows covered by EPR.
Sector-specific challenges
Distinguishing household from professional packaging
Hospitals, clinics, pharmacies, laboratories, medical practices, specialist distributors and patients: the same product portfolio can follow very different channels.
EPR classification therefore cannot rely solely on the product category or on the fact that it belongs to the healthcare sector.
It requires cross-checking the packaging’s function, its format and the channel through which it is placed on the market, so that each flow can be allocated to the right scheme.
For companies with thousands of product references or presentations, this mapping is one of the main preparatory steps towards compliance.
Changing packaging without compromising product safety
In healthcare, some packaging performs a regulatory or technical function directly linked to the product.
A sterile barrier system must maintain the sterility of a device until it is used. Pharmaceutical packaging must preserve the stability and quality of the medicine. Some packaging also carries tamper-evident, temperature-control or identification features that help secure the supply chain.
Changing a material, thickness, closure or structure may therefore require testing, revalidation or a regulatory change process.
The challenge is to distinguish highly constrained packaging from components that can be changed more quickly.
Finding the right opportunities for reduction, recyclability and reuse
Not all healthcare packaging offers the same circularity potential.
A glass bottle, a blister pack, a grouping carton and a logistics crate cannot be transformed according to the same criteria.
The priority is therefore to segment flows according to their function and level of constraint: preserve what is necessary for product safety and quality, simplify what can be simplified and look for the best levers for reduction, recyclability or reuse on suitable flows.
In many cases, the first opportunities lie in secondary, grouped or transport packaging, before touching the packaging directly associated with the product.
Linking regulatory traceability and packaging data
Batch numbers, expiry dates, serialisation of certain medicines and device identifiers: healthcare companies already work in an environment where traceability is highly structured.
EPR adds another layer of information: the packaging’s function, material, weight, household or professional status, reusability and the data required for declarations.
The challenge is therefore not to build a parallel traceability system, but to identify the right data in existing systems and connect it to EPR processes.
What EPR changes for your company
If you are a producer placing packaging on the market
Any company that packs, has products packed or imports packaged products intended for professionals may be considered a producer placing packaging on the market. When the scheme comes into force, you will need to:
- join an approved eco-organisation;
- obtain a Unique Identifier (IDU);
- declare the quantities of packaging placed on the market;
- pay the corresponding eco-contributions.
If you are a professional packaging waste holder
Healthcare facilities, laboratories, warehouses and other professionals that unpack or use products are packaging waste holders. You will need to:
- sort your packaging waste in accordance with the regulations;
- organise its management and collection;
- keep evidence of collection and treatment;
- favour reuse wherever possible.
Waste holders are not required to join an EPR scheme for the packaging they receive, but they play an essential role in reuse, sorting and recovery.
Special cases
Several situations that are common in healthcare require careful classification:
- product references or ranges distributed through both professional channels and to patients;
- the division of responsibilities between the marketing authorisation holder and the exploitant;
- imports into France of medicines, medical devices, active ingredients or consumables that are already packaged;
- grouped and transport packaging associated with units that fall under another EPR scheme;
- a large number of references, presentations, pack sizes or configurations for the same product;
- products that combine a medicine, a device and accessories in the same pack.
EPR responsibility must be assessed according to the role of each stakeholder and the flow concerned.
Twiice’s expertise for the healthcare sector
Sterile barriers, pharmaceutical packaging, logistics packaging: the scope for change is not the same from one flow to another.
Twiice’s approach is to classify these flows to distinguish what is constrained from what can change, and to focus compliance and circularity actions where they are relevant.
Understand EPR and map your packaging flows
Multiple references, professional and patient channels, primary, secondary and logistics packaging: Twiice maps your flows to identify the packaging in scope, its status and the data to declare. This gives you a reliable, usable EPR scope.
Secure your compliance
Quality, regulatory affairs, procurement, packaging, supply chain: the data needed for EPR is often spread across the company. Twiice helps you gather and structure the relevant data (weights, materials, destinations, flow classification) and integrate it into a reliable declaration process.
Prioritise the packaging to change
Not all packaging offers the same scope for change. Twiice distinguishes packaging that is highly constrained by product safety or quality from flows that offer more room for manoeuvre. This analysis makes it possible to target the reduction, recyclability and reuse projects that are genuinely achievable.
Reduce and optimise your eco-contribution
Twiice analyses your packaging in light of eco-modulation levers: material reduction, recyclability, recycled content or reuse. The aim is to identify the changes that combine technical and regulatory feasibility, environmental benefit and eco-contribution optimisation.
Support that matches your needs
Twiice offers three levels of support depending on the complexity of your flows and your ambitions. A business with a limited range of packaging? Move forward independently with the Compliance pathway. Several ranges, channels or sites, with data spread across quality, regulatory affairs, procurement and supply chain? Structure your organisation with the Organisation pathway. A complex portfolio and challenges around eco-design, recyclability or reuse? Take action with the Transformation pathway.
With Twiice, everything is simpler.
Join TwiiceTwiice’s financial support for the healthcare sector
Improve sorting at source and collection
Packaging waste assessment
A partner expert maps your plastic packaging flows on site, analyses your practices and identifies priority levers for reduction, reuse and recycling. The outcome: an operational roadmap.
For producers placing packaging on the market and waste holders (funded by Twiice)
Sorting at source
Setting up separate sorting on your sites, with guidance adapted to plastic packaging in the healthcare sector, team support and consolidation of flows towards recycling channels.
For producers placing packaging on the market and waste holders (funded by Twiice)
Equipment purchases
Support for purchasing pre-collection equipment to improve the separation, storage and management of plastic packaging flows on your sites.
For producers placing packaging on the market and waste holders (funded by Twiice through calls for projects)
Optimise the overall performance of plastic packaging
Awareness & Communication Kit
Educational tools and suitable signage to help your teams apply good practices for sorting and managing plastic packaging.
For producers placing packaging on the market and waste holders (produced by Twiice)
Industrial investment
Support for targeted investment to improve the collection, sorting and treatment of professional plastic packaging.
For producers placing packaging on the market and waste holders (funded by Twiice through calls for projects)
Eco-design
Recycled plastic incorporation / IMPR
Do you incorporate recycled plastic into your packaging? Twiice funds traceability audits to certify your recycled content rates and access the premium: up to €1,000 per tonne for resins that are difficult to recycle.
For producers placing packaging on the market and waste holders (funded by Twiice)
MyRecycledContent
Looking to secure your supply of recycled plastics? MyRecycledContent, our responsible purchasing platform, connects you with a network of qualified suppliers offering certified packaging that incorporates recycled materials.
Discover all of Twiice’s solutions and financial support for producers placing packaging on the market and packaging waste holders in their reuse, collection and recycling initiatives.
News
- PPWR 12 Aug 2026
PPWR: the European regulation changing the rules for your packaging
The PPWR entered into force on August 12, 2026. This European regulation updates the rules governing packaging to make it more recyclable, reusable, and sustainable. Find out what is changing and the deadlines to anticipate.
- EPR scheme 19 Aug 2026
The EPR scheme for professional packaging: the date is set for 1 January 2027
The Extended Producer Responsibility (EPR) scheme for professional packaging has been postponed to January 1, 2027. This delay is intended to clarify the implementation details and provide greater visibility for businesses.
- Circular economy
- EPR scheme
- Projects & innovation 18 Mar 2026
Meeting the challenge of recycling expanded polystyrene (EPS)
To mark Global Recycling Day, Twiice wanted to highlight a very real challenge for professional packaging: recycling expanded polystyrene (EPS).
Reading time: 5mins approx.
Read article Meeting the challenge of recycling expanded polystyrene (EPS)Turn your EPR obligations into opportunities.
Twiice helps healthcare stakeholders identify the scope for change that is compatible with their products’ requirements, and turn EPR into a performance driver.
FAQ
Are companies in the healthcare sector subject to the EPR scheme for professional packaging?
Yes, when they place products on the French market in packaging that falls within the professional scope.
The difficulty lies in particular in the diversity of distribution channels: a company may sell some product references exclusively to professionals and others to patients or households.
It is therefore necessary to classify packaging and its channels precisely, rather than treating your entire portfolio as a single, uniform flow.
Is packaging for medicines or medical devices covered?
Yes, some may fall under the EPR scheme for professional packaging, depending on how they are classified under the regulations.
The fact that a medicine or device is used by a healthcare professional is not enough on its own to classify its packaging as professional packaging. Each packaging item must be analysed according to its function, characteristics and distribution channel.
The associated grouped and transport packaging must also be classified separately.
Does the EU packaging regulation impose the same recycled content requirements on all healthcare packaging?
No.
The EU packaging regulation provides, in particular, for exemptions from the minimum recycled content targets for certain categories, such as the immediate packaging of medicinal products and certain contact-sensitive packaging for medical devices or in vitro diagnostic medical devices.
These exemptions do not mean that the packaging is excluded from EPR. They do show, however, that the path towards circularity must take account of the packaging’s function and specific constraints.
Why is traceability a particular challenge in the healthcare sector?
Because healthcare companies already have highly structured traceability systems built around products, batches and, depending on the product, specific identifiers.
EPR introduces additional data on packaging: type, function, materials, weight, status and end-of-life destination.
The challenge is to link this information to existing reference systems rather than create an entirely separate EPR database.
Can I be both a producer placing packaging on the market and a waste holder?
Yes.
For example, you may be responsible for some packaging that you place on the market while also holding packaging received with raw materials or products used on your own sites.
These two responsibilities relate to different flows and can apply at the same time.
Are you looking for a quick answer?
Check out our FAQs or start a conversation with Eliia, our AI agent.
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Transport & logistics
At the heart of packaging flows, the sector plays a key role in traceability, reuse and putting packaging back into circulation.