Frequently asked questions

The EPR scheme for professional packaging comes into effect on 1 January 2027. Companies concerned should therefore prepare in advance by identifying their professional packaging, collecting the necessary data and organising their declaration process.

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.

No. Manufacturing packaging is not enough on its own to determine EPR responsibility. Status depends in particular on the packaging type, the conditions under which it is made available and, in some cases, the brand under which it is sold. A manufacturer may therefore be an EPR producer for some flows and simply a supplier for others.

EPR targets are generally not defined by business sector, but by packaging type and use. The targets presented here are those set at national and European level for the scheme as a whole. Certain flows are nevertheless subject to specific targets or exemptions, including transport packaging for dangerous goods.

The two frameworks coexist, but their targets are not cumulative. French reuse targets apply until 2027, while from 2030 the PPWR introduces new European targets differentiated by packaging type and use.

No. Local authorities act as partners in the scheme and can benefit from the mechanisms provided for in the specifications without joining Twiice. They must nevertheless sign an agreement with Twiice to do so.

Yes, if it places packaged chemical products intended for professionals on the French market, whether it is a resin or raw material producer, formulator, co-packer, distributor or logistics provider.

Both are possible, depending on your activity. A company that packs or repacks products under its own brand is likely to be a producer placing packaging on the market. A company that receives products already packaged by its suppliers for its own use is a waste holder. Our packaging flow analysis helps you clarify your situation independently. For complex cases, our team is here to advise you.

The French Environmental Code (Article L. 541-9-5) provides for several administrative and financial penalties for failure to comply with EPR obligations:
– a fine of up to €7,500 per unit or tonne placed on the market;
– a daily penalty payment of up to €20,000 until the situation is remedied;
– a fine of up to €30,000 for failure to register in SYDEREP (the French national EPR register), incorrect data or absence of a Unique Identifier (IDU).

Your Unique Identifier (IDU), issued by ADEME and provided by Twiice once you have joined, is evidence of your EPR compliance. It serves as proof of declaration to the public authorities and your customers. It must appear in your General Terms and Conditions of Sale.

Producers placing packaging on the market must join an approved eco-organisation, declare the volumes of packaging they place on the market each year, and finance waste management through the eco-contribution. EPR is not a voluntary initiative: it is a legal obligation governed by the French Environmental Code.

Manufacturers of transport, service or primary-production packaging must declare the packaging they manufacture, unless it is produced under another company’s name or brand, in which case the principal is responsible. All packaging manufacturers are responsible for the sales or grouped packaging in which they ship the packaging they manufacture.

If you only use packaging customised with your clients’ brands, those clients are responsible for declaring their packaging. However, if you handle packaging under your own name or brand, you are responsible for that packaging.

Yes. French subsidiaries and branches are subject to the scheme for imports of which they are not the end user and for the packaging they place on the market in France.

Yes. The principal is considered the producer. If production or packaging is subcontracted, the principal, not the subcontractor, declares the packaging and pays the eco-contributions.

Yes. If you entrust the production or packaging of your products to a subcontractor, you are responsible for declaring the packaging and paying the eco-contributions. The subcontractor is not liable for these obligations.

Both are possible, depending on the activity. For example, a garage that distributes spare parts under its own brand is likely to be a producer placing packaging on the market. A garage that receives products packaged by its suppliers is a waste holder.

The producer placing packaging on the market: the entity that packs, has packed or imports the packaged product intended for professionals. In cases of co-packing or complex distribution, our packaging flow analysis helps identify responsibilities precisely.

Yes, as long as it places packaged products intended for professionals on the French market, whether it is a carmaker, supplier, distributor, garage or logistics provider.

Yes. Both texts apply simultaneously to French companies. In practice, both frameworks converge on the same reduction, reuse and recycling objectives.

The sooner you join, the sooner you are compliant. Payment of the eco-contribution will be retroactive from 1 January 2027. Waiting increases the amount of regularisation required and the risk of penalties from the public authorities of up to €7,500 per unit or tonne of undeclared packaging placed on the market.

You must fulfil your EPR obligations through an approved eco-organisation or an individual system approved by the French State In practice, almost all companies choose the eco-organisation route, which is simpler and less costly to implement.

You are subject to it if you are considered a “producer” under the Extended Producer Responsibility (EPR) scheme for professional packaging. There are three main scenarios: you manufacture, or have manufactured, packaging under your own brand; you manufacture, or have manufactured, products packaged in sales packaging; or you import products of which you are not the end user.

They organise the public waste management service, contribute to local initiatives, help promote awareness campaigns and take part in discussions with the scheme’s other stakeholders.

Depending on the flows concerned, Twiice provides several mechanisms to support the public waste management service, particularly for plastic, cardboard and wood packaging.

Yes, provided that your service provider has an agreement with an approved eco-organisation for the EPR scheme for professional packaging. This enables the necessary conditions to be put in place to receive the financial support provided for professional packaging waste management.

The producer placing packaging on the market is the company that places packaging intended for professionals on the French market. It joins an eco-organisation and pays the eco-contribution. The waste holder is the company that receives and uses this packaging and generates packaging waste on its site. The waste holder is not required to join an eco-organisation, but must sort and properly manage its waste.

Yes, if you import packaged products of which you are not the end user. The importer is considered the producer placing packaging on the market and is responsible for declaring the packaging of the products it imports. It must request the necessary information from its foreign supplier.

Yes, if you manufacture, or have manufactured, packaged products intended for professionals in France. As the manufacturer, you are responsible for declaring the packaging and paying the eco-contribution.

The European reuse targets do not apply to transport packaging or sales packaging used for transport:
– used for the transport of dangerous goods in accordance with Directive 2008/68/EC;
– used for the transport of large-scale machinery, equipment and goods, where the packaging is specifically designed to meet the individual requirements of the economic operator placing the order;
– in flexible format, used for transport and in direct contact with food and feed within the meaning of Articles 2 and 3(4) of Regulation (EC) No 178/2002, or with food ingredients within the meaning of Article 2(2)(f) of Regulation (EU) No 1169/2011 of the European Parliament and of the Council;
– in the form of cardboard boxes and cardboard dividers;
pallet-wrapping films.

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.

The distinction is not based solely on whether your customer is a professional. The regulations take into account, in particular, the nature and function of the packaging, its capacity and, in some cases, the intended destination of the packaged product.

Offcuts and rejects arising directly from manufacturing must be distinguished from packaging that becomes waste after use. They may be suitable for recovery or recycling solutions, but do not necessarily fall under the same mechanisms or regulatory definitions. They are therefore not eligible for financial support under the EPR scheme for professional packaging.

Yes. This professional sales packaging is declared when it is placed on the market. Reusable big bags benefit from a reduced eco-contribution from their first placing on the market; subsequent rotations, including through reconditioning loops, do not give rise to any new contribution.

Yes. It will have to be declared so that packaging flows can be monitored, but no new eco-contribution will be payable after its first placing on the market.

These three levers follow a hierarchy: reduction means placing less packaging on the market or using more resource-efficient packaging; reuse means using the same packaging several times without it becoming waste between uses; recycling comes into play when the first two levers are not possible.

Single-use: packaging not designed to be reused. Subject to the full eco-contribution.
New reusable packaging: packaging designed for several rotations and placed on the market for the first time. Benefits from a reduction of at least 50% in the eco-contribution.
Reused: reusable packaging that has undergone at least a second use for the same type of purpose. No new contribution is payable. Not to be confused with recycled packaging.

No. This packaging does not fulfil the legal functions of packaging within the meaning of Article R. 543-43 of the French Environmental Code. It is not included in the EPR scheme for professional packaging.

For products returned within the statutory withdrawal period and put back on the market without repackaging, the packaging does not need to be declared a second time. Nor can it be considered reused packaging.

No. Packaging for unsold products does not need to be declared, as it is not considered to have been placed on the market.

Yes. Samples are considered packaging placed on the market even when there is no financial transaction.

Yes. Packaging for hazardous products is included in the EPR scheme on professional packaging and has a specific classification in the declaration. However, Twiice has chosen a single pricing structure, regardless of whether the packaging contains hazardous products.

Yes. It must be declared by the importer, provided they are not the end user of the imported product.

Yes. Grouped and transport packaging are included: cardboard boxes, pallets, crates, films, strapping, stillages, protective inserts, layer pads, etc.

Yes. Sales packaging for products sold to professionals is included (cardboard boxes, bags, jerrycans, buckets, plastic and metal drums, big bags, bottles, etc.).

Not by the company renting it. The company that manufactures the packaging, or has it manufactured under its own brand or to its own specifications for rental, is responsible for declaring it.

Yes. It is declared when first placed on the market and benefits from a reduction of at least 50% in the eco-contribution. Subsequent rotations do not give rise to any new contribution.

All packaging sold to professionals is included, regardless of material or use (single-use, reusable or reused). This includes sales, grouped, transport and primary-production packaging placed on the market in France (including the French overseas departments, regions and territories), as well as packaging containing hazardous products.
The following are excluded: packaging already covered by another EPR scheme (EcoDDS, oils and lubricants, agricultural supplies, PMCB – building products and materials – category 2c), packaging for exported products, and containers used solely for processing or internal handling within a site.

The distinction is not based on the packaging itself, but on who generates the waste. Professional packaging is packaging whose waste is generated by a professional in the course of their business. The EPR scheme on professional packaging covers packaging placed on the market for professionals, as opposed to household packaging, which is covered by a separate EPR scheme.

The two schemes cover different scopes depending on the packaging’s final destination. Household packaging EPR applies to packaging whose waste is generated by private individuals. The EPR scheme for professional packaging applies to packaging whose waste is generated by professionals. The same packaging may fall under either scheme depending on whether it is sold to a private individual or to a professional. When a product is sold to both, the declaration of its sales packaging depends on the allocation defined in the ministerial order of 2 December 2025 on the scope of the scheme.

Sales packaging directly contains the product sold to the professional. Transport packaging facilitates the handling and transport of several sales units. Primary-production packaging is intended for unprocessed products from agriculture, livestock farming, hunting, fishing or gathering (produce crates, big bags, etc.). All three categories are subject to the EPR scheme for professional packaging.

Yes. Pallets, plastic covers, crates and other transport packaging fall within the scope of the EPR scheme for professional packaging when they are placed on the market for professionals.

Rendez-vous dans la section Événements du site pour consulter le calendrier et vous inscrire. Les replays sont disponibles après chaque session.

Yes. Companies placing small volumes of packaging on the market (fewer than 2,000 units and less than 4 tonnes) can benefit from a simplified declaration with a flat rate. The applicable flat-rate amount is set out in the Twiice eco-contribution fee schedule. The minimum annual contribution is €50. Our advisers are here to support you, whatever the size of your company.

As soon as you join, the Starter Kit gives you access to: an EPR assessment of your situation, a MyTwiice account and your IDU within 3 working days, a data preparation guide, a declaration template, and telephone support from a Twiice adviser.

Twiice provides your IDU within 3 working days of your registration on MyTwiice and the signature of your contract. It is specific to EPRO and must appear in your General Terms and Conditions of Sale.

Twiice is the only eco-organisation 100% dedicated to professional packaging. Since 2019, we have carried out 30 reuse and recycling pilot projects with industrial companies across all sectors. Our hands-on expertise, our partnerships with stakeholders across the value chain and our knowledge of the specific characteristics of professional packaging enable us to support companies pragmatically and effectively.

Membership is completed entirely online through MyTwiice. Have the required information ready: account creator details, company information, contract signatory details and the type of contract required. Once validated, Twiice registers your company and provides your Unique Identifier (IDU).

No. There are no membership or application fees. Twiice’s operating costs are included in the eco-contribution fee schedule.

You can join directly through MyTwiice.

Twiice helps you structure your internal management: identifying the people responsible, defining reporting processes and preparing for possible inspections. The aim is to give you a clear, lasting overview that goes beyond the annual declaration alone.

Twiice works with you to design materials suited to your activities, sector and internal organisation (signage, short training sessions and monitoring indicators) to embed good sorting practices on the ground over the long term.

The financial arrangements depend on the nature and volume of the professional packaging you place on the market. The eco-contribution you pay finances packaging collection, recycling and reuse, as well as the tools, guidance and financial support offered by Twiice. Depending on your activity, you may also benefit from financial support to accelerate your projects.

• By email: contact@twiice.org
• By phone: +33 9 70 25 60 11 (standard rate from France)
• Through MyTwiice, for members
• Through Eliia, our AI agent, available 24/7 on the website

Twiice is governed by its members: producers placing packaging on the market from six governance colleges representing the main industrial sectors subject to the EPR scheme for professional packaging.
Twiice is also the first eco-organisation to have included packaging manufacturers in its governance.

Yes. Twiice is approved by the French Ministry for Ecological Transition for the EPR scheme for professional packaging. This approval, valid for a maximum of six years, confirms that Twiice meets the regulatory requirements to carry out its duties as an eco-organisation.

An eco-organisation is a private not-for-profit organisation approved by the French Ministry for Ecological Transition. Its role is to collect eco-contributions from producers placing packaging on the market and redistribute them to finance packaging collection, sorting, reuse and recycling. By joining an eco-organisation, you legally transfer your EPR obligations to it.

Twiice is the only eco-organisation 100% dedicated to professional packaging. While other eco-organisations cover several EPR schemes, Twiice focuses all its expertise on professional packaging: its materials, uses and specific constraints. Since 2019, we have carried out 30 reuse and recycling pilot projects with industrial companies across all sectors.

Twiice is the only eco-organisation 100% dedicated to professional packaging. While other eco-organisations cover several EPR schemes, Twiice focuses all its expertise on professional packaging: its materials, uses and specific constraints. Since 2019, we have carried out 30 reuse and recycling pilot projects with industrial companies across all sectors.

Your regulatory obligations continue to apply regardless of membership. If you do not join, you lose access to structured support and to the financial support for which your organisation may be eligible, and you may be exposed to the penalties provided for under the French Environmental Code.

The recycled plastic incorporation premium (IMPR) is an eco-modulation mechanism designed to encourage the use of recycled plastic.
Where the regulatory criteria are met, it benefits the producer placing on the market the product or packaging concerned.
Packaging manufacturers play an essential role in enabling their customers to access this premium, by incorporating recycled material and providing the necessary information and evidence.

The eco-contribution is the amount paid to the producer responsibility organisation to finance packaging waste management. Eco-modulation adjusts this amount according to the environmental characteristics of the packaging. For example, reusable packaging benefits from a reduction of at least 50% in the contribution.

Two separate mechanisms apply to reuse.

For packaging that is actually reused, no new contribution is due, provided that evidence of reuse is kept available for the eco-organisation and the quantities concerned are declared each year. For packaging placed on the market after 1 January 2027, it must also be possible to demonstrate that a contribution was paid when it was first placed on the market.

For reusable packaging, from its first placing on the market, an eco-modulation premium applies if it forms part of an effective reuse system: a reduction of at least 50% in the contribution, rising to 100% for packaging belonging to a standard range.

The amount varies depending on whether the packaging is single-use (full contribution), reusable (reduction of at least 50%) or actually reused (no new contribution). Other criteria, such as incorporating recycled materials or eco-design, may be added to this mechanism.

The payment terms and deadlines for your eco-contribution are set out in your membership agreement, in the Members’ Guide and in your MyTwiice account.

Yes. Eco-contributions may change to reflect regulatory developments and the scheme’s management costs. The latest version is always available in your MyTwiice account and in the Resource Centre.

Eco-modulation is a mechanism that adjusts the amount of the eco-contribution according to the environmental characteristics of your packaging. The more packaging is designed to limit waste generation or support circularity, the lower its contribution. Reusable packaging benefits from a 50% reduction, and reused packaging gives rise to no new contribution.

Your eco-contribution is calculated on the basis of the weight of the packaging you declare and the material it is made from. Amounts vary by material: plastic attracts the highest contribution and glass the lowest. Reusable packaging benefits from a reduction of at least 50%, while reused packaging gives rise to no new contribution. The detailed fee schedule can be downloaded from the Resource Centre.

Beneficiaries must comply with regulatory obligations, sign the standard Twiice agreement, apply the technical standards, ensure flow traceability and provide the necessary evidence.

Access to financial support requires registration with Twiice, compliance with technical standards, flow traceability and declaration of tonnages through MyTwiice.

EPR provides financial support for collection, sorting, plastic recycling and traceability and, depending on the mechanism, for local recycling or investment projects.
Twiice Boosters are the main financial support mechanisms available to members.

A premium is provided for companies that incorporate recycled plastic into their packaging, of up to €1,000 per tonne of material incorporated (Source: Order of 5 September 2025). Implementation details will be announced shortly.

To identify certified recycled-plastic suppliers, MyRecycledContent connects you with qualified providers.

SEPA direct debit is the standard payment method. Card payments are accepted if the annual amount is below €1,000 incl. VAT. Bank transfers are possible with Twiice’s prior approval.

The eco-contribution is the amount you pay to Twiice to finance the management of your packaging waste. Eco-modulation is the mechanism that adjusts this amount according to the environmental characteristics of your packaging. Reusable packaging benefits from a 50% reduction, and reused packaging gives rise to no new contribution.

Yes. It will have to be declared so that packaging flows can be monitored, but no new eco-contribution will be payable after its first placing on the market.

Twiice sends ADEME consolidated data by sector. Each company’s data is anonymised and pooled with data from the same sector. Twiice does not provide ADEME with any data identifying individual companies.

Yes. Even though Twiice supports you through the process, you remain responsible for the truthfulness, accuracy and completeness of the information you submit. Keep all the documents needed to ensure the traceability of your declarations.

Your history is available at any time in your MyTwiice account.

You can submit a corrective declaration within the specified deadlines directly through MyTwiice. The correction procedure is set out in the Members’ Guide. If the deadline has passed, contact our team so that they can review your request.

Yes. As an authorised representative, you can declare on behalf of one or more producers. Each company requires a separate declaration, and responsibilities must be defined in the mandate. To save time, you can import an Excel file containing the data for all entities; validation must then be completed manually, entity by entity.

When you register, you will be asked to enter your NAF code (the French business activity code), which determines your sector. Our teams can help you if you are unsure.

To prepare your declaration, ask your packaging suppliers and packaging fleet managers for the packaging materials (resins for plastics), the unit or total weight, and whether the packaging is single-use, reusable or reused.

Packaging is declared by weight for each material and by unit according to the predominant material, in accordance with French and European regulations.

The declaration is the process by which you provide Twiice with the quantities of packaging you placed on the market over a given period. It is used to calculate your eco-contribution and to feed the scheme’s indicators, such as reuse and recycling rates. It is submitted every year through MyTwiice.

The first declaration must be submitted between 1 January and 28 February 2027. The procedures will be communicated to you through MyTwiice and updated on this page.

Declarations are made through MyTwiice in one of two ways: manual line-by-line entry, or import of a structured Excel file for high-volume declarations.

The Twiice declaration matrix lets you pre-fill 50% to 75% of the coding.

Yes, under certain conditions. You can submit a corrective declaration within the specified deadlines through MyTwiice.

The procedures are set out in the Members’ Guide.

A flat-rate arrangement for small companies that meet both of these conditions: fewer than 2,000 units placed on the market and less than 4 tonnes in total weight. The applicable flat-rate amount is set out in the Twiice eco-contribution fee schedule.

Yes, where the packaging and the reuse loop are suitable. Developing reuse must take account of return, cleaning and, where necessary, disinfection conditions, as well as container traceability. Whether a loop is suitable therefore depends as much on the packaging design as on the organisation that allows it to be put back into circulation under appropriate conditions.

It depends on the packaging and the material. For materials intended for food contact, the use of recycled material must remain compatible with the applicable food-contact regulations. Optimising the eco-contribution must therefore be considered alongside health, technical and product preservation requirements.

Recyclability, material reduction, reusability and the incorporation of recycled materials are gradually becoming core criteria for producers placing packaging on the market.
By developing your packaging, you can reduce its environmental impact, anticipate regulatory changes and offer your customers better-performing solutions.

When it becomes waste on your sites, you must have it sorted and directed to appropriate collection, reuse or recycling solutions. Tracking these flows also makes it possible to demonstrate that they have been properly managed and recovered.

Your service providers can give you information on destination routes and the recovery performance associated with your flows.

Start with the largest flows by volume, the most costly flows, or those with the greatest potential for reuse.

Not necessarily. The first priority is to understand your flows and assess your current organisation before considering any changes.

No. EPR complements and improves existing arrangements for waste sorting, management and traceability. Your current obligations therefore continue to apply, while EPR provides additional ways to improve the collection, sorting and recovery of professional packaging.

The eco-contribution applies to producers placing packaging on the market. A packaging waste holder is subject to it only if it also has that status.

Not necessarily. Membership of an eco-organisation applies to producers placing packaging on the market. A packaging waste holder may nevertheless benefit from initiatives implemented under the scheme, subject to accepting the applicable terms of use.

These targets are set collectively at scheme level; there is no individual penalty for failing to meet them. Eco-modulation, however, encourages each company to improve its packaging in order to reduce its contribution.

Why is Twiice developing technical standards?
Standards help preserve flow quality, harmonise practices between operators and improve recycling performance across the scheme.

Yes. Some support is available to packaging waste holders, including the packaging waste and reuse assessment and sorting at source support, available from launch and funded by Twiice.

Access to financial support requires, in particular, membership of Twiice followed by the appropriate contractual arrangements, compliance with technical standards, traceability of flows and declaration of tonnages through the designated system.

No. Operators keep their commercial autonomy. Twiice does not intervene in the contracts, prices or technical solutions offered to waste holders.

Twiice supports operators through financial support, technical standards and calls for projects to improve their performance. EPR does not change operators’ commercial relationships with their customers: Twiice does not intervene in the contracts, prices or technical solutions offered to waste holders.

Standards help preserve flow quality, harmonise practices between operators and improve recycling performance across the scheme.

Calls for projects cover, in particular, pre-collection equipment and improvements to sorting and recycling conditions.

MyRecycledContent is a platform that connects companies wishing to incorporate certified recycled plastic into their packaging with qualified suppliers.
In addition, Twiice’s IMPR Booster funds the traceability audits needed to certify your recycled content rates and access the premium.

Financial support currently covers professional plastic packaging. An extension to other materials is planned shortly. Twiice will let you know through MyTwiice and the newsletter as soon as new materials become eligible.

No. Twiice’s role is not to challenge an effective system, but to identify how it can be strengthened and how its performance can be recognised financially.

Through technical tools, awareness initiatives, support programmes, support schemes and local coordination involving businesses, operators and local authorities.