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Am I considered a producer of waste and thus concerned by the EPR?

YES, if you are a natural or legal person who develops, manufactures, handles, treats, sells, or imports waste generating products or elements and materials used in their manufacture (article 62 of the French circular economy law).

 

One of the major contributions of the French circular economy law (law 2020-105 of 10th of February 2020) is the extension of the scope of extended producer responsibility (EPR), which is a translation of the polluter-pays principle. According to this principle, the polluter must bear the costs resulting from measures that aim to prevent and reduce pollution of which they are the origin (Environmental Code, Article L.110-1).

Indeed, the circular economy law extends EPR to several new sectors, including the building sector, which will be operational from 1st of January 2022 onwards.

If you identify yourself as a waste producer, you can go and consult the answers to the questions “How do I ensure full compliance of my construction site?” and “What does the French circular economy law change for me?”. 

 

Note that EPR concerns all inert waste, non-hazardous non-inert waste, and hazardous waste from the construction sector, except for excavated soil. The management of excavated soil must nevertheless respect specific provisions, more information on it here.