Citeo Pro, a subsidiary of the Citeo Group, is a French operator in the field of Extended Producer Responsibility (EPR) for commercial packaging: this principle, enshrined in the Environment Code, means that the producer or distributor is responsible for, and funds, the management of waste arising from their products.
Find out more: About us
Overview
The principle of Extended Producer Responsibility was established by the Environment Code in 1992, based on the ‘polluter pays’ principle: all companies that place certain categories of products on the market are required to fund their end-of-life management, i.e. the management of waste generated by those same products. There are currently 25 EPR schemes in France (e.g. textiles, electrical waste, medicines, batteries, etc.). To find out more about EPR schemes, you can consult the information sheet produced by the Ministry for Ecological Transition and Territorial Cohesion.
In France, each company is free to set up its own individual system – approved by the public authorities – for the collection, sorting and recovery of packaging placed on the market. However, since the introduction of the EPR scheme, all companies have chosen to pool their efforts by joining an approved, non-profit eco-organisation, thereby delegating 100 per cent of their obligations to it.
The eco-organisation collects a financial contribution from its clients, which is then used, in particular, to fund the overall collection, sorting and recycling scheme at national level.
The Extended Producer Responsibility (EPR) scheme for catering packaging applies to any company placing ‘bulk-sized’ packaged food products on the French market, whether consumed or used by catering professionals or households, and entails their responsibility for managing and financing the end-of-life of this packaging. This covers collection, sorting, recycling and reuse, as well as eco-design and consumer awareness.
This new EPR sector came into force on 15 March 2024, and Citeo Pro, by order of 11 March 2024, is the first and only eco-organisation accredited to date for this EPR sector.
Links to the regulatory texts relating to this EPR:
In the event of non-compliance with obligations under the Extended Producer Responsibility (EPR) scheme:
Should the public authorities carry out an inspection and find that a breach has occurred, an administrative fine may be imposed. The amount of this fine is determined by taking into account, on the one hand, the estimated average annual quantity of products placed on the market by the producer, in relation to the duration of the breach, and, on the other hand, the maximum unit financial contribution set by the accredited eco-organisations in the relevant sector and, where applicable, the waste management costs borne by the individual accredited systems within that same sector.
Scope of the Extended Producer Responsibility (EPR) scheme for catering packaging
From 15 March 2024, in accordance with the provisions of the AGEC and Climate and Resilience Acts, businesses that produce or import ‘bulk’ food products intended for catering professionals in France* are required to reduce the environmental impact of the primary packaging of these products.
The law defines a catering professional as a person whose main or secondary professional activity is catering. This applies to all types of catering, whether indoors or outdoors, for consumption on the premises or as takeaway.
Examples of catering professionals include commercial catering (traditional restaurants, fast food, chain restaurants, etc.) or institutional catering (schools, businesses, healthcare and social care settings, etc.), hotels, petrol stations, as well as cafés, pubs, food shops offering a catering service, vending machines, etc.
Who is affected by this Extended Producer Responsibility (EPR)?
The producer, for products packaged in France:
With regard to private-label brands, it is advisable for businesses to specify in their commercial agreements who is responsible for declaring packaging. Citeo Pro recommends that manufacturers carry out the declaration to ensure operational efficiency.
The importer or distributor: for products packaged abroad – both within and outside the European Union – and resold on the French market.
If the manufacturer or importer/distributor cannot be identified (products packaged in France and abroad): the party responsible for first placing the packaged product on the market is liable.
Example: I import products manufactured and packaged abroad by a supplier that has a subsidiary in France. A
foreign manufacturer is subject to French law when it markets its products through a subsidiary registered in France (with a SIREN number).
By marketing products from its group or parent company, the supplier then becomes the first party to place the product on the market. This company will be responsible for declaring its placing on the market in its capacity as the introducer/importer, rather than as the manufacturer. Distributors
are affected:
Marketplaces are affected:
Packaging manufacturers are not affected as they do not package the products.
The French market comprises mainland France and the overseas departments and regions (Guadeloupe, Martinique, French Guiana, Réunion, Saint Pierre and Miquelon, Saint Martin, Mayotte), as well as the duty-free and boarding areas in the above territories.
Only primary packaging* for ‘bulk’ food products placed on the market in France and used by catering businesses (whether or not this is their main activity) or households is covered.
The Order of 20 July 2023 sets out in detail the rules for identifying primary food packaging* covered by the Extended Producer Responsibility (EPR) scheme for catering packaging, based on the volume or mass of the packaged product.
Grouping packaging and shipping packaging do not fall within the scope of this EPR. Let’s
take the example of a cardboard box containing 10 x 5-litre tubs of ice cream intended for a restaurant. The ice-cream tubs are all primary packaging and are therefore covered by the scheme. The cardboard box containing the ice cream tubs is secondary packaging and is not covered by the ER EPR. Please
note! This mixed food packaging falls within the scope of the Household Packaging EPR. If you only supply your products to catering professionals and only have mixed food packaging, you simply need to declare this packaging to Citeo, Adelphe or any other organisation authorised under the Extended Producer Responsibility (EPR) scheme for Household Packaging and Graphic Paper.
*Definition taken from Article R543-43 of the Environment Code: ‘Sales packaging or primary packaging: this is designed in such a way as to constitute, at the point of sale, an item intended for the end user or consumer’.
For further information on the definition of the packaging concerned, please refer to the question ‘Only primary food packaging must be declared under the Extended Producer Responsibility (EPR) scheme for catering packaging. What is primary packaging?’
The Order of 20 July 2023 sets out the rules for distinguishing, on the basis of the volume or mass of the packaged product, catering packaging from ‘mixed food’ packaging, which will fall under the Extended Producer Responsibility (EPR) scheme for Household Packaging and Graphic Paper from 1 January 2024.
Catering Packaging:
Primary packaging for food products with a volume or mass exceeding the values specified in the annex to the decree (Article R. 543-43 of the Environment Code) consumed or used by catering businesses or households. Commonly referred to as ‘large-format packaging’.
Primary food packaging exceeding the thresholds set by the scope decree of 20 July 2023 must, by default, contribute to the Catering Packaging EPR scheme, regardless of the distribution channel.
Thus, large-format packaging intended for households must be included in the catering EPR scheme. Mixed Food
Packaging:
Food packaging with a volume or mass less than or equal to the values specified in the annex to the decree (Article R. 543-43(III)(5) of the Environment Code), which are likely to be consumed or used by both households and catering businesses. Commonly referred to as ‘small-format packaging’.
Please note! Mixed food packaging now falls within the scope of the Extended Producer Responsibility (EPR) scheme for Household Packaging and Graphic Paper (REP EMPG). If you supply your products exclusively to the catering sector but only have mixed food packaging, you simply need to declare this packaging to Citeo, Adelphe or any other organisation authorised under the REP EMPG scheme.
Example to help determine whether your food packaging is catering packaging or mixed food packaging: I sell tins of vegetables, each weighing 2 kg and packed in sets of six in a cardboard box, to a catering business.
A) I start with my primary packaging: this is the tin, as it is the reference unit of goods.
B) I identify the size (volume/mass) of my primary packaging and compare it to the threshold for the category of packaged products set out in the scope decree: In our example, the mass of each tinned vegetable tin is 2 kg.
According to the annex to the decree of 20 July 2023, the threshold for this category of packaged product (tinned vegetables and tinned fish) must be greater than 1.2 kg for the tinned product to fall within the scope of catering packaging.
Consequently, the tins in our example have weights above this threshold and are therefore classified as catering packaging.
Any of my tins weighing 1.2 kg or less would be considered ‘mixed food packaging’ and would fall within the scope of the Extended Producer Responsibility (EPR) scheme for household packaging and graphic paper.
Primary packaging (or sales packaging) is the packaging of each unit of goods marketed to catering professionals. In the case of bulk sales, primary packaging must be regarded as the packaging for each individual unit of goods making up the batch in question, and not the packaging grouping these units of goods together.
Primary packaging for food products whose volume or mass exceeds the threshold set out in the scope decree. Definition
under Article R543-43 of the Environment Code: “Sales packaging or primary packaging is packaging designed to constitute, at the point of sale, an item intended for the end user or consumer.”
Example: I sell tins of vegetables, each weighing 2 kg, to a catering business, packed in cartons of six.
Consequently, the tins in our example have masses above this threshold and are therefore classified as catering packaging. Some
examples of primary packaging covered by the Extended Producer Responsibility (EPR) scheme for catering packaging: A 2kg tin, a 5L oil can, a 3kg bag of meat, a 20L beer keg, and a seafood crate used for storing fish.
Secondary and tertiary packaging are excluded from the Extended Producer Responsibility (EPR) scheme for catering packaging. They will be covered by the future EPR scheme for industrial and commercial packaging (EIC).
Secondary packaging (or group packaging) can be defined as packaging used to group together a set of individual goods, particularly to form batches intended for sale.
Example: a cardboard box or grouping bag containing various individual packages, such as a box containing six tins or oil cans.
For further information, see Article R543-43 of the Environment Code.
Tertiary packaging (or transport packaging) can be defined as packaging used to facilitate handling and transport operations. Tertiary packaging has, in particular, a logistical dimension. It can facilitate the transport of a number of packaging units, particularly secondary packaging, under appropriate handling and storage conditions. In the case of products delivered ‘in bulk’ or ‘by weight’, the delivery crates and trays used to deliver these products to catering professionals constitute tertiary packaging. Example
: the seafood container (rigid PS) or seafood crate (EPS), used for transporting fish; fruit and vegetable crates; oyster baskets; shellfish nets; potato nets; pallets; pallet wrap; and strapping.
For further information, please refer to Article R543-43 of the Environment Code.
Article R. 543-43(8) of the Environment Code: “Catering business operator: any person carrying out a professional catering activity, whether on-site or for takeaway, including licensed premises, whether or not this is their main business, and whether indoors or outdoors.”
Examples: The following are considered catering professionals: caterers, petrol stations with catering facilities, vending machines (for drinks, pizzas, baguettes).
As a matter of principle, in accordance with the provisions of Article 2 of the Scope Order, whenever a producer places on the market food packaging listed in the Annex to the Order, that packaging is deemed to be subject to declaration under the Extended Producer Responsibility (EPR) scheme for catering packaging.
However, an exemption from the scope is provided for if the producer can demonstrate that at least half of the packaging in the ‘catering packaging’ category – in accordance with the provisions of the Order – is not intended for professionals engaged in catering activities. In this case, the producer may consider that only the proportion of packaging intended for catering professionals falls within the ‘catering packaging’ category.
First example: I place oil on the market intended for agri-food businesses (60 per cent of my sales) and for catering professionals (40 per cent of my sales).
If I can provide evidence of this, I may exclude packaging for products intended for the food industry from the scope of my declaration and will only declare the 40 per cent of packaging actually intended for catering professionals.
If I cannot justify this breakdown of sales, all sales must be reported within the scope of the Extended Producer Responsibility (EPR) scheme for catering packaging.
Second example: I place tomato sauce on the market for food processing businesses (20 per cent of my sales) and for catering professionals (80 per cent of my sales).
I must declare all my sales within the scope of the Extended Producer Responsibility (EPR) scheme for catering packaging. What
supporting documents must be provided to qualify for an exemption?
Citeo Pro will not issue an exemption certificate. However, you must ensure you have the technical details identifying the invoiced company (non-catering business).
Packaging for non-food products used specifically in the catering sector;
Packaging for food products whose volumes or masses are less than or equal to the thresholds specified in the decree: so-called ‘Mixed Food Packaging’ (EMA), which must be declared under the Extended Producer Responsibility (EPR) scheme for Household Packaging and Graphic Paper;
Secondary and tertiary packaging for food products whose volumes or masses exceed the thresholds specified in the decree;
Primary packaging for food products is predominantly intended for other businesses. Please note! If I cannot prove that more than 50 per cent of my sales in this product category are intended for other businesses, I must report this packaging under the catering EPR scheme.
The company (e.g. a distributor) that purchases food products abroad and imports them into France is solely responsible under the Extended Producer Responsibility (EPR) scheme, regarding membership of an eco-organisation and the declaration of its imports, in its capacity as the first party to place the products on the French market. This applies even if it transfers its EPR obligation to its foreign supplier by commercial agreement.
In this case, the importer must be able, in the event of an inspection, to provide evidence that their foreign supplier: Is
up to date with the declaration of products exported on behalf of the distributor who has delegated this obligation to them.
Either is fully aware of the French regulations;
is able to distinguish between mixed food packaging (small formats) (EMA) and large-format catering packaging (ER)
Is a member of an eco-organisation for the relevant EPR sectors
Holds a Unique Identifier (IDU) for each EPR sector that applies to them (household packaging and/or catering packaging)
Where the producer does not sell directly to catering professionals but solely through a network of distributors who may dispatch and/or repackage its products when selling to end customers (e.g. products sold in bulk, by the dispatch or in transport packaging – i.e. tertiary packaging):
If the producer can obtain evidence from their distributors that the packaged products supplied are subsequently repackaged, they may exclude their own packaging from their declaration, as it does not reach the end customer. In this case, the distributor acts as the producer if they repackage the product in primary sales packaging.
It is presumed to sell its packaged products in the same form as it sells them to its distributors. If it cannot obtain proof from its distributor that the packaged products supplied are subsequently repackaged: it must therefore, by default, declare all its primary packaging.
The French market comprises mainland France and the overseas departments and regions (Guadeloupe, Martinique, French Guiana, Réunion, Saint Pierre and Miquelon, Saint Martin, Mayotte), as well as the duty-free and boarding areas in the above territories.
Since the introduction of the Extended Producer Responsibility (EPR) scheme, companies have chosen to pool their efforts by joining an accredited, non-profit environmental organisation, in order to delegate 100 per cent of their obligations to it. The role of the environmental organisation is then to:
However, each company may set up its own individualised system – approved by the public authorities – for the collection, sorting and recovery of the packaging it places on the market; in which case, your EPR obligation is deemed to have been met.
However, if your current individual take-back scheme has not been approved by the public authorities as fulfilling your EPR obligation, you will not be eligible for an exemption from the contribution.
Membership
You can sign up for Citeo Pro online. Simply click on the ‘Sign up’ button on this website’s homepage. You will then be guided through the sign-up process.
To complete your registration, you will need your company’s details (SIRET number, intra-Community VAT number or registration number) as well as the contact details of the person designated as the contract signatory.
It may take up to a few days for your membership to be approved. Once you have joined, you will have access to the Citeo Pro customer portal, where you can view the documents you need to make your declaration (contract, tariff guide, declaration guide, and declaration file for calculating your contribution).
You will also be required to pay a minimum contribution of €80 in the month of your registration.
Thereafter, each year, a financial contribution corresponding to the volume and type of packaging placed on the market is invoiced to Citeo Pro customers, based on the tariff set for the year in which the packaging was placed on the market.
You can register and declare the primary food packaging placed on the market by your clients directly under the relevant market placements listed in your declaration file.
For information:
A mandate is a mandate agreement whereby a Principal entrusts the Agent with their declarations and the respective payments on their behalf and for their account in specific situations exhaustively listed in the general terms and conditions of the contract.
A principal is a natural or legal person responsible for the legal obligation to prevent and manage waste from catering packaging placed on the French market, who has authorised the agent to carry out, in their name and on their behalf, the declaration and related operations, as well as the payment of their contribution. The Principal retains the status of Client.
Keeping the list of Principals and related information up to date constitutes a contractual obligation of the Agent. Furthermore, the Principal is subject to certain rights and obligations set out in the Contract on the basis of the Mandate entered into between the Principal and the Agent.
An agent is a person appointed by a Principal, subject to holding a mandate (which may be implied), to submit the Principal’s declaration and pay the Contribution in the Principal’s name and on the Principal’s behalf in specific and exhaustively listed situations. The Agent, if subject to the legal obligation to prevent and manage packaging waste from the catering sector, is also a customer.
An Agent may enter into a contract with Citeo Pro, provided that a mandate has been granted:
If you are a customer of an eco-organisation within the Citeo Group (Citeo, Adelphe or Citeo Soins & Hygiène), and you wish to have your various customer accounts merged, we advise you to ensure that the key details of your new contract are the same as those in your existing contract.
If any of the key details of your contract (for example: SIRET number, country, etc.) differ from those in your current contracts, please note that your customer accounts cannot be merged.
We therefore urge you to ensure that these key details are indeed the same. If you wish to make changes to your new contract with Citeo Pro, please ensure that these changes have already been implemented in your current contracts by contacting your account managers for those contracts.
Reporting your catering packaging
At the start of each year, you must submit a declaration of your packaging relating to products placed on the market in year N-1.
There are two types of declaration, depending on the number of primary packaging items placed on the French market:
NB: From 2024, if the volume or mass of your primary packaging is less than or equal to the thresholds specified in the decree, this mixed food packaging (EMA) must be declared under the Extended Producer Responsibility (EPR) scheme for Household Packaging and Graphic Paper (EMPG). To find out how to make a declaration, please contact an approved eco-organisation or the eco-organisation with which you have signed a contract under the EMPG EPR scheme.
15 March 2024: Entry into force of the Extended Producer Responsibility (EPR) scheme for catering packaging.
NB: The extension of the scope of the Household Packaging EPR* to include ‘small-format’ mixed food packaging came into force on 1 January 2024. 1
January > 28 February 2025: Declaration of catering packaging placed on the market in 2024.
During 2025: Adjustment invoice(s) for the contribution relating to catering packaging placed on the market in 2024, followed by provisional invoices for 2025:
1 January > 28 February 2026: Reporting of catering packaging placed on the market in 2025.
The list of categories and their thresholds set out in the annex to the Order of 20 July 2023 have been defined and approved by the public authorities. You should assign your various packaged products to the categories that most closely match them.
2024 is the year in which the Extended Producer Responsibility (EPR) scheme will be introduced.
You may encounter difficulties in choosing the product category to which you are assigned under the scope of the decree. For your information, Citeo Pro provides decision-making guidance to help you complete your declaration:
Any frozen product should be included in this category. The fact that the product is deep-frozen is the decisive factor in determining its categorisation.
Example: deep-frozen bread, confectionery, cassoulet, sauerkraut and tarts do not fall into the category for which they are explicitly intended, but into the deep-frozen category.
The category ‘Ready-to-eat desserts, dessert mixes and dessert preparations’ specifically covers desserts that are already prepared or nearly complete and cannot be repurposed.
It should be distinguished from the second category, ‘Other products for pastry-making and cooking aids’, which covers ingredients or components of a dessert that can be used for various purposes.
Example: a chocolate cake mix should be placed in the ‘Ready-to-eat desserts’ category, whilst a tart base should be placed in the ‘Other products for pastry-making and cooking aids’ category.
The first category covers only ‘ferments’ and excludes all other products and cooking aids.
Example: A food enzyme may be regarded as a ferment.
To declare them: primary packaging supplied on reels must be declared in the same way as all other packaging.
How do you calculate the unit weight of a primary package produced on a reel? You
can work out an average to determine the unit weight of the primary packages. Unit weight of the primary packaging (in g) = (Weight of the reel in g / number of primary packages produced).
The average weight is calculated by reel type, so you must declare one reel type per line.
You must declare these packaged products based on the product’s reference weight.
The unit weight* (in g) of a primary packaging unit is entered in the box for the relevant material.
The number of packaged products produced is entered in the ‘Number of primary packages’ box. *It
is possible to calculate an average to determine the unit weight of the primary packages.
Unit weight of the packaged product (in g) = (Weight of the reel (in kg) × 1000) / number of primary packages
You must declare these packaged products based on the product’s reference weight.
In the absence of clarification from the public authorities, in order to understand the thresholds set by the decree, for example for the categories ‘Yoghurts and similar products, creams and fromage blanc, milk-based desserts and sweet dishes’, ‘Ready-to-eat desserts, preparations for desserts and sweet dishes’, ‘Condensed and powdered milk’, Citeo Pro will, for the sake of simplicity, treat one litre as equivalent to one kilogram.
Unique identifier (UID)
Article 62 of the Anti-Waste Law for the Circular Economy (AGEC Law), adopted on 10 February 2020, provides for the introduction of a mandatory unique identifier for all companies or entities subject to the principles of Extended Producer Responsibility (EPR).
Specific to each EPR scheme, this identifier will enable the identification of every company or entity registered with an accredited organisation and subject to the EPR principle.
Find out more about the unique identifier in our quick reference guide, available in the resources section of your customer portal.
Under the Extended Producer Responsibility (EPR) scheme for catering packaging, you do not need to take any action to obtain it from ADEME following your registration with Citeo Pro.
Once you have joined, we will act as quickly as possible to obtain your unique identifier from ADEME. As soon as we receive your unique identifier, we will be sure to let you know. It will also be available directly in your customer portal (Contract tab > Unique Identifier).
This unique identifier must be included in your general terms and conditions of sale or any other contractual document. It must also be displayed on your website, where applicable.
Failure to include the unique identifier in your Terms and Conditions of Sale or any other contractual document may result in an administrative fine of up to 30,000 euros.
Invoicing
Membership of Citeo Pro is free, but you will be charged a minimum contribution of €80 in the month you join.
Citeo Pro’s clients pay a financial contribution based on the actual volume and type of packaging placed on the market, with a minimum annual charge of €80 excluding VAT. The fee schedule is available in the ‘Fees and Resources’ section of this website.
Membership of Citeo Pro involves, at the very least, the administrative management of your customer account, which includes, in particular:
The environmental levy under the Extended Producer Responsibility (EPR) scheme for catering packaging, just like that for household packaging and graphic paper, forms part of their retail prices.
This is why, as an environmental organisation, we are unable to offer you any advice on this matter. You may wish to consult this guidance on price transparency published by the public authorities for further information.
Reuse
The AGEC Act (Article 67) sets out reuse targets for all types of packaging (sales, group packaging and transport packaging); details of these can be found here. These targets therefore also apply to catering packaging.
The regulatory framework sets out annual targets for the placing on the market of reused packaging to be met by producers (with annual sales of more than 10,000 units):
Packaging may be described as reusable or refillable if it has been designed, manufactured and placed on the market to undergo, during its life cycle, several cycles of use, by being refilled or reused for the same purpose for which it was designed.
Reused packaging is packaging that is used at least once more for a purpose of the same nature as that for which it was designed, and the reuse of which is organised by or on behalf of the producer. Reused packaging must be recyclable.
*more than 10,000 sales units.
Support for the collection of reusable packaging:
Citeo Pro helps to cover the costs of collecting reusable packaging (within the ‘Catering Packaging’ scope).
Operators collecting reusable packaging will be required to report the number of units collected on a quarterly basis and will receive support based on a scale by packaging format.
Funding the transition to reuse:
Citeo Pro allocates 5 per cent of its budget each year to funding the transition to reuse.
Packaging may be described as reusable or refillable if it has been designed, manufactured and placed on the market to undergo, during its life cycle, several cycles of use, by being refilled or reused for the same purpose for which it was designed.
Reused packaging is packaging that is used at least once more for a purpose of the same nature as that for which it was designed, and the reuse of which is organised by or on behalf of the producer. Reused packaging must be recyclable. MUST
BE DECLARED Reusable
packaging: it must be included in the declaration relating to the year of its first placing on the market. This qualifies for a 5% bonus on your 2025 declaration.
DOES NOT NEED TO BE DECLARED Reused
packaging, i.e. reusable packaging from its second time on the market onwards. You must be able to provide evidence that this packaging has been reused.