DEEE in France: French version of EU WEEE
Guide WEEE in France
The French DEEE stream (Dechets d'Equipements Electriques et Electroniques, the national name for waste electrical and electronic equipment) is one of the most developed Extended Producer Responsibility regimes in Europe. Built on the transposition of Directive 2012/19/EU into the Code de l'Environnement, it has been reshaped since 2020 by the Anti-Waste for a Circular Economy Law (Loi AGEC, n. 2020-105 of 10 February 2020), which extended the European baseline by introducing a Reparability Index, reinforced obligations on spare-parts availability, and an eco-modulation framework tied to product reparability. This guide presents the French legal architecture (Code de l'Environnement, implementing decrees, Loi AGEC), the role of ADEME and the RPDP register, the split between the ecosystem and ecologic eco-organisations, the mechanics of the Reparability Index and its successor the Durability Index, the distinction between household and professional streams, and the recurring pitfalls observed during inspections.
Legal basis: Code de l'Environnement and European Directive
Section titled “Legal basis: Code de l'Environnement and European Directive”The French WEEE regime articulates on three normative levels.
- European level. Directive 2012/19/EU, known as the recast WEEE Directive, sets the minimum collection, reuse and recycling targets and imposes an Extended Producer Responsibility framework on Member States. It replaces the initial Directive 2002/96/EC and has extended scope to all categories of electrical and electronic equipment since 2018 (the so-called open-scope regime).
- National statutory level. Articles L541-10 onward of the Code de l'Environnement transpose the WEEE Directive and organise the EPR stream, setting general obligations of registration, declaration, financing and reporting.
- National regulatory level. Articles R543-172 onward of the Code de l'Environnement detail the operational rules of the WEEE stream. Decree n. 2014-928 of 19 August 2014 structured the current version of the stream, subsequently amended to reflect the Loi AGEC.
On top of this base, Law n. 2020-105 of 10 February 2020 (Loi AGEC) is the principal vehicle of divergence between the European minimum and the French requirement. Several Loi AGEC provisions translate directly into the WEEE stream.
| Loi AGEC provision | Effect on the WEEE stream | Reference article |
|---|---|---|
| Mandatory Reparability Index | Point-of-sale and online display | Loi AGEC article 16, codified L541-9-2 |
| Spare-parts information requirement | Consumer information and availability duration | Loi AGEC article 19 |
| Eco-modulation by environmental criteria | Bonus/malus on eco-contribution | Loi AGEC article 62 |
| EPR extension to new streams | Toys, sports articles, DIY, gardening | Loi AGEC articles 61 onward |
| Durability Index | Successor to Reparability Index | Loi AGEC article 16 (progressive entry into force) |
Scope: the six categories of WEEE
Section titled “Scope: the six categories of WEEE”Directive 2012/19/EU and its French transposition group equipment into six categories since the 2018 recast, the scope set out in Annex III of the directive. The earlier ten categories (collection groups 1 to 10) still appear in some administrative documents.
| Category | Definition | Typical examples |
|---|---|---|
| 1 | Temperature exchange equipment | Refrigerators, freezers, air conditioners, heat pumps |
| 2 | Screens, monitors, screens with surface above 100 cm2 | Televisions, monitors, tablets above a certain size |
| 3 | Lamps | Fluorescent tubes, LEDs, discharge lamps |
| 4 | Large equipment (external dimension above 50 cm) | Washing machines, dishwashers, ovens, photovoltaic panels |
| 5 | Small equipment (external dimension at or below 50 cm) | Vacuum cleaners, irons, electric toys, small connected objects |
| 6 | Small IT and telecommunication equipment | Smartphones, laptops, telephones, routers |
For each category, the eco-organisation cahier des charges published in the Journal Officiel sets the operational targets (collection rate, recycling rate, reuse rate).
Producer, distributor, importer: who is concerned
Section titled “Producer, distributor, importer: who is concerned”The Code de l'Environnement defines the producer as any party who, on a professional basis, manufactures, imports or places on the national market electrical and electronic equipment under their own brand, resells under their own brand equipment manufactured by others, or introduces equipment from a third country or from another Member State.
| Actor | Status under the stream |
|---|---|
| French manufacturer selling under own brand | Producer |
| Distributor reselling under private label | Producer |
| Importer from a third country | Producer |
| Importer from another Member State | Producer |
| Distributor reselling under the manufacturer's brand | Distributor (take-back and information duties) |
| Cross-border online seller into France | Producer, via authorised representative if not established in France |
The introduction of marketplace liability, extended by the Loi AGEC, now requires online marketplaces to verify the registration of their third-party sellers established outside France. This evolution has reinforced the RPDP registration requirement for foreign operators.
RPDP registration: the mandatory entry point
Section titled “RPDP registration: the mandatory entry point”The RPDP (Registre des Producteurs de DEEE et Piles) is maintained by ADEME (Agence de la transition ecologique, the French agency for the ecological transition). Registration is a prerequisite to placing on the market, codified at article R543-179 of the Code de l'Environnement.
Registration procedure
Section titled “Registration procedure”| Step | Actor | Output |
|---|---|---|
| Self-assessment of producer status | Company | Determination of status under the Code de l'Environnement |
| Selection of an accredited eco-organisation | Company | Membership contract with ecosystem or ecologic |
| Submission via the SYDEREP platform | Company | Online dossier, SIRET, brand, categories |
| Validation by ADEME | ADEME | Issuance of an individual RPDP number |
| Display of the RPDP number | Company | Inclusion on commercial and regulatory documents |
The RPDP number is unique per producer entity. It must be cited in annual declarations, on invoices to professional clients where required, and kept in the compliance file. A company may hold multiple memberships with different eco-organisations for distinct categories (household WEEE and batteries for example).
Annual declaration of quantities
Section titled “Annual declaration of quantities”Each registered producer submits, generally before the end of the first quarter of year N+1, a declaration of the quantities placed on the French market in year N, broken down by category and subcategory. The declaration is the basis for calculating the eco-contribution. A missing or inaccurate declaration exposes the producer to adjustment by ADEME and by the eco-organisation.
The household WEEE eco-organisations: ecosystem and ecologic
Section titled “The household WEEE eco-organisations: ecosystem and ecologic”Operational management of the stream is performed through eco-organisations accredited by inter-ministerial order. For household WEEE, two structures are currently active on the French territory.
ecosystem
Section titled “ecosystem”ecosystem arose from the 2018 merger of three historical structures, Eco-systemes (large household WEEE), Recylum (lamps) and Recyclum (professional lamps). The merger produced the eco-organisation that leads the stream by volume. Its accreditation was extended in 2021 to professional WEEE, which makes it today a transverse actor covering the full household and professional spectrum.
ecologic
Section titled “ecologic”ecologic is a nationally accredited eco-organisation, of more modest size than ecosystem, whose scope covers household WEEE with a similar accreditation. The producer freely chooses the eco-organisation among those accredited for the target category. Competition between ecosystem and ecologic plays out on the eco-contribution schedule, the declaration service, and the regulatory support.
Comparison overview
Section titled “Comparison overview”| Criterion | ecosystem | ecologic |
|---|---|---|
| Year of creation | 2005 (Eco-systemes), 2018 (merger) | 2006 |
| Legal form | Non-profit simplified joint-stock company | Non-profit company |
| Household WEEE scope | All categories | All categories |
| Professional WEEE scope | Yes (accreditation extended 2021) | According to current accreditation |
| Lamps scope | Yes (from Recylum) | According to accreditation |
| Volume market share | Dominant position | Smaller |
| Eco-contribution schedule | Public, on the eco-organisation website | Public, on the eco-organisation website |
The choice between the two eco-organisations is in practice driven by volume placed on the market, integration with the producer's internal tools, and the producer's commercial position on its categories. The regulatory obligations are identical regardless of the eco-organisation.
Eco-contribution and eco-modulation
Section titled “Eco-contribution and eco-modulation”The eco-contribution is the amount paid by the producer to the eco-organisation for each unit placed on the market. It finances collection, sorting, reuse, recycling, information and innovation. Its amount depends on the product category, the mass, and since 2023 on an explicit modulation tied to reparability.
Eco-modulation principle
Section titled “Eco-modulation principle”Eco-modulation introduces a price signal correlating the eco-contribution with the environmental performance of the product, in particular reparability. The eco-organisation cahier des charges, public in the Journal Officiel, defines criteria and coefficients.
| Product characteristic | Effect on eco-contribution |
|---|---|
| High Reparability Index | Bonus (reduction) |
| Low Reparability Index | Malus (increase) |
| Documented spare-parts availability | Partial bonus |
| Modular design | Partial bonus |
| Significant use of hazardous substances | Partial malus |
| Limited disassembly | Partial malus |
The exact coefficients vary by category and by eco-organisation, within the limits set by the cahier des charges. The aggregate balance is published each year by the eco-organisation in its annual report and by ADEME in its dashboards.
The Reparability Index: 2021 baseline and transition to the Durability Index
Section titled “The Reparability Index: 2021 baseline and transition to the Durability Index”The Reparability Index is a score out of 10 displayed at point of sale and on online media, informing the consumer of how easy the product is to repair. It entered into application on 1 January 2021 on five priority categories.
Categories covered since 2021
Section titled “Categories covered since 2021”- Smartphones
- Laptop computers (laptops excluding tablets)
- Televisions (above a certain size)
- Front-loading washing machines
- Electric lawn mowers (corded, cordless, robotic)
The implementing order of 16 December 2020 and Decree n. 2020-1757 of 29 December 2020 set the calculation. The index aggregates five main components, weighted, producing a score out of 100 rescaled to a score out of 10 displayed to one decimal place.
Calculation components (initial categories)
Section titled “Calculation components (initial categories)”| Component | Description |
|---|---|
| Documentation | Availability and duration of access to technical documentation |
| Disassembly | Ease of disassembly, type of tools, type of fasteners |
| Spare-parts availability | Duration and delivery lead time |
| Spare-parts pricing | Ratio between part price and new product price |
| Specific criterion | Category-specific additional criterion |
The score must be displayed in store and on online media. The producer calculates the index according to the regulatory grid and keeps it available to the consumer. Non-publication or erroneous calculation exposes the producer to sanction.
Transition to the Durability Index
Section titled “Transition to the Durability Index”The Loi AGEC provides for the progressive replacement of the Reparability Index by a Durability Index, richer, which integrates reliability, software and hardware upgradability, and robustness. The transition is being rolled out category by category, starting in 2024, through sector-specific orders. For categories covered by the Durability Index, the Reparability Index ceases to be mandatory.
Household WEEE and professional WEEE: two distinct streams
Section titled “Household WEEE and professional WEEE: two distinct streams”The stream distinguishes two flows with different financing and collection rules.
| Characteristic | Household WEEE | Professional WEEE |
|---|---|---|
| End user | Private consumer | Company, administration, professional |
| Eco-organisation | ecosystem or ecologic accredited household | ecosystem (professional accreditation since 2021) or direct producer take-back |
| Collection financing | Eco-contribution levied on placing on the market | Eco-contribution + possible contractual financing |
| Collection | Public network + distributors | B2B logistics, contractual pick-up |
| Regulatory symbol | Crossed-out wheeled-bin mandatory | Crossed-out wheeled-bin mandatory |
The boundary between the two flows is legal rather than commercial. Equipment sold through general mass distribution with predominantly domestic use is treated as household WEEE. Equipment sold B2B to a professional user is treated as professional WEEE, even if technically identical to the consumer model. Misclassification is a recurring source of adjustment, addressed in the pitfalls section.
The crossed-out wheeled-bin symbol
Section titled “The crossed-out wheeled-bin symbol”The crossed-out wheeled-bin symbol is set out in Annex IX of Directive 2012/19/EU and made mandatory in France by article R543-177 of the Code de l'Environnement. It must be affixed visibly, legibly and indelibly on every EEE placed on the market after August 2005.
For small products where the surface is insufficient, the symbol may be placed on the packaging, on the manual, or on the warranty card. The form of the symbol is uniform at European level, with no national variant, which simplifies multi-country compliance.
Right to repair and spare-parts availability
Section titled “Right to repair and spare-parts availability”The Loi AGEC reinforced information and availability obligations on spare parts, in complement to the WEEE regime proper.
- Information on spare-parts availability. The professional seller must, under threat of sanction, indicate the duration for which spare parts essential to the use of the product are available. The obligation is codified at article L111-4 of the Consumer Code.
- Minimum availability duration. For certain categories, the implementing order sets a minimum duration of five years from placing on the market.
- Parts from the circular economy. The professional repairer must inform the consumer of the possibility of using parts from the circular economy (used parts brought back to standard), unless otherwise specified by the manufacturer.
- Planned obsolescence. Article L441-2 of the Consumer Code penalises the practice of deliberately reducing the lifespan of a product to increase its replacement rate.
These provisions, although not strictly part of the WEEE stream, complete the incentive to reparability induced by eco-modulation, and feed the Reparability Index and then Durability Index criteria.
Cross-references with other EPR streams
Section titled “Cross-references with other EPR streams”France has over twenty EPR streams as of 2026. Several intersections with the WEEE stream are worth identifying to avoid duplicate declarations.
| Adjacent stream | Scope | Articulation with WEEE |
|---|---|---|
| Batteries and accumulators | Portable batteries, industrial batteries | Distinct, but shares the RPDP register, separate eco-contribution |
| Household packaging | Cardboard, plastics, paper (CITEO stream) | EEE packaging handled by packaging stream, EEE handled by WEEE |
| Textiles and footwear | Refashion stream | No product overlap |
| Tyres | ALIAPUR stream | No product overlap |
| Electric vehicle batteries | Regulation (EU) 2023/1542 and national regime | Battery Regulation cf EU Battery Regulation guide |
| Toys, sports and leisure, DIY and gardening | EPR introduced by Loi AGEC | Separate the EEE component (WEEE) and the object component (own EPR) |
For a consumer electronics manufacturer, the most common combination is WEEE + batteries + packaging. For an industrial manufacturer, professional WEEE + packaging + sometimes Battery Regulation. Mapping the streams is a vigilance point at every product launch.
Articulation with CE marking and the European framework
Section titled “Articulation with CE marking and the European framework”The WEEE stream is an Extended Producer Responsibility obligation, distinct from CE marking. CE marking attests conformity with the product directives applicable (Low Voltage, EMC, RED, RoHS, machinery, toys, etc.), while RPDP registration and eco-organisation membership attest conformity with the waste management stream.
| Obligation | Nature | Validity |
|---|---|---|
| CE marking | Product conformity with applicable directives | At placing on the market, maintained throughout commercial life |
| RPDP registration | Identification of the producer in the EPR stream | Permanent, updated on structural change |
| Eco-contribution | Stream financing | Annual, levied on year-N quantities |
| Crossed-out wheeled-bin symbol | Consumer information | On the EEE or its packaging |
| Reparability / Durability Index | Consumer information | Point-of-sale and online display, calculated at placing on the market |
For a product covered both by a CE directive and by the WEEE stream, coexistence of the two obligations is the rule. A product CE compliant but not RPDP registered cannot be lawfully marketed in France. Conversely, a product RPDP registered but not compliant with the applicable CE directives is exposed to sanction at the point of placing on the market.
See also the CE page for the presentation of CE marking and its associated directives, and the future WEEE EU guide for the European directive perspective.
Recurring pitfalls observed during inspections
Section titled “Recurring pitfalls observed during inspections”Operational experience reveals several recurring errors that trigger adjustments by ADEME, the DGCCRF or eco-organisations.
1. Missing or lapsed RPDP number. A producer that modifies its structure (transfer, merger, change of corporate name) without updating the SYDEREP registration is exposed to an ADEME audit finding placing on the market without valid registration. Updating the registration is a stand-alone obligation, distinct from the annual declaration.
2. Wrong household / professional classification. Equipment sold through general mass distribution generally falls under the household stream, even if technically of professional quality. Equipment sold B2B falls under the professional stream, even if derived from a consumer range. Misclassification leads to an incorrectly computed eco-contribution and an adjustment.
3. Under-declared quantities. The annual declaration is based on actual sales. A mismatch between declared quantities and actual volumes (for instance through sales via a foreign marketplace not integrated) triggers an adjustment. Reconciliation between sales accounting and the declaration is an internal control to maintain.
4. Incorrectly calculated Reparability Index. The Reparability Index calculation rests on five weighted components. An error on documentation, disassembly or spare-parts availability leads to an incorrect score. The producer must keep the detailed calculation and the evidence supporting each component, under threat of sanction by the DGCCRF on inspection.
5. Missing or non-compliant crossed-out wheeled-bin symbol. Omission of the symbol, or its placement on a surface where it is not visible, is sanctioned. For small products, the fallback to packaging or manual must be justified and documented in the technical file.
6. Confusion between integrated and separate batteries. Batteries integrated into an EEE fall under the battery stream, handled through the battery eco-organisation, distinct from the WEEE stream even if the RPDP is shared. A smartphone producer is registered in both streams, with two separate annual declarations.
7. Foreign operators without a representative. A seller established outside France marketing on the French market through a marketplace must appoint an authorised representative for EPR. The absence of a representative exposes the marketplace itself since Loi AGEC, which has increased pressure on third-party seller compliance.
Regulatory calendar and outlook
Section titled “Regulatory calendar and outlook”Several developments are worth watching over the short and medium term.
- Generalisation of the Durability Index. The progressive replacement of the Reparability Index by the Durability Index is being rolled out category by category. Successive sectoral orders define the reliability and upgradability criteria to integrate.
- Strengthened eco-modulation. Eco-modulation coefficients continue to evolve toward a wider gap between reparable and non-reparable products. The cahier des charges documents are reissued periodically.
- Articulation with the Ecodesign for Sustainable Products Regulation (ESPR). The European ESPR Regulation (Regulation (EU) 2024/1781) provides for a digital product passport for many product categories, which will interact in the medium term with information required under the WEEE stream and the Durability Index.
- Convergence of EPR streams. ADEME regularly publishes assessments that guide stream consolidation and procedural harmonisation. A unified declaration platform is envisaged in the medium term.
See also
Section titled “See also”- EU Battery Regulation 2023/1542: passport, carbon
- ESPR (EU) 2024/1781: Sustainable Products Reg
- ErP / Ecodesign 2009/125/EC: product energy efficiency
- Energy Star: the US voluntary energy-efficiency program
Practical roadmap for a manufacturer
Section titled “Practical roadmap for a manufacturer”A structured approach comprises five steps.
1. Map the obligations. Identify the EPR streams concerned by the products (household WEEE, professional WEEE, batteries, packaging, possibly specific streams), inventory the applicable categories and subcategories, and determine the producer, distributor or importer status.
2. Register in the RPDP via SYDEREP. Build the registration file with ADEME, obtain the RPDP number, and include this number in internal and commercial documentation.
3. Select and join the eco-organisations. Choose the eco-organisation for each stream (ecosystem or ecologic for household WEEE, ecosystem for professional WEEE, specialised eco-organisations for batteries and packaging), sign the membership contract, and integrate the eco-contribution schedule into product pricing.
4. Implement the product-level obligations. Affix the crossed-out wheeled-bin symbol on products or packaging, calculate and display the Reparability Index (then Durability Index) for the relevant categories, organise spare-parts availability, and document everything in the technical file.
5. Organise annual declarations and follow-up. Set up the collection of placing-on-the-market data, prepare the annual declaration by end of March of year N+1 at the latest, keep the supporting documents (invoices, calculated indices, evidence of spare-parts availability), and update the RPDP registration on structural changes.
Further reading
Section titled “Further reading”- CE marking and associated directives : product regulatory baseline
- Glossary : definitions of ADEME, RPDP, eco-organisation, EPR, eco-modulation
- WEEE EU guide (forthcoming) : European directive perspective on Directive 2012/19/EU
- RoHS guide (forthcoming) : restriction of hazardous substances in EEE
- EU Battery Regulation : Regulation 2023/1542 on batteries
Sources & references
- ADEME, WEEE dossier, what are DEEE , ADEME www.ademe.fr/expertises/dechets/passer-a-laction/dossier/dechets-dequipements-electriques-electroniques-deee/quest-deee
- ecosystem, accredited eco-organisation for household and professional WEEE , ecosystem www.ecosystem.eco/
- ecologic, accredited eco-organisation for household WEEE , ecologic www.ecologic-france.com/
- Law n. 2020-105 of 10 February 2020 on anti-waste and circular economy , Legifrance www.legifrance.gouv.fr/jorf/id/JORFTEXT000041553759
- Reparability Index, French Ministry for Ecological Transition , Ministere de la Transition ecologique www.ecologie.gouv.fr/indice-reparabilite
- Directive 2012/19/EU on waste electrical and electronic equipment , EUR-Lex eur-lex.europa.eu/eli/dir/2012/19/oj