The reporting requirement for reusable professional packaging
Become compliant with the help of Valobat and its partner Twiice, soon to become the PRO for professional packaging
TABLE OF CONTENTS
Regulatory context
Since 2023, any producer placing more than 10,000 units of packaged products on the market per year is subject to a reuse obligation and must submit an annual declaration of their packaging data.*
Valobat and its partner Twiice, the future PRO dedicated to EPR for Professional Packaging, can help you meet this regulatory obligation.
*More information in Decree No. 2022-507 of April 8, 2022 regarding the minimum proportion of reusable packaging to be placed on the market annually.
How is a producer defined by the decree?
- A professional who packages or has their products packaged for placing on the market,
- Any importer of a packaged product placed on the market in France
Pending the implementation of the Extended Producer Responsibility (EPR) scheme for Professional Packaging scheduled for July 1, 2026, ADEME’s Reuse and Reusability Observatory provides a temporary solution for the 2026 return of those concerned, regarding packaging placed on the market in 2026.
Filing season began on January 20, 2026 and will continue until May 29, 2026.
How Twiice and Valobat can help
In 2025, Valobat formed a strategic partnership with Twiice, a future PRO fully dedicated to the EPR scheme for Professional Packaging, scheduled to launch on July 1, 2026.
Bringing together Twiice’s technical expertise with Valobat’s construction focus, Our goal is to provide a comprehensive, construction-specific response for industry players by combining Twiice’s packaging expertise with Valobat’s one-stop shop / construction industry knowledge.
This partnership extends to the reporting of professional packaging, as Twiice has established itself as a collective body to deliver this declaration service.
In practice:
- You benefit from comprehensive support throughout the declaration period: webinar, guide, meetings with our teams…
- You submit your declaration on the MyValobat Members platform
- Twiice handles the anonymized summary and shares it with ADEME and the Reuse Observatory.
The service costs €30 for Valobat members and €60 for non-members (administrative fees).
Special case: You place products on the market in category 2C* AND other professional packaging:
Mortars, plasters, paints, varnishes, resins, including their containers, excluding specific hazardous waste.
- you must declare the information relating to the reuse rate for category 2C (primary only) to your approved PRO free-of-charge.
- For any other industrial or commercial packaging, whether you choose to submit your declaration directly to the Reuse Observatory or to benefit from the support of Valobat and its partner Twiice. The applicable packaging is as follows:
- Secondary and tertiary professional packaging for producers of products in category 2C.
- Primary, secondary and tertiary professional packaging for producers of any other type of packaging.
Webinars to learn more
On March 3, 2026 at 11 a.m., March 25 at 10 a.m., or April 9 at 10 a.m., Valobat will hold webinars specifically dedicated to this declaration requirement and the support we and Twiice provide to ensure your regulatory compliance.
Register now!
More information about the reused packaging declaration
Who is subject to this requirement?
- Any professional who packages or has their products packaged for placing on the French market.
- Any importer/introducer whose products are marketed in packaging in France, or…
- The person responsible for the first placing on the market (in the absence of identification of the producer or importer).
- As a producer:
- for service packaging sold or made available to households to be filled at the point of sale.
- for shipping packaging used for home delivery of a product.
- As an introducer/importer for packaged products imported to the French market.
- Are subject if they package products for shipment.
The case of packaging manufacturers and packaging pool managers
Packaging manufacturers and packaging pool managers do not place packaging on the market: they do not count packaging (which will not be the case under the new definition of producer as defined by the EPR scheme for Professional Packaging).
However, pool managers are required to transmit data to their customers.
How is “placing on the market” defined for professional packaging?
Placing professional packaging on the market means transporting one or more packaged products and a purchase/transfer (subject to payment or free of charge) of packaged products between two entities with different SIRET numbers. The packaging must be tracked and declared from 2024 by companies subject to reuse obligations (Decree No. 2022-207).
What is reused packaging?
Reused packaging must be recyclable, according to Article L541-1 of the Environmental Code.
It is packaging that is used at least a second time in three scenarios:
- the packaging is used a second time for the same type of use for which it was designed and whose reuse is organised by or on behalf of the producer.
- being filled at the point of sale as part of bulk sales.
- being refilled at home if the producer has organised a refill system
About the threshold of 10,000 units of packaged products
The Context
All producers placing at least 10,000 units of packaged products per year on the market are subject to the reuse obligation and have been required to track and count their packaging since 2023.
-> A producer calculates their units of packaged products per year within the scope of:
- Packaging placed on the French market
- All household and professional packaging
- All types (sales, grouped or transport) and packaging materials
- Single-use, new reusable and reused packaging
- Excluded from reporting are:
- exported packaging
- Packaging subject to a reuse prohibition (R.541-350, III of the Environmental Code)
Examples
As an example to illustrate the concept of packaged product unit (in relation to the threshold of 10,000 units of packaged products):
- 1 bottle of shampoo = 1 unit of packaged product
- A pack of 12 yogurts = 12 units of packaged products
- 6 bottles of wine grouped in a wooden crate = 6 units of packaged products
- 1 phone in a package = 1 unit of packaged product
- 20 palletized automotive parts (with boxes, pallet wrap, padding…) = 20 units of packaged products
- 100 concrete blocks (sold in lots of 100 units) palletized = 100 units of packaged products
Packaging counted
The reuse of industrial and commercial packaging concerns both:
the primary packaging of products not intended for household consumption, as well as secondary and tertiary packaging.
The producer of these packaged products is responsible for communicating and tracking the data.
- Sales packaging, formerly known as primary, i.e., packaging designed to constitute a sales unit at the point of sale for the end user or consumer;
- Grouped packaging, formerly known as secondary, i.e., packaging designed to constitute a group of a certain number of sales units at the point of sale, whether sold as such to the end user or consumer, or used only to stock shelves at the point of sale; it can be removed from the product without modifying its characteristics;
- Transport packaging, formerly known as tertiary packaging, i.e., packaging designed to facilitate the handling and transport of a specific number of sales units or grouped packages to avoid transport-related handling and damage. Transport packaging does not include road, rail, sea and air transport containers.”
(Article R543-43 of the Environmental Code)
Professional Packaging included in the scope of the study corresponds to Professional Packaging referenced in the ADEME study “Mapping of product/type and packaging material pairs”, October 2021.
If necessary, this scope will be redefined to align with the EPR for Professional Packaging, scheduled for July 2026.
Some counting examples
ADEME informs you
Watch the video below for a step-by-step demonstration of how to count the reuse of your packaging.
For more information on counting methods, please consult the educational materials provided by ADEME.
Reporting Procedures for Reusable Packaging
Reporting by head office
A declarant must have a SIREN number. If the head office has multiple establishments, it must submit its declaration for all of its establishments.
What information must you report from January 20, 2026?
The following information will be requested via a secure online platform:
- The organization’s tax identity
- Its main business sector (and secondary, optional)
- The quantities of professional packaging placed on the market in 2025, in packaging units:
- The total quantity of professional packaging placed on the market in 2025;
- The proportion of reused professional packaging placed on the market in 2025.
Items to declare
Go further: prepare for EPR for Professional Packaging with the Twiice and Valobat’s fully dedicated construction solution
On July 1, 2026, companies placing professional-use packaging on the market must comply with new regulations: Extended Producer Responsibility (EPR) for professional packaging. This regulation, already applicable to other sectors (Construction, Household packaging…), assigns producers, distributors and importers of certain products the responsibility for managing the end-of-life of the products they place on the market.
Valobat’s role
Bring the expertise of a legitimate player in professional packaging recovery
Twiice means 5 years of expertise in managing professional packaging, already reflected in more than 30 projects to optimise every stage of the professional packaging recovery process!
A single, dedicated point of contact for all your EPR schemes
Valobat remains your one-stop shop and dedicated point of contact at every stage of your compliance process, with standardised tools and services for each of your EPR schemes.
Valobat embodies the voice of the construction sector within Twiice’s governance
Valobat speaks on your behalf within Twiice’s governance, as part of the Building College, developing eco-contribution fee schedules, and consulting you on industry development projects
Why choose Valobat?
We centralize your information and prepare the ADEME summary, anonymized and pooled
Declare simply directly on our website or from your My Valobat Member personal portal
Valobat provides you with a declaration certificate to confirm your compliance with the ADEME study declaration.
Valobat guides you through your declaration with a dedicated service. Have a question? We are by your side to help you prepare for the arrival of the EPR Scheme for Industrial and Commercial Packaging Waste (DEIC)
