Ministry for the Ecological Transition 

General Direction of Risk Prevention (GDRP) – Direction Générale de la Prévention des Risques (DGPR)

Ministère de la transition écologique et de la cohésion des territoires

Direction Générale de la Prévention des Risques

Tour Séquoia 1 place Carpeaux

92055 LA DÉFENSE CEDEX

30 June 2025

30 June 2025

30 June 2025

France uses as mainly method the placed on the market approach based on production/import statistics to quantify the packaging waste generated. These data, mainly, come from INSEE (annual production surveys realised by branch of activity according to the Prodcom nomenclature) and from the customs service. These data are supplemented by data from surveys conducted by national sectorial federations of packaging, most often annually, to their members and by other studies or surveys realised in order to collect data required in the framework of the Directive 94/62/EC and the Decision 2005/270/EC.

France uses recycling data collected by PROs in the framework of the EPR scheme which covers household packaging and has set up many reporting campaigns from recycling plants in order to collect recycled packaging waste data. When data cannot be measured at calculation point, the derogation to make use of average loss rates has been applied.

France applies the new calculations rules according to Decision 2005/270/EC. 

Table : Institutions involved in the collection of data and distribution of tasks

INSEE data: Data for national packaging production are provided annually by INSEE (National Institute of Statistics and Economic Studies) through the INSEE annual production survey. The annual production survey (EAP) constitutes a fundamental element of the industrial statistics system. It is the main source of economic information on production at a detailed level.

France uses a product’s classification in 10 digits (PRODFRA codes) on PRODCOM codes and the French Product Classification (FPC): INSEE website.  The sections of the PRODFRA nomenclature are coded in ten positions: the first eight include the eight positions of the associated PRODCOM code if it exists. The last two are used to refine the nomenclature. The French PRODFRA nomenclature corresponds to the finest description of industrial products as used by production statistics.

The main objective of the annual production survey (EAP) is to provide the elements enabling the production of detailed data on industrial production, both to meet the requirements of the European EBS (European business statistics) regulation, but also to respond to the demands of national users (requests of professional unions, public authorities, …).

The annual production survey is conducted by branch of activity. It is exhaustive for companies with more than 20 employees or with more than 5 million euros in turnover. The exhaustive stratum represents more than 96% of total industry turnover. Moreover, companies involved in industrial activities and not surveyed in the exhaustive part of the annual production survey are interviewed by sampling (the sample is taken randomly each year).

Customs data: Data (imports and exports in weight, by CN8 code and HS code) for comext are provided annually by the Customs (Finances).

Data are available by aggregated countries but only the total value per CN8 code is used (in case of strong annual evolutions, we can check country by country).

Within the General Directorate of Customs and Indirect Duties (DGDDI), the Department of Statistics and Foreign Trade Studies (DSECE) is the service responsible for monitoring and analyzing evolutions in France's foreign trade in terms of goods.

Foreign trade statistics are statistics governed by legal provisions:

•  European: Regulation (EC) No. 223/2009 of March 11, 2009 (revised version of 2015) relating to European statistics, Regulation (EU) 2019/2152 of November 27, 2019 relating to European business statistics, repealing ten acts in the field of business statistics known as the “EBS Regulation”, as well as Commission Implementing Regulation (EU) 2020/1197 of 30 July 2020 establishing technical specifications and implementing rules pursuant to the Regulation (EU) 2019/2152.
• National: law no. 51-711 of June 7, 1951 on the obligation, coordination and secrecy in matters of statistics.

The customs statistical network cooperates with the directorates and services that use foreign trade data:

• At the national level: INSEE (preparation of quarterly and annual national accounts), Directorate General of the Treasury, Energy Observatory, Bank of France (preparation of the balance of payments) and of course the technical ministries (industry, agriculture, transport, ...) directly use customs data for the analysis of their area of ​​expertise.
•  At European level: statistical data are transmitted each month by Customs to Eurostat for the preparation in combined nomenclature of the EU trade balance with third countries, and intra-European Union statistics. The DSECE participates in European work for the evolution of statistical practices.
• Other international organizations (OECD, IMF, UN, etc.), which establish comparative statistics on countries, also use the customs source.

  About recycling,for each material, we use “EPR national standards” defined in the framework of the “household packaging EPR” in France (see the agreement specifications Legifrance).  In complement, use some relevant existing standards (example: EN 643 for paper and cardboard) or denomination of flows we defined with professional organization specially for example for flows of industrial and commercial packaging because it doesn’t exist national standards (because no EPR established in France in 2023 on industrial and commercial packaging)

The R/D codes in Annexes I and II of Directive are solely used. The decree of December 12, 2022 sets the data that the PROs have to report to the administrative authority. For any treatment operation, the code of the treatment that was carried out has to be specified (article 6) for each flow.

Quantification of empty packaging placed on the market in France:

The tables below present the PRODCOM codes (within which the PRODFRA codes are considered) and CN8 Customs codes considered for each material. France uses mainly PRODFRA codes to estimate the quantity of empty packaging produce in France and placed on the French market. The list of CN-codes is used by France to quantity imported and exported empty plastic packaging. When the descriptions of PRODFRA and CN codes are not enough precise to determine the part of packaging, France uses data from other sources (data produced by national sectorial federations mainly). 

• Steel material:

List of PRODCOM and CN8 Customs codes considered for the steel material.

*only for refillable steel gas cylinders

• Aluminium material:

List of PRODCOM and CN8 Customs codes considered for the aluminium sector

• Wood material:

List of PRODCOM and CN8 Customs codes considered for the wood material

• Paper & cardboard material:

List of PRODCOM and CN8 Customs codes considered for the paper and cardboard sector

• Plastic material:

List of PRODCOM and CN8 Customs codes considered for the plastic material

• Glass material:

List of PRODCOM and CN8 Customs codes considered for the glass sector

Quantification of filled packaging placed on the market in France:

The HS* codes are used to estimate the import and export of filled packaging (see the French methodology presented in the Informal discussion group “Placed on the market (POM) based on coefficients and production and trade statistics” and available on Circabc). This filled packaging balancing is the only data that must be modelled since only data about quantities of products are available. The filled packaging database is built on HS8 codes from the customs database of about 9000 HS8 codes. First, in order to obtain a representative, realistic, reproducible and verifiable result, France proceeds on a grouping of the HS8 codes from the customs database into manageable homogeneous categories. This results in the identification of 357 different products or groups of products. This grouping is initially done based on the characteristics of the products themselves before being cross-checked with information available on the packaging of these products.

This grouping was done on the basis of different criteria: the representative stakes of the tonnages of products at levels HS2 and HS4; the homogeneous nature of products at HS8 level allowing their grouping; the specific nature of some HS8 codes where the packaging format is specified.

Depending on the product, the SH* code is split depending on the existing packaging format. Several packaging formats are possible for the same product / group of products. A market share is then applied.

The final result is that these products correspond to 413 product segments. For each of these segments, the tonnage of imported and exported products is calculated based on data from the customs database.

To the tonnages of products imported and exported from the customs database, the calculation model assigns different parameters relating to the packaging that com-poses them, mainly: the proportion of packaged products (distinction with bulk); the portion of the packaging of the product by type of material; the relative weight of each packaging material for each product and for each of the primary, secondary and tertiary packaging). Depending on the product code considered, the average "packaging weight / product weight" ratio is obtained by two different methods: either the unit weight of packaging (in grams) by material and by format is known, or it is evaluated directly in % (average percentage of packaging weight per packaged product weight, by material).

Data is associated with an uncertainty in order to obtain a packaging weight (by mate-rial and by type) with its uncertainty rate. The value of the flow of full packaging linked to foreign trade used for reporting to the European Commission is as follows: mean value minus uncertainty. In the case of a net import balance, this value decreases (x kt – y kt uncertainty). In the case of a net export balance, its absolute value increases (-x kt – y kt uncertainty). If the mean value is less than the uncertainty calculated, an equilibrium balance is retained (0).

Distinction between HS Codes and CN codes:

• The HS Code, or "Harmonized System Code", is a standardized system developed by the World Customs Organization (WCO) to classify products traded around the world. It primarily aims to facilitate trade by providing uniform terminology to classify goods.
• The CN code, or “Combined Nomenclature”, is a classification specific to the European Union. Although it builds on the structure of the HS system, it has been designed to meet the needs of EU customs, tax, trade and statistical regulations more specifically.
• International harmonization: The first six digits of the CN code are identical to the HS Code. This correspondence ensures harmonization with the international classification system, which facilitates international trade.
• EU-specific subdivisions: After these first six digits, the CN code incorporates two additional subdivisions (7th and 8th digits). These subdivisions allow a more detailed classification of products according to the specific needs of the EU.

We take into account the amount of wooden packaging that is repaired for reuse in the calculation of the targets laid down in point (f), point (g) (ii), point (h) and point (i) (ii) of Article 6 (1) of Directive 94/62/EC. The adjusted rate is 37,1%.

We take into account the amount of metals in incineration bottom ash (IBA) for calculation of the targets.

The organizational arrangements for reusing EIC packaging in B to B vary depending on the companies and sectors of activity. We can nevertheless distinguish the following five modalities illustrated by the diagram below:

This illustration makes it possible to distinguish:

1. “Shuttle” packaging between a customer (distributor, end user) and its supplier (packer, importer of packaged products). Full packages are sent from one company to another company, who returns the packaging once emptied. Pallets, crates, bins are often used as shuttle packaging shuttle.
2. Packaging reused in a “closed loop” for which packaging is exchanged between more than two companies, but remain within a closed logistics circuit. The reuse circuit is known and controlled between several companies. Some examples of reused industrial and commercial packaging concerned: pallets, plastic bins and crates, wooden boxes, cans, barrels…
3. Packaging reused via a packaging manager or “pooler” who manages the logistic, reconditioning, washing and control. Packaging is managed by an owner manager of packaging whose role is to provide ready-to-use packaging and to collect empty packaging. Some examples of reused industrial and commercial packaging concerned: pallet, bins, crates.
4.  packaging reused in an “open loop”, packaging is exchanged between more than two open loop companies, that is to say without necessarily returning to the initial company. In this case, the different users of the packaging are not known to the initial producer. Some examples of reused industrial and commercial packaging concerned: pallets, boxes.
5. Packaging with a single-use element: the packaging is reusable but contains a disposable part. This is for example the case of certain IBCs with a reusable cage and a disposable bag.

Note: in practice overlaps are possible between certain modalities. 

Mixed flows incinerated with household waste are taken into account and, inside, the part of packaging waste (see report on the treatment of Household and Similar Waste Le-traitement-des-dechets-menagers-et-assimiles-itom-2022). Packaging waste in plastic, wood, aluminium (thickness less than 50 µ) and paper/cardboard are subject to energy recovery.

With the COVID-19 health crisis, the production of glass cullet steeply decreased in France in 2020. At the same time, the collection of glass packaging for recycling continued and has not decreased, resulting in a stock of unprecedented magnitude. To ensure the traceability of the management of this tonnage, the eco-organizations have commissioned an audit firm in charge of considering the data from the glass manufacturers.

The accurate management of the destinations of these stocks was too complex to rely on the the glass manufacturers' declarations. So for 2021 and 2022, we used the reliable data from the EPR scheme (not including the stocks) for the household, and we reported the 2020 data for the non-household (no EPR scheme for I&C packaging yet but the 2020 data was accurate because it was calculated as the difference between the results -household and non-household- of a comprehensive survey of glass manufacturers and the EPR scheme data -household-) adjusted for 2022 regarding the 2,5 months of quarantine in 2020.

In order to avoid this issue, 2023 POM is based on household EPR 2023 POM and renewed 2022 non-household POM, instead of packaging production.

France collects data from:

• producers of empty packaging placed on the market in France (empty packaging produced and placed on the market in France, packaging elements intended to be incorporated into another material sector produced and placed on the market in France)
• importers and exporters of empty packaging
• importers and exporters of filled packaging
• professional federations
• PROs
• waste operators
• recycling plants

INSEE data: The statistical population is made up of all legal units in the industrial economic sectors (sections B to E of the NAF rev. 2), as well as non-industrial legal units with a secondary activity relating to industry.

Placed on the market approach: Total packaged products placed on the national market for the first time by all economic operators

Treatment: Treatment plants treating nationally generated packaging waste" or “sorting plants” (it depends if data is available at calculation point).

France including French overseas departments.

The statistics covers the 2023 calendar year. 

Not applicable.

INSEE data: Production volume depends on the products (defined by the PRODCOM list – see tables in the section 3.3). If data are exclusively available in units and no conversion in mass is possible (example: steel and aluminium INSEE data), we use data from sectorial professional organizations.

Customs data: All data are available in mass.

Reporting data: Tonnes

Calendar year

INSEE data: Legal acts and other agreements:

At the European level, European business statistics (EBS: European business Statistics) are governed by a transversal legal framework for the collection, compilation, transmission and dissemination of European statistics on structure, economic activity, competitiveness, global transactions and business performance. Commission Implementing Regulation (EU) 2020/1197 was adopted on 30 July 2020.

At the national level, the committees which gave INSEE the right and legitimacy to collect this data are:

• The Cnis which examines each new project, whether it is a survey, a directory or the exploitation of administrative files... These projects are presented by all the institutions which contribute through their work to the construction of public statistics. The discussion concerns in particular the purpose of the project, its place in the information system and the planned conditions for its dissemination. It is necessary to check that each operation meets a need of general interest and does not duplicate existing sources of information, in other words to ensure its appropriateness. He gives notice of opportunity. All public statistics surveys labeled by the CNIS and approved by the Minister are included in the annual program published by a decree in the Official Journal;
•  The label committee, within the CNIS, ensures that it respects the statistical quality criteria. This ensures that the survey meets the statistical quality criteria with regard to the collection and sampling method (sampling plan, data adjustment method, treatment of non-responses guaranteeing the reliability of the results. ..), relevance of the questioning and adaptation of the dissemination to the announced objectives. It also ensures that the investigation does not cause an excessive burden on the investigations, that consultation has been carried out with the partners concerned and that the wishes expressed by the CNIS during the appropriateness debate have been taken into account. account. It gives a label of general interest and statistical quality.

EPR data: The EPR scheme in France covers the household packaging and the restauration packaging (from 2024). The household packaging sector was the first to have implemented, in 1992, the principle of extended producer responsibility (decree No. 92-377 from April 1, 1992). Three PROs are currently state-approved in the household packaging sector: Citeo, Adelphe and Léko.

The AGEC law (February 2020) created the EPR scheme for packaging used by catering professionals. Decree No. 2023-162 of March 7, 2023, establishes this new scheme.

An EPR scheme covering the industrial and commercial packaging is due to entry into force on January 1, 2025 (article L. 541-10-1 from the Environmental Code).

The decree of December 12, 2022 (Legifrance) sets the data that these eco-organisms have to report to the administrative authority.

The National Agency for Ecological Transition (ADEME) is in charge to centralize all data about packaging and waste packaging collected in the framework of the 94/62/EC Directive. Every year, The Extended Producer Responsibility Supervision department (DSREP) from ADEME is responsible for ensuring the reliability of this data. The DSREP was created by the article 76 of the national Anti-Waste and Circular Economy Law (AGEC Law) . The Article R131-26-1 of the Environmental Code precises missions of the DSREP. The ADEME shares data with the Ministry of ecological transition which is the reporting entity.

Reporting data: No data collected individually from an actor is published. All data is aggregated before being reported/published. All parts of this report can be published (non-confidential data/informations).

INSEE data: Regarding internet collection, the collection site is completely secure and the standards for managing survey access codes are strict and standardized for all surveys undertaken. For legal units choosing to use paper, data entry is carried out by managers, with strict respect for the confidentiality of the data collected.

Before the distribution of data, secrecy is applied:

- primary secrecy: a result is marked as confidential if fewer than three legal units contribute to this result, or if one legal unit alone represents 85% of the result;

- secondary secret: a result is hidden if it allows results to be found in primary secret, by addition or subtraction with the margins of the tables or other data already published.

Customs data: The DSECE respects statistical secrecy, the obligations of which fall under texts at the national level (Law No. 51-711 of June 7, 1951 on the obligation, coordination and secrecy in matters of statistics) and European level (the general regulation on data protection and Regulation 223 relating to European statistics).

Reporting data: No data collected individually from an actor is published. All data is aggregated before being reported/published.

Reporting data is published on Eurostat website (Data Browser - Statistics) each year after validation stage.

Furthermore, a report called "Valorisation des emballages en France - Données 202X" and/or "Packaging recovery in France – 202X data" (english version) is published on the ADEME website  

every year in the autumn. This report describes methodology applied to quantify packaging waste generated, recycled and recovered in France.

Reporting data: Eurostat databrowser.

Report: Librairie.

The report called "Valorisation des emballages en France - Données 202X" and/or "Packaging recovery in France – 202X data" is a public report.

Data are reported to Eurostat and disseminated every year.

Not applicable

"Packaging recovery in France" report:

• 2023 data version is not yet available (autumn). It will be published on this website : website.  
• 2022 data version is available here :  website.
• 2021 data version is available here :  webiste.

Not applicable

Not applicable

Not applicable

"Packaging recovery in France" report:

• 2023 data version is not yet available (autumn). It will be published on this website : website.
• 2022 data version is available here : website.
• 2021 data version is available here :  website. 

"Packaging recovery in France" report:

• 2023 data version is not yet available (autumn). It will be published on this website : website.  
• 2022 data version is available here : website. 
• 2021 data version is available here :  website. 

INSEE data: The annual production survey was presented to the Label Committee in 2019. The label of general interest and statistical quality was thus renewed for a period of 5 years, from 2020 to 2024.

The Label Committee's mission is to examine on behalf of the National Council for Statistical Information (Cnis) all projects for which the visa provided for in Article 2 of the law of June 7, 1951 is requested. The Committee has builds over time a method and jurisprudence to examine the files submitted to it. Based on considerations expressed in terms of burden or proportionality of the collection to the objectives pursued, the Committee broadened its examination rules to cover all dimensions of statistical quality, as formalized in the Code of good practices of the European statistics. The Committee thus constitutes a lever to ensure compliance with these principles, whether in terms of consultation, methodological quality, proportionate burden, dissemination or provision of duly documented statistical sources.

Regarding the European Statistics Code of Good Practice, it constitutes the reference for assessing the quality of the production of national statistical institutes.

Customs data: The data collected and statistical productions are regularly evaluated and validated in order to improve the collection and production processes.

Completeness of collection:

• In extra-EU trade in goods, 100% of import and export operations are taken into account because they are linked to customs formalities.
• In order to reduce the statistical burden on companies, data concerning intra-EU trade have been collected since 2022 via the monthly survey on intra-EU trade in goods (EMEBI) which is carried out among a sample of companies. The data collected from this sample still represents around 95% of the amounts imported or exported of goods between Member States of the European Union.
• Intra-EU trade in goods collected other than by survey, also referred to as “data below the threshold”, is subject to an overall estimate which is integrated into the calculation of the FOB/FAB economic indicator. The other statistics presented do not take into account the estimation of these data.

Data received late or missing:

• For exchanges of extra-EU goods declared in customs clearance forms (DAU = single administrative document), the data is received as soon as it is validated by the customs service. There are no reports received late.
• For intra-EU trade in goods collected as part of the statistical section of the trade in goods declaration (DEB) until December 2021 then as part of the monthly survey on intra-EU trade in goods (EMEBI) from January 2022, responses from surveyed companies may be submitted late. In order to minimize the impact of data collected late, the DSECE specifically monitors the filing of declarations by the largest operators and carries out systematic reminders within the population of other companies. Data received late or absent are subject to an estimate.

Declarative errors:

• Errors may be made in the declarations submitted by the declarants. Declaring goods according to NC8, which includes nearly 10,000 items, is in fact rather difficult. Sometimes operators assign their product to an incorrect code. Other statistical variables (partner countries for example) may also be erroneous. In order to reduce the impact of these errors, tools are regularly developed and implemented in the automated process of collecting and calculating foreign trade results.

After their first publication, foreign trade statistics are revised monthly for a period of 35 months. Data supplemented by corrections and declarations received late replace the initial data. Estimates for late data are recalculated.

Reporting data: The National Agency for Ecological Transition (ADEME) is in charge to centralize all data about packaging and waste packaging collected in the framework of the 94/62/EC Directive. Every year, The Extended Producer Responsibility Supervision department (DSREP) from ADEME is responsible for ensuring the reliability of this data (consistency checks and changes observed from one year to the next). Each new data/source used have to be reliable to be taken into account. The detailed data collected for the reporting are checked and challenged by experts from the professional organizations during an annual sectorial meeting (usually held in March/April N+2) and multiple exchanges about data take place with these organizations between this meeting and June.

See 11.1

The main users of these data can be presented in different groups, namely:

• Institutions at European level: European Commission, Eurostat;
• Institutions at the national level: Ministries (Environment, Industry, Economy, Finance, etc.), public authorities, régional/local authorities, etc.;
• Others: PROs, professional federations, design offices, engineering consultants, journalists, students, etc.

Information not available

All types of packaging are covered by statistics.

The main issue of the data accuracy concerns the foreign trade statistics, which rely on a mandatory but declarative basis. A few products' codes data are identified as abnormal and should be treated before use (in this case we mainly reconduct the previous year value as the delay for the official data correction is not compatible with the deadline for the reporting to the EC ; this process nevertheless ensures that next year data should be correct as the declarant of the erroneous data is made aware of the problem). Most of the time, the problem affecting a NC8 code is limited to the trade with a specific country inside this NC8 code. 

Moreover, many PRODFRA quantities (10 digits production codes from INSEE based on PRODCOM codes) became unavailable in 2021, 2022 or 2023. We managed to get an overall value for the PRODCOM code which is in fine more accurate than summing PRODFRA tonnages where some codes could be unavailable (in this case we've been reconducting the previous year value).

The information in this section is to provide an overarching understanding of the accuracy of any statistical surveys used relating to packaging waste. Some of the information may be available in previous questions.

The information in this section is to provide an overarching understanding of the accuracy of any statistical surveys used relating to packaging waste. Some of the information may be available in other concepts.

Not available.

The Extended Producer Responsibility Supervision department (DSREP) from ADEME is responsible for ensuring the reliability of this data (consistency checks and changes observed from one year to the next) and treat the errors and inconsistencies occurred.

Final data for year n are available at the reporting deadline (n+18m). 

The release schedule is generally respected. The data is transmitted to Eurostat each year before the deadline (June 30).

Not applicable.

INSEE data: the results are always published in pairs: results from year N and year N-1 with nomenclature N. Comparison over 2 years, down to the finest level, is therefore guaranteed. However, no further retropolation is made. Temporal comparisons can be made over 2 consecutive years for the PRODFRA level.

Customs data: Controls ensure the internal consistency of the data presented on the site (i.e. arithmetic and accounting equalities are checked). The concepts and nomenclatures used comply with international standards, if they exist. When national needs impose specific nomenclatures or treatments, their compatibility with international standards is guaranteed. With this same concern for transnational comparability, France's foreign trade statistics are the subject of regular comparisons with the equivalent statistics of countries which have trade with France. The continuity of the series published on the site is guaranteed. When changes cause breaks in the time series, the series are, if possible, backcasted. If this is not the case, the break is reported and explained.

Reporting data: Every year a comparison between N data and three previous years data is made. However, we don’t proceed in further retropolation, excepted in specific case.

Many breaks in series between 2022 and 2023 data:

- For every materials (excepted “plastics”): foreign trade of filled packaging is based on the foreign trade of products itself with the application of a ratio on the quantity of packaged goods and a ratio on the weight of the packaging with respect to the weight of the goods. Most of those ratios on the weight of the packaging were updated.

- For "plastics": Extrapolation of non-household plastic packaging waste declaration is based on a new source (Eurostat data of PELD exported from France : Eurostat database on EU trade by HS2-4-6 and CN8 (ds-045409)). Agricultural PELD non-packaging waste exported, household PELD films identify by EPR and estimated PELD production wastes are subtracted from PELD exported from France, and compared to non-household PELD declared to get extrapolation multiplying factor applied to the other plastic flows.

- For "wood":

• Between 2021 and 2022, the main source of data shifted from INSEE to the FNB (French Wood Federation). The overall number of pallets is close between the two data sets but the FNB provides a realistic breakdown by type of pallets and enables the removal of pallets that doesn't undergo a preparation for reuse but are resold directly (that represents ~31% of the whole pallets). In 2023, repaired pallets are now accounted directly from the FNB (adjusted with the INSEE data evolution) instead of taking a part of the total amount of pallets which is assessed less precise.
• Only Euro pallets were considered as reusable until 2022 data. From 2023 data, a portion of each kind of pallets is accounted as reusable.
• Until 2022, only pallets were considered as reusable wood packaging. From 2023, cable drums are also accounted as reusable (sales packaging), but no information could have been collected on rotations.

- For “aluminium”: The reusable aluminium packaging are based on CO2 gas cylinders, faced data confidentiality issues (only a few actors) until 2022 data, but could have been estimated for 2023 data. (moderated impact)

- For ”glass”:

• Until 2022, the accurate management of the destinations of stocks was too complex to rely on the glass manufacturer's declarations: reliable data from the EPR scheme (not including the stocks) were used for the household, and non-household data was the 2020 one adjusted for 2022. To avoid this issue, 2023 POM is based on household EPR 2023 POM and renewed 2022 non-household POM (to which we add the change observed on POM households between 2022 and 2023), instead of packaging production.
• In 2023, for the first time, output of cullet preparation from the glass manufacturer's declaration could have been used for both non-household and household glass packaging recycled in France, completed by EPR data for household exports and glass manufacturer's declaration for non-household exports.

Not applicable.

The internal consistency of the data is ensured. 

Explanation detailing the causes of the tonnage difference (in relation to which waste streams, sectors or estimates have caused the difference, and what the underlying cause is) for any component of packaging waste generated and recycled which shows greater than a 10 % variation from the data submitted for the previous data year.

Not applicable.

Reporting data: No revisions are applied to the data except if more reliable source is identified.

Nevertheless, institutional organizations (INSEE and customs) sometimes modify some previous year values when publishing data for year N. These adjusted data are tracked and used only to compute (and analyse) the real evolution between N-1 and N.

No major revisions are planned.

The main next change with an impact on the results will be a source change. As mentioned in the national waste law (AGEC, Anti-Waste and Circular Economy Law), the EPR packaging should cover the complete packaging scope, including the industrial and commercial packaging by 2025. At this time the French PoM approach should shift to a PoM approach based on EPR schemes (as the data will be available).

When the revision of the method is affecting calculation procedures, the whole timeseries will be revised – according to data availability.

When the revision is causing a change of data sources, the timeseries will be updated back according to data availability of the new source.

Data used come from many sources:

• INSEE (French National Statistical Institute): INSEE data (production volumes) are used to quantify empty packaging quantity produced in France, placed on the market and exported from which we deduce the quantity of empty packaging exported (based on CN-codes)
• Customs: Customs data are used to quantity filled packaging flows (based on the use of HS* codes), empty packaging flows (based on CN codes) and exported industrial paper and cardboard packaging recycled abroad,
• National sectorial federations,
• SYDEREP (national declaration system for PROs),
• Citeo and Léko (French PROs),
• ADEME - National Agency for Ecological Transition,
• Recycling plants in France (Glass processing plants, paper mills, plastic material regenerators),
• Plastic waste exporters.

The waste samples for waste analysis are taken from:

A specific study led by ADEME is carried out every year in order to collect data for the annual reporting of packaging and packaging waste.

See different sections below.

Only the PoM approach based on other sources is used for the France’s reporting.

For plastic material, the WCA method has been developed. Results will be reported in the POR statement. 

The composites were already identified in the previous years.
The professional organizations helped us identifying these packaging.
Each material component of composite packaging is extracted and included in its respective material, except for the aluminium in the carton packaging (which represents 4% of the weight of the carton).

Additional information about the methodology, including the combination of methods used:

See the report “Valorisation des emballages en France – données 2022”: 

Librairie, document for the complete detailed methodology, described for each material.

The report “Valorisation des emballages en France – données 2023” will be published on this website.  (autumn)

• For "glass", the data on packaging waste recycled in France comes from an electronic registry led by ADEME. The data on packaging waste recycled abroad comes from this electronic registry and EPR scheme. The data on packaging waste from oversea territories recycled in these oversea territories comes from EPR scheme.
• For "plastic", the quantities of household and non-household packaging waste recycled in France and the exports of non-household packaging waste for recycling come from two distinct electronic registries led by ADEME completed by surveys and Eurostat database on EU trade by HS2-4-6 and CN8 (ds-045409) to ensure the completeness of the data. The quantity of household waste packaging exported for recycling come from PROs.
• For "wood", the results of the survey come from the UIPP, the French wood-based panel manufacturers organization. The tonnages of shreeded pallets for littering, mulching, ... are based on a 2022 national study.
• For "paper and carboard", the quantities of packaging recycled in France come from an electronic registry led by ADEME completed by data from COPACEL (French union of cardboard, paper and cellulose industries) to ensure the completeness of the data and the exports for recycling are based on the customs data.
• For "ferrous metals", the survey concerns only the industrial packaging, the data on household packaging waste being declared by the PROs.
• For "aluminium", the non-household packaging waste is estimated through a survey carried out by the French aluminium recycling organization and the data on household waste packaging are declared by the PROs.
• For "other", no recycling is identified.

Website to annual production survey INSEE.
Website to customs data.

See the report “Valorisation des emballages en France – données 2022”:Dechets-economie-circulaire / packaging-recovery-in-france-2022, document for the complete detailed methodology, described for each material.

The report will be published on this website :Valorisation des emballages en France – données 2023”:(autumn).

Glass data on reusable packaging is collected through a survey. Each year, an email containing an NDA is sent to our contacts in order to collect the tonnages of reusable bottles put on the market two years ago. Then the confidential data are aggregated and extrapolated using a correction factor based on imports.

Wood: data come from survey conducted by the professional federations of wooden packaging.

Calculation of recycling of metals from incinerator bottom ash : Detailed description of the method to collect data in order to calculate the amount of metals separated from incineration bottom ash in accordance with the Commission Implementing Act adopted in accordance with Article 37(7) of Directive 2008/98/EC.

For metals, both ferrous and aluminium, the same data collection and data treatment processes are applied.

The incineration bottom ash quantities are collected by the EPR eco-organisms as they provide a financial support (€/t) for the tonnages directed towards the recycling of metals recovered from household waste treatment units (incineration clinker). These data are then integrated in an annual recovery report, separately for ferrous IBA and aluminium IBA.

Given the specificity of the recycling sector after an incineration process, i.e. the metals are systematically embedded in the residual waste, the IBA data is not corrected (in accordance of Article 5 of Decision 2005/270/EC).

Nevertheless, another double correction factor is applied: a packaging ratio (in order to exclude quantities from non-packaging metals) and a metal ratio (in order to exclude quantities from inerts).

The packaging ratio is given by the results of the French national MODECOM survey (the last one dates back to 2017). This huge survey aims at characterizing household and assimilated waste. The packaging ratio is 71.4% for ferrous and 70.8% for aluminium.

The metal ratio is a mean value taking into account various treatment processes. The data has been obtained through discussions with experts from professional organizations. The metal ratio is 70% for ferrous and 60% for aluminium.

See. 11.1 and see sections below.

Article 6a(3) of Directive 94/62/CE :

Household packaging waste: Data relating to the quantities of generated and recycled packaging waste are declared by the PROs on the EPR Sector Reporting System called SYDEREP ( website). 

The Extended Producer Responsibility Supervision department (DSREP) from ADEME is responsible for ensuring the reliability of this data (consistency checks and changes observed from one year to the next).

Recycling of household and non-household packaging waste: From 2021, the National Agency for Ecological Transition (ADEME) has established electronic registries, in order to gather data directly from the various operators in the recycling value chain for 3 materials (plastic, glass and paper-cardboard) and from exporters of plastic packaging waste for recycling.

The detailed data collected for the reporting are checked and challenged by experts from the professional organizations during the annual sectorial meeting (usually held in March/April N+2).

Article 6a(8) of Directive 94/62/CE :

In France, PROs are non-profit private companies with a public service purpose. They have to follow terms of reference imposed by the State.

1. From 2018, the public authorities impose on PROs, in the approval specifications, a regulatory control procedure for a selection of their adherent “marketers”, in accordance with articles R.541-126 to R.541-129 of the Environmental Code. For the 2018-2022 period, these controls should cover at least 80% of contributions and 15% of contributions per year. The selection of clients who give rise to this regulatory control is done randomly by a bailiff. 
2. For the calculation of the amount of recycled packaging, PROs have to follow several provisions relating to the traceability and control of recycling operations which are specified in the EPR scheme approval specifications:

• Traceability: Whatever the part-exchange option chosen by the local authority, with the exception of streams whose part-exchange and recycling are organized by the PRO, the PRO reserves in the various agreements that it concludes with the actors concerned the possibility of ensuring the effective recycling of packaging waste that complies with standards and their traceability to the recycler-end user of the material. For this purpose, the PRO ensures that the buyer provides the following supporting documents:
  • elements of traceability of quantities and qualities based on checks carried out by or on behalf of the buyer;
  • the recycling certificate;
  • proof that any processing carried out outside the European Union, where applicable, took place under conditions equivalent to the legal requirements applicable under Article 6 “Recovery and recycling” of amended Directive 94/62/EC. 

• Control: In order to ensure the accuracy of the supporting documents, the PRO carries out or has carried out the necessary external checks on documents (declaration) or on site at the buyers, and among recyclers-end users of the material (audit). These controls concern at least:
• verification, with those involved downstream of the sorting center until final recycling, of the accuracy of the tonnages declared, taken back and recycled, by sampling batches declared as taken back and establishing the traceability of these batches to the recycler-end user;
• verification that tonnages exported outside the European Union only contribute to recycling objectives if they are recycled under conditions equivalent to the legal requirements applicable under Article 6 “Recovery and recycling” of amended Directive 94 /62/EC;
• verification of compliance with the provisions set out in VI.1.b on material standards.

To meet the obligations of the specifications and guarantee compliance with the performance objectives, financial security and fairness of the system, two types of controls are put in place by Citeo & Adelphe:

• Consistency control: It consists of checking the declarations of the local authorities under contract and their buyers and aims to detect the slightest anomaly from the triggering of the declaration (e.g. inconsistency between the declarations of the authorities and their buyers, lack of traceability to the recycling plant, failure to provide the information and supporting documents required under the export standards for processing carried out outside te European Union, etc.), therefore the risks linked to errors or omissions in declaration are reduced.
• Audit: Carried out by an accredited third-party organization selected by Citeo and Adelphe, the audit covers a smaller number of auditees and a broader field of investigation. These audits can be carried out at any point in the recycling chain, from the sorting or processing operator to the final recipient, but the majority of controls relate to recycling plants. The main objective being to verify compliance with the rules concerning material standards, traceability to the recycler-end user and, for any new non-EU factory declared from the first quarter of 2021, compliance with the export standards such as specified below.

       3. Export referential: The cumulative principles retained in the export referential by Citeo and Adelphe with reference to Article 6 of the amended Directive 94/62/EC, as part of the controls carried out on recyclers-end users located outside the European Union are as follows:

• The company has authorizations to import household packaging waste and carry out its activity;
• The recycling process uses industrial techniques to process household packaging waste under conditions essentially equivalent to the applicable requirements of EU environmental law;
• The company has a waste management system for its activity enabling the disposal of residues from the recycling process under conditions substantially equivalent to the applicable requirements of EU environmental law.

For more details, please see the Citeo's control reference document:  Emballages and the recycling certificate.

The approval specifications provide that at the end of the approval period, approved PROs must have inspected buyers and recyclers-end users representing at least 95% of the tonnages recycled per material.

See 18.4.1.

The columns in the table relate to information on verification procedures used within the national statistical reporting system to validate the accuracy of the data.

The columns in the table relate to information on verification procedures used within the national statistical reporting system to validate the accuracy of the data.

See sections below.

Not applicable, excepted for glass 2023 data. For other materials, France doesn't use this approach.

Primary sources and their shares in the total.

(*) Necessity of a certain minimum amount of waste, turnover etc. to be registered 

Primary sources and their shares in the total.

(*) Necessity of a certain minimum amount of waste, turnover etc. to be registered

Not applicable (France didn't use this approach).

Packaging waste generated estimated by waste analysis

See 18.3.1 about explanations of waste analysis in progress.

See the report “Valorisation des emballages en France – données 2022”: Packaging recovery in France - 2022 data",

 document for the complete detailed methodology, described for each material.

The report “Valorisation des emballages en France – données 2023” will be published on this website.  (autumn)

The source for packaging POM is the production data from the French National Statistics Institute (INSEE), completed by the foreign trade of empty packaging and the simulation of the foreign trade of filled packaging (based on the foreign trade of products itself with the application of a ratio on the quantity of packaged goods and a ratio on the weight of the packaging with respect to the weight of the goods). Nevertheless, a few production data need treatment (as an example the gross production of molded cellulose includes both packaging and non-packaging uses, so a ratio on the packaging use part has been applied): the hypothesis and the data retreatment is explained in the above mentioned file.

1. For "plastic", no correction is applied for the recycling in France (at the calculation point, that is at the output of the shredding line except in cases where this measure point is not possible -integrated production- where the measure is taken at the output of granulation), but a loss rate is applied for the exports (output of sorting plant).

• Recycling in France: An annual declaration campaign of regeneration and transformation units of plastic packaging waste in France is carried out each year by ADEME with the support of the professional organization SRP (Federation of companies running regeneration units of plastic waste in France) and the engineering consultant AJBD. No loss rates are applied because data is measured at calculation point.
• Recycling abroad:
  • The household plastic packaging waste: The household plastic packaging waste collected for recycling is known precisely through the data of the recovery observatory, fed by PROs. Loss rates are then applied.
  • The non-household plastic packaging waste: An annual declaration campaign is carried out each year by ADEME with the support of professional organizations (FEDEREC, FNADE, SNEFID) in order to collect from collectors their tonnages of post-user non-household plastic packaging waste collected and exported abroad. As the tonnages are not measured at the calculation point, a loss rate is applied for the exports (output of sorting plant).

2. For "wood", an impurity coefficient is applied to the measurement point.

3. For "ferrous metals", the measurements points (output of sorting) for both household and non-household packaging need to be corrected by an impurity coefficient and a correction coefficient for humidity.

4. For "aluminium", the measurements points (output of sorting) for both household and non-household packaging need to be corrected by an impurity coefficient and a correction coefficient for humidity.

5. For "glass", the measurements points (output) need to be corrected by an impurity coefficient and a correction coefficient for humidity.

6. For "paper and carboard", the measurement point in France (input to pulper) need to be corrected by a ratio of packaging, an impurity coefficient and a correction coefficient for humidity; the measurement point for the exports (output of sorting) need to be corrected by an impurity coefficient and a correction coefficient for humidity.

For each material, the professional organizations provided, for each waste stream (separate collection, industrial and commercial waste, …), an impurity coefficient (in order to take into account non-target materials) and a correction coefficient for humidity (in order to reflect the natural humidity rate of packaging). For some materials, a global loss rate is used. These coefficients are either based on detailed data from the professional organizations, or on averaged main values also from the professional organizations or on standards. When the measurement is made at the calculation point, no correction is applied.

See the paragraph answer for 18.5.4 for measurement points used for each material.

See the paragraph answer for 18.6.1 for loss rates applied for each material.

Zoom plastic loss rates:

We apply loss rates to the quantity of plastic waste packaging exported for recycling. These loss rates come from two sources: SRP (National union of plastic material regenerators) and Valorplast (company responsible for ensuring and promoting plastic recycling):

- SRP methodology:

The SRP is the French organization representative of companies which manage a regeneration unit of plastic waste in France. Annual SRP statistics come from a compilation of confidential information transmitted by all of its members, following an exhaustive survey carried out each year at the start of year N+1.

The loss rates communicated are the result of dividing the quantity of Regenerated Raw Material (RRM) produced by the quantity of waste used for their production.

- Valorplast methodology:

For the household flows regenerated on French sites, the data comes from the annual reports transmitted by the regenerators to Valorplast.

This is a weighted average based on the tonnages processed by each site.

The regenerators declare for one year:

• Tonnages processed
• The quantities produced (straws or granules)
• Quantities of co-products from the process by category (sludge, wire, labels, fines, sorting rejects, etc.)
• For each co-product it is specified whether it is a recovery (recycling or energy) or an elimination

The recycling rate is based on the quantity of material regenerated in the form of flakes or granules and includes all fractions (co-products) oriented towards recycling (caps, labels, fines, sorting rejects, etc.).

Household plastic flows: The loss rates used in the calculations are an average between loss rates from these two sources.

Non-household plastic flows: The loss rates used in the calculations come from the SRP source.

Not applicable.

Paper mills which treat these carton packaging declare to the ADEME, in the framework of the declaration campaign for paper mills located in France and receiving household and professional post-consumer paper and cardboard packaging waste, the quantity of POLYAL produced and sent for recycling. These tonnages of POLYAL are distributed among the plastic and aluminium sectors in proportion to the share represented by each of these two materials in complexed packaging for liquids: 21% plastic, 4% aluminium considered.

Recycled composite packaging is not reported as recycled paper and plastic packaging (no double counting). Quantities of 5.03.00 and 5.03 A are therefore accounted for 75% in the paper and cardboard material (with deductions for unwanted materials and humidity) because we consider that these flows are composed of 75% paper, 21% plastic and 4% aluminium. The outgoing quantities of POLYAL are therefore be counted pro rata in the plastic material and aluminium material.

Description of the sorted packaging waste to which ALRs are applied, types of sorting plants to which different ALRs apply, the methodological approach to calculating ALRs at such point(s), including the statistical accuracy of any surveys used, or the nature of any technical specifications.

See 18.6.1, 18.6.2 and 18.6.3

Ferrous Metal: 

*Scrap metal (70% IBA coefficient * 71,4% packaging ratio)

Aluminium:

*Scrap aluminium (60% IBA coefficient * 70,8% packaging ratio)

• Wood:

*On new packaging, the density is calculated on a basis of 20% humidity. For panel makers, the dry tonne is reduced to 20% humidity. Thus, all tonnages are estimated considering this humidity of 20% and no humidity correction should therefore be applied.

• Paper and Cardboard:

Rates applied to paper and cardboard packaging recycled in France:

*Type corresponding to selective collection from households.

Rates applied to paper and cardboard packaging recycled abroad:

 Average non-target/waste humidity/natural humidity: household (3,5%/12%/7%), non-household (2,6%/10%/7%) determined on the base of the coefficients applied paper type by paper type for paper and cardboard packaging recycled in France (see above).

• Plastic:

*The loss rate used is global and represents material losses after the first step involved in preparing the material (including target material losses, impurities and a moisture differential from the new material).

See the paragrah answer for 18.5.4.1 for the methodology developped to estimate these plastic lost rates.

• Glass: 

Description, where applicable, of the methodology to exclude non-packaging waste from the reported amount of recycled packaging waste and of the methodology to correct the amount of packaging waste at the measurement point in order to reflect the natural humidity rate of packaging (including by using relevant European standards). Aggregated data across facilities of a similar type is acceptable.

Description of the methodology to exclude waste originating from other countries, where applicable. Aggregated data across facilities of a similar type is acceptable.

We remain at your disposal should you need any additional information.