The traceability data French EPR schemes expect

In France, packaging reuse is no longer a purely voluntary effort. Since 2022, a precise regulatory framework has set targets, and since 2024, companies have had to report their results. Knowing exactly what data this framework requires helps companies prepare for what will become, for many of them, a condition of market access.

The framework that changes everything in 2026

France has created a new extended producer responsibility (EPR) scheme dedicated to commercial and industrial packaging. The décret n° 2025-1081 (French decree) of 17 November 2025, issued to comply with European Regulation (EU) 2025/40, was meant to make this scheme operational on 1 July 2026; the government postponed that date to 1 January 2027 (announcement of 28 July 2026). The scheme covers the packaging of products consumed or used by businesses, and directly affects around 1.7 million companies in France. Its food service component has existed since 2023, with a dedicated eco-organization, Citeo Pro, approved in March 2024.

This extension is more than an administrative detail. It means that companies previously outside the scope of the traditional EPR schemes (household packaging) will in turn have to report their data on packaging placed on the market and reused.

The reuse targets that create the burden of proof

The decree of 8 April 2022 sets annual targets for reused packaging placed on the market, expressed in sales units rather than tonnage: 5% in 2023, rising along a trajectory to 10% in 2027. These targets apply to all packaging categories (household, food service, transport) and concern companies that place more than 10,000 units of packaged products on the French market per year. Eco-organizations must also allocate 5% of the contributions paid by their members to reuse solutions.

A numerical target of this kind cannot remain a statement of intent. It automatically calls for a measurement and reporting system, which is why, since 2024, the companies concerned have been required to report their reuse data.

What Citeo actually asks for

The details of this reporting are telling, because they show what an EPR scheme considers admissible evidence. To validate a monthly reuse declaration, Citeo (a French packaging eco-organization) asks for a structured file, for example a direct export from the company's ERP, which must contain:

• the collection method for reusable packaging,
• the number of reusable primary packaging units collected,
• the type of packaging concerned,
• the collection date, to the month,
• the collection location, identified at minimum by a name and preferably by a SIRET number (French business registration number),
• the identification of the first consolidation point and of any collection service providers, also by name and SIRET,
• the batch number and consignment note number, optional but considered useful for traceability.

This information must be provided every month. For operators affiliated with both Citeo (household packaging) and Citeo Pro (food service), separate supporting documents are required for each packaging category.

This level of detail shows that an EPR scheme is not satisfied with an overall reuse rate. It wants to be able to reconstruct, location by location and month by month, the actual journey of the declared packaging.

Audits and supporting documents

Beyond routine reporting, Citeo states that supporting documents may be requested during spot checks. For mature schemes such as household packaging, an audit framework already governs this kind of verification: matching declared tonnages against documents from take-back operators, verifying traceability down to the final recycler, checking that data is consistent from one year to the next. The commercial and industrial packaging scheme and its reuse component follow the same logic: a declaration must be justifiable after the fact, not simply asserted at the time it is made.

For a company that relies on a reusable packaging provider, the consequence is direct: the provider's ability to supply structured, dated data by location and by batch becomes a selection criterion as important as the physical quality of the packaging.

Towards a common traceability language

To tackle this, GS1 France has launched Le Pack't, an alliance that brings together nineteen initial reuse players around a shared traceability framework for commercial and industrial packaging: three approved eco-organizations (Citeo Pro, Léko Pro, Twiice) and sixteen operators specializing in reuse management, washing and traceability, including MOBIUSpack. The stakes are concrete: without an interoperable system between the different players in the same flow (packaging manufacturer, logistics provider, producer, eco-organization), tracking rotations, managing stock and invoicing containers quickly become unmanageable as volumes grow.

GS1 already offers standardized identifiers suited to this need, such as the GRAI for reusable assets, which can identify packaging by type or unit by unit, depending on the level of granularity required. Over the coming years, the sector's challenge will probably be to align these technical identifiers with the reporting formats eco-organizations expect, rather than letting each player develop its own closed system.

What this means for producers and their suppliers

For a company subject to these obligations, two practical consequences emerge. First, traceability data can no longer be an afterthought: it has to be built in from the design of the reuse system, so that it natively matches the fields the eco-organization expects. Second, the choice of a reusable packaging supplier should weigh its ability to produce this data reliably and consistently as much as the quality or price of the packaging itself.

Companies that prepare for this framework, rather than discovering it at their first mandatory declaration, start with a real operational advantage on a subject the sector is still largely unprepared for.

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