What are the reporting obligations for third party sellers and marketplaces?

Third party sellers selling their products through marketplaces must report products quantities to their Producer Responsibility Organization (PRO).

The marketplace must report to its PRO:

• The quantity of products sold under its own brands;
• The accumulated quantity of products sold by third party sellers through the marketplace, per product category.  This accumulated tonnage does not account for products sold by third party sellers, which already have a URC.

Reporting schedule:

• For any new producer, the quantity to be declared in year N concerns products placed on the market during the year N-1.
• For a producer which complying with EPR regulations in year N, the quantity to be declared in year N concerns products placed on the market in the year N-1 and possibly the years before, if any retroactivity is required by the PRO (according to each PRO’s specific terms and conditions).

Note: there is no retroactivity for marketplaces as their Extended Producer Responsibility come into effect in 2022, excepted for the tonnages placed on the French market under their own brands.