FREQENTLY
ASKED QUESTIONS
Welcome to our FAQ page.
Below you’ll find answers to the most frequently asked questions. They’re arranged by subject area. Don’t hesitate to contact us by email should you have any specific questions.
What does EPR stand for?
EPR stands for “Extended Producer Responsibility”. EPR schemes oversee the prevention and management of waste for certain types of products. Their purpose is not only to treat the waste produced but also to prevent waste production by taking action throughout the entire product life cycle. In France, the extended producer responsibility principle (EPR) legally exists since 1975 and is codified in article L. 541-10 of the French Environment Code.
How many EPR schemes exist?
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19 schemes already exist
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5 will be set up in 2022
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4 others to come
What is a producer responsibility organization?
In France a producer responsibility organization is a company governed by private law created by producers and distributors in order to manage, within the context of an Extended Producer Responsibility (EPR) scheme, the end-of-service-life of the goods that they place on the market.
What is the 2022 EPR scheme and what are its consequences?
The EPR (Extended Producer Responsibility) scheme meets collection objectives for waste oils and improves their integration into the circular economy in accordance with specifications set out by the French State. Responsibility is transferred by the State to government-approved producer responsibility organizations representing the entities placing lubricants on the French market (known as “marketers”). An eco-fee is established to fund collection and recycling operations. Under the EPR scheme, marketers transfer their obligations to CYCLEVIA, a producer responsibility organization whose government approval was enacted by the French Order of 24 February 2022 and its publication in the French Official Journal of 23 March 2022.
What is CYCLEVIA?
In France a producer responsibility organization is a company governed by private law created by producers and distributors in order to manage, within the context of an Extended Producer Responsibility (EPR) scheme, the end-of-service-life of oils and encourage their reuse following recycling/regeneration in order to foster a circular economy. CYCLEVIA is a non-profit making organization that must balance its accounts every financial year.
Is empty packaging covered by the EPR scheme?
No. The mineral, synthetic or industrial oil or lubricant EPR scheme only applies to the lubricant itself, not its container.
Are engine coolants covered by EPR scheme?
No. They are not included in the waste oils EPR scheme.
Are all products covered (lubricants/greases/Engine coolants/adBlue)?
Scope: all finished products that are placed onto the market EXCEPT oils that are soluble in water, international marine motor oils, most process oils, petroleum jellies, brake fluids and 2T oils. A table of the products covered by the EPR scheme is available on this site in the “Marketer” section.
WHO IS CONSIDERED A PRODUCER?
Is a distributor considered to be producer?
This depends:
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If a distributor distributes the brand of a manufacturer who is located in France then he’s not considered to be a producer.
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If a distributor sells imported products, he is considered to be a producer and must register with CYCLEVIA.
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If a distributor sells own-brand products, he is considered to be a producer and must register with CYCLEVIA. However, a mandate signed with his manufacturer allows the distributor to delegate marketing declarations and the payment of the eco-fee.
What procedure must be followed if a distributor is considered to be producer?
The distributor must obtain a standard contract from CYCLEVIA and join the producer responsibility organization.
Who is responsible if a producer delivers first-fill engine oil outside of France and the vehicles containing this first-fill oil are imported into France?
The vehicle importer is considered to be a producer because it is the first entity placing the product on the market in France. Please note that when a producer sells outside of France, the quantities sold are not subject to the eco-fee.
Is a car manufacturer who imports vehicles into mainland France or French overseas territories considered to be a producer? And if so, does the manufacturer have to join CYCLEVIA?
Yes. In this case, the importer is considered to be a producer and must pay the eco-fee.
What is the geographical scope for Local Authorities governed by article 73 of the French Constitution?
Guadeloupe, French Guiana, Martinique, Reunion Island, Mayotte, Saint-Martin, Saint-Pierre-et-Miquelon.
Are Monaco and Andorra geographically covered by the EPR scheme?
No. The mineral oil EPR scheme covers all stakeholders present on “French soil” (art. R. 543-3- I of the French Environment Code defining producers, article R. 543-8 of the French Environment Code laying down the producer responsibility organization’s missions, introduced by French Order n° 2021-1395 of 27 October 2021) or on the “national market”. “French soil” is where France exercises its sovereignty. Andorra and Monaco are independent sovereign states.
ECO-FEE
At which date does the eco-fee apply?
The eco-fee applies as from 1 April 2022.
Is the eco-fee reviewed every year?
The eco-fee is reviewed every year and is either increased or decreased.
Why are greases subject to an eco-fee?
This product range is established according to French Order n° 2021-1395 of 27 October 2021. CYCLEVIA defines grease as a finished lubricating product. Furthermore, grease is made from soap or a thicker and a lubricant.
How can entities placing products onto the market invoice their customers?
The eco-fee is an integral part of the product’s manufacturing costs. Marketers have the possibility of including the eco-fee when invoicing their customers.
How is EPR invoiced?
CYCLEVIA invoices the marketer in €/tonne for the products liable. A table of products covered by the EPR scheme is available at cyclevia.com.
How much is the eco-fee?
For 2023, the fee is €89/tonne.
Is the eco-fee the same for all product types?
Yes. The same eco-fee is applied in an identical manner to all products. However, since 1 January 2023, it can be adjusted according to the type of product, some products being more virtuous than others. This is known as “eco-modulation”. The various categories used:
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exempt from the Eco-fee: eco-labelled products;
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bonus, reflected by a lower eco-fee: products with regenerated bases;
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standard: most products;
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penalty, reflected by a higher eco-fee: products classified as hazardous by the H2, H3, H4 CLP classification system;
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not liable (products that are not listed in the eco-fees table).
Do all marketers apply the same rules?
All marketers are free to apply the eco-fee as they so wish, to feature it or not on invoices and to modulate it depending on a product’s properties. However, the sum of the eco-fee set by the producer responsibility organization is the same for everybody.
Do retailers have to apply the eco-fee? And what about the management of their customers’ waste?
The eco-fee is an integral part of a product’s manufacturing cost. It is possible to include this information separately at the bottom of an invoice for example.
How is the eco-fee applied when a producer sells products on an e-commerce platform in France and the platform then exports them?
The products liable for the eco-fee are products which are intended to be used directly on French soil. Exported products are therefore not liable. It is a producer’s responsibility to provide proof that products have been exported.
How can a manufacturer ensure that a distributor has paid its contribution to CYCLEVIA?
When registering with CYCLEVIA a unique identification number is allocated by the ADEME.
Who pays the eco-fee in the case of first-fill oil used in equipment in France?
The first marketer in France is responsible for paying the eco-fee.
Who pays the eco-fee in the case of a distributor brand?
In the case of a distributor brand, the distributor is considered to be a producer. It is however possible to sign a mandate to ensure that the manufacturer takes on this obligation.
Are products sold to French State Departments subject to eco-fees?
Yes. As soon as oils coming within the EPR scheme are sold or provided free or charge to an end-user on the French market the eco-fee must be paid.
Can a lubricant distributor access the table of products covered by the eco-fee?
A table of products covered by the EPR scheme is available at cyclevia.com.
ECO-MODULATION
Do hazard statement codes need to be provided in Lubrec? And if yes, where?
Do not provide the hazard statement codes, simply fill in the tonnages of the products classified as hazardous and the type of product concerned (CPL code) in the declaration form.
Which CLP hazard classifications, categories and statements cause an increase in eco-modulation?
All hazard classifications, categories and statements starting with the letter “H” concerning the finished product as a whole will cause an increase in eco-modulation.
For products with an EU Ecolabel does the product’s registration number need to be provided?
No. Indicate the quantities per product type. This information shall be stated in the supporting documentation to be provided during declaration reporting.
Are Ange Bleu, NF and other environmental certificates eligible for eco-fee exemption?
No. Only the European Union’s Ecolabel established by EC Regulation n° 66/2010 is eligible.
Which “recycled materials” are eligible in the context of the Oils and Lubricants EPR scheme?
Regenerated or recycled oils resulting from the treatment of waste mineral oils in regeneration and recycling facilities.
Does the quantity of regenerated/recycled oil within a product need to be calculated?
No. It is the total quantity of regenerated/recycled oils which is purchased and reincorporated into oils intended for the French market that is declared, not the quantity of regenerated/recycled oil per product type.
How is the 20% bonus for regenerated/recycled oils calculated?
It is calculated as follows: eco-fee in €/t x tonnage regenerated/recycled oils purchased and reincorporated into oils intended for the French market declared in tonnes x 20%. This amount is deducted from the overall invoice.
A company introduces imported products already containing regenerated/recycled oils onto the French market. Which quantity of regenerated / recycled oils should be declared by this company?
The quantity of regenerated/recycled oils to be declared is communicated by the overseas supplier via a certificate, along with the proof of purchase of the regenerated/recycled oils.
How can a quantity of hazardous product or of EU Ecolabel product be declared within the declaration reporting file?
A hazardous product or EU Ecolabel product quantity is declared using a specific “modulation description” code per modulation criterion. These codes can be found in the ”Help” section of your Lubrec account.
Do hazardous products, EU Ecolabel certified products and regenerated/recycled oils purchased abroad need to be declared?
All quantities purchased abroad and placed onto the French market must be declared, even if they are not concerned by eco-modulation.
If a product is covered by 2 eco-modulation criteria how are the
bonus/penalties applied?
There are two possible scenarios:
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The presence of regenerated / recycled oil in products classed as hazardous or Ecolabel certified:
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The regenerated / recycled oil is declared as an overall quantity purchased and is intended for the French market: 20% of the quantity will be deducted from the invoice.
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Products classed as hazardous or with an EU Ecolabel are declared using a CPL code and a penalty (40%) or bonus (total exemption) will be applied to the quantity concerned.
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A entire product that is both hazardous and EU Ecolabel certified: this type of product is subject to a 40% penalty.
How is a product that has both an EU Ecolabel and contains regenerated/recycled oils declared?
Both properties are declared separately:
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For an Ecolabel, the declaration is made using the CPL code.
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For regenerated/recycled oil, the declaration is made using the overall quantity purchased and incorporated into the products sold on the French market.
When should the quantities concerned by eco-modulation be declared?
The quantities are to be declared when the annual adjustments are made, and at the latest, by the 31 January of each year.
Do safety data sheets need to be provided for oils?
This supporting documentation only needs to be provided for oils that are classified as “hazardous” according to the CLP regulation.
SCOPE
INFO-TRI
The information below covers “mineral, synthetic or industrial oils and lubricants” only.
Please note that FAQ are also available on the French Ministry of Ecological Transition website.
Is the “Info-Tri” sorting information label mandatory?
Yes. The “Info-Tri” symbol is mandatory and based on article L. 541-9-3 of the French Environment Code.
Is the “Triman” logo also mandatory?
Yes. Indeed, the “Info-Tri” label constitutes one of two elements provided for in article L. 541-9-3 of the French Environment Code that must be adjacent to each other as required by article R. 541-12-21 of the French Environment Code, i.e.:
- Sign: this is a logo known as the ”Triman logo” or “Triman symbol”;
- Information specifying the methods to sort or deposit product waste.
Is the “Info-Tri” sorting information label intended for private individuals or professionals?
The legal requirement for the “Info-Tri” label covers household products subject to the Extended Producer Responsibility scheme regulations and placed on the French market (see article L. 541-9-3 of the French Environment Code). Products for use by professionals do not fall within the scope of the “Info-Tri” information label requirement.
What should I do with products that can be used by both private individuals and professionals?
Article L. 541-9-3 of the French Environment Code requires that the “Info-Tri” information label is affixed on products subject to an EPR scheme and intended for household use. If the product that is subject to EPR is likely to be placed on the household market then “Info-Tri” label must be affixed. If the marketer is sure that the product cannot be placed on the household market, then the marketer is not required to affix the “Info-Tri” label.
Does the “Info-Tri” label apply to marketplaces?
The legal requirement related to the “Info-Tri” label is valid for all products subject to EPR requirements that are placed on the French marketplace and intended for use by households, including those sold on marketplaces.
Does the “Info-Tri” label apply to products sold to private individuals via a retail network or dealers?
The legal requirement related to the “Info-Tri” label is valid for all products subject to EPR requirements that are placed on the French market and intended for use by households. The sales method (direct sales or via a retail network) does not affect this legal requirement.
Are all the oil categories covered by the Oils EPR scheme concerned by the “Info-Tri” sorting information label?
Yes, as soon as the products are intended for household use and placed on the French market.
Does the “Info-Tri” label apply to two-stroke oils?
No. Two-stroke oils are excluded from the EPR scheme’s scope and are not covered by our scheme’s “Info-Tri” information label.
Does the “Info-Tri” label apply to all types of packaging or only to packaging where the quantity is less than or equal to 5 litres?
The “Info-Tri” label is applicable to products that are subject to EPR requirements and intended for use by households, irrespective of their packaging.
Does the “Info-Tri” label apply to non-recoverable lubricants such as oils for chains, aerosol oils or grease?
All products that are covered by the Oils EPR scheme are concerned by our scheme’s “Info-Tri” label as soon as they are placed on the French market and intended for household use.
How can a private individual dispose of a pot of grease or a chain oil can that has been opened? What instructions apply?
A private individual must comply with the sorting instructions given on the product’s “Info-Tri” sorting information label.
My company sells oils in different types of packaging: HDPE container, recycled HDPE containers, cubitainers (cardboard + flexible plastic bag + hard plastic tap), metal cans. Which ‘Info-Tri” information must I put on my products?
Cyclevia’s “Info-Tri” label applies strictly to products that fall within its scope, i.e. Oils and lubricants listed in article R. 543-3 of the French Environment Code. Cyclevia does not provide information on packaging. This is not within the scope of the Oils EPR scheme.
Does the “Info-Tri” label apply to products sold outside of the French national territory?
No. Article L. 541-9-3 of the French Environment Code makes this “Info-Tri” sorting information label mandatory and is only applicable to products placed on the French market. This is why the letters “FR” appear on our “Info-Tri” label.
When was the Info-Tri label officially validated?
Our Info-Tri label was validated by the French Government on 20 June 2023.
What is the deadline for implementing the “Info-Tri” label requirement?
You have up to 12 months to implement the “Info-Tri” label from the date of its validation by the authorities, i.e. by 20 June 2024 at the latest.
Will packaging products using packaging without the ‘Info-Tri” label still be authorised after the 20 June 2024?
No. In accordance with article R. 541-12-18 of the French Environment Code, “producers [...] shall affix the sign and its information twelve months at the latest following the date at which it was validated” ”
The “Info-Tri” label for our EPR scheme was validated on 20 June 2023. All product packaging manufactured or imported after the 20 June 2024 must have the “Info-Tri” sorting information label on it.
After the 20 June 2024, can stockpiles without the “Info-Tri” label be sold?
Yes. In application of article R. 541-12-18 of the French Environment Code, product stockpiles without an ‘Info-Tri” label can be sold up to 6 months after the deadline for implementing the label, i.e. up to 20 December 2024 at the latest.
What are the minimum dimensions for the “Info-Tri” sorting information label?
The minimum size for using our “Info-Tri” label is:
• 28 mm in width X 11 mm in height, for its horizontal version;
• 9 mm in width X 25 mm in height, for its vertical version;
Are there any exceptions to the requirement to affix the “Info-Tri” label on products?
Yes. Article R. 541-12-21 of the French Environment Code provides for the following exceptions: “When the surface area of a product’s longest side or of its packaging is less than 10 square centimetres and no other document is supplied with the product, the sign and its information may be displayed in a paperless format. When the surface area is between ten square centimetres and twenty square centimetres, only the information is given in the paperless format.
For products with cylindrical or spherical packaging, the surface areas of ten and twenty square centimetres previously cited are increased to twenty and forty square centimetres. ”
Can the “Info-Tri” label be affixed as a sticker?
Yes. Article R. 541-12-21 of the French Environment Code states that “this label and its information can be affixed as a sticker.”
Does the Oils scheme “Info-Tri” label need to be affixed on a product that already has the Packaging scheme’s “Info-Tri” label?
Yes. Both “Info-Tri” sorting information labels need to appear on the packaging because they give complementary instructions: for the packaging itself and for the product contained within the packaging.
Is it mandatory to have both Triman logos on the same label: one for the Packaging scheme and another for the Oils scheme?
No. You have the possibility of either affixing a single Triman logo to both sets of information specifying the sorting methods so long as these are placed next to one another, or affixing each schemes entire “Info-Tri” sorting information label.
Is there a risk of being fined in the event of non-compliance to the “Info-Tri” rules?
Yes. Under Article L. 541-9-4 of the French Environment Code any “Info-Tri” requirements that are not met are open to an administrative fine, the amount of which may be as high as €3,000 for a natural person and €15,000 for a legal entity.
Is there a special system for private individuals? Does a private individual have to return waste oil to a dealer?
A private individual must return waste oil to a municipal recycling facility (MMRF) equipped with a specific waste oil container.
Does CYCLEVIA manage the replacement of damaged waste oil containers?
Local authority containers are managed through annual funding according to the quantity collected by the local authority.
What does an operator need to do if it collects oils from a municipal recycling facility but is not yet registered with CYCLEVIA?
In accordance with Order 2021-1395 of 27 October 2021 and as from the date of CYCLEVIA’s government approval, all oil collection operators are required to register with the producer responsibility organization. It is therefore essential for a local authority to deal with a registered collection operator.
What is the oil recovery process?
It remains unchanged in relation to the situation before government approval was granted. However, cost-free collection applies as from 1 January 2022 in accordance with Order 2021-1395 of 27 October 2021.
Is there a list of approved collection-transfer station operators or are they all free?
All collection-transfer station operators must be registered with a producer responsibility organization in order to be able to conduct their business. The collection-transfer station operators registered with CYCLEVIA can be consulted on our internet site under the “Collection” section (search by county - “département”).
If a company has comments regarding the standard agreement, is it possible to discuss them?
CYCLEVIA is very mindful of dialogue. However, these agreements are identical for the entire sector and their terms and conditions are now defined.