French EPR category guide
French EPR guidance for unused human medicines, including producer scope, MNU registration, IDU numbers and declaration data.
Category overview
The MNU stream supports the collection of unused or expired human medicines held by households and returned through pharmacies. Producer responsibility is tied to the pharmaceutical operator responsible for placing the medicine on the market, while packaging, self-treatment sharps and professional healthcare waste follow different routes.
EPR scope is product-specific. A product can fall under several streams, and its packaging may create an additional obligation. Confirm the current official scope before placing products on the French market.
Scope assessment
These examples are a starting point, not a substitute for checking the detailed legal and eco-organization nomenclature.
Empty primary and secondary medicine packaging belongs to the packaging stream rather than MNU.
Self-treatment sharps belong to the dedicated medical-sharps stream.
Veterinary medicines, food supplements, non-medicinal pharmacy products and healthcare-professional waste are outside the household MNU stream.
Compliance roadmap
Registration is only one part of compliance. Product classification, declarations, records and post-registration duties must remain aligned.
Map each product against the official stream definitions. Review function, materials, intended user, sales channel, components and packaging instead of relying only on customs codes or catalogue labels.
Establish who first places the product on the French market. Depending on the supply chain, this may be a manufacturer, importer, private-label seller, distance seller or marketplace.
Most producers join an approved eco-organization. An approved individual system may be possible, but it carries direct operational, collection, treatment and reporting responsibilities.
Complete the relevant onboarding, provide company and product information and obtain the unique identifier for this EPR stream. Each applicable stream can issue a separate IDU.
Submit products first placed on the French market using the required units, weights and category codes. Eco-contributions are normally calculated from these declarations.
Keep auditable records, renew declarations, monitor fee schedules and eco-modulation, and apply any stream-specific sorting, take-back, consumer-information or prevention obligations.
Declaration readiness
Reliable source data reduces classification errors and makes recurring declarations easier to audit. Keep the calculation method and source records alongside every submitted return.
Declaration periods, category codes, fee scales and minimum contributions vary by eco-organization and stream. Confirm the current member guide before calculating a return.
Medicine presentation, authorisation or registration reference
Number of packs and quantities placed on the market
Pharmaceutical operator and authorisation-holder relationship
Household-use classification and distribution channel
Associated packaging and any separately regulated delivery device
Supplier evidence, internal calculations and copies of submitted declarations
Cross-stream review
EPR categories overlap by design. Assess the complete product, incorporated components, accessories, printed inserts and packaging.
Common questions
No. Empty medicine packaging is handled under the relevant packaging stream. The MNU stream concerns unused or expired human medicines held by households.
No. The household MNU stream concerns human medicines. Veterinary medicines, food supplements and other non-medicinal pharmacy products are outside this specific EPR scope.
No. The IDU is stream-specific. A company covered by several streams can hold several unique identifiers and must maintain the registration and declarations for each one.
It may need to register when it directly places covered products on the French market, including through distance sales. The answer depends on the contractual chain, customer and role of any importer or marketplace.
Category assessment
We can review your products, identify overlapping streams and prepare the information needed for French registration and IDU applications.
This page provides general information and is not legal advice. Product scope, approved schemes, fees and reporting rules can change. Confirm the rules that apply when your products are placed on the French market.
