By C. Chai, director, UIC International B.V. Published 2026-08-21, last updated 2026-08-21. How we write these.
France runs one of the most developed extended producer responsibility systems in the EU and legislates its own language and sorting marks on top of it. Here is what we can source, and where this page stops.
Everything in the EU compliance pillar applies in France first. CE marking, RoHS, the WEEE directive, Regulation (EU) 2023/1542 on batteries and the General Product Safety Regulation (EU) 2023/988 are the frame. France then layers national registration, marking and language obligations on top, and those are the parts a Dutch or German seller usually discovers late.
France operates responsabilité élargie du producteur as a set of schemes called filières. The environment ministry's page on the general framework puts the principle plainly: producers, meaning the people who place certain products on the market, can be made responsible for financing or organising the management of the waste from those products at end of life. Electrical and electronic equipment and batteries are both listed schemes.
The mechanism that makes it visible is the identifiant unique, the unique identifier or IDU. ADEME's page on the IDU states that since 1 January 2022 each producer subject to a REP scheme must hold a unique identifier for each scheme concerned, that it is issued by ADEME, and that it attests to registration in the SYDEREP declaration system. It defines a producer as any business placing products subject to a scheme on the national territory, naming manufacturers, distributors and importers. It also says one IDU is issued per producer per scheme, so a device with a built-in cell is capable of touching more than one.
Two details from the same ADEME page change your documents rather than your product. The identifier must be communicated in your general conditions of sale, and a producer with a website must publish it there too. And for European companies the registration data ADEME asks for includes the intracommunity VAT number, the field a Dutch B.V. will be filling in.
What we will not tell you is whether your SKU and route make you the producer. That depends on who first places the goods on French territory, which is a question about your contracts. Ask ADEME or the eco-organisme. The shape of the duty is in the WEEE registration guide.
France requires a national sorting mark with no EU equivalent. The ministry page cited above sets out the obligation under article L. 541-9-3 of the code de l'environnement, introduced by the loi AGEC: every product covered by extended producer responsibility, other than household glass beverage packaging, carries the Triman marking telling the consumer the product is subject to sorting rules.
The same text adds the part that matters for artwork. The marking is accompanied by information specifying how the waste is sorted or handed in; where different elements are sorted differently, those arrangements are detailed element by element; and the information appears on the product, on its packaging, or failing that in the other documents supplied with it. For a small device with a built-in cell, "element by element" is the phrase to design around, and "the other documents supplied" is why the insert card guide matters.
The loi n° 94-665 du 4 août 1994 relative à l'emploi de la langue française, the loi Toubon, makes French compulsory in the designation, offer, presentation, instructions for use and description of the extent and conditions of the guarantee of a good, product or service, and in invoices and receipts. Where a translation is added, article 4 requires the French to be as legible, audible or intelligible as the foreign language, so a French block in smaller type is not compliant. Article 20 states the law is of public order.
This is where a hardware supplier has to be careful, and where we will disappoint anyone looking for a clean answer. France's vaping-product declarations go to ANSES. The DGCCRF's published questions and answers on electronic cigarettes states that the code de la santé publique provides for a prior declaration of vaping products to ANSES, alongside the prohibition on sale to minors. ANSES's own page describes the framework as flowing from Directive 2014/40/EU and obliging manufacturers and importers to transmit information to the competent authorities before marketing.
Read the ANSES definition before you assume empty hardware is outside it. That page describes vaping products as electronic vaping devices, meaning products or any component of those products, including cartridges, tanks and devices without a cartridge or tank. That is broader than "a device containing nicotine", and it is the reason we will not repeat the comfortable claim that empty hardware is automatically outside the French declaration regime. Our TPD and empty hardware guide sets out the EU-level position; the French application of it to a specific SKU is a question for ANSES or a French adviser, and it is worth the fee.
On disposables, the DGCCRF page states that since February 2025 single-use electronic vaping devices are prohibited, and describes the prohibited product as one pre-filled with a liquid and incapable of being refilled, whether or not it has a rechargeable battery. It adds that the prohibition does not apply to e-cigarette cartridges. It states no position on devices sold with no liquid, and we will not invent one.
Market surveillance for non-food consumer products sits with the Direction générale de la concurrence, de la consommation et de la répression des fraudes (DGCCRF), whose published mission includes checking the conformity and safety of non-food products, ordering seizures, withdrawals and recalls, and overseeing labelling and consumer information. It states that it acts at production, import and placing on the market as well as at distribution, so an importer is in scope, not only a shop.
| Requirement | Body | Typically held by | What the source says |
|---|---|---|---|
| CE, RoHS, battery and safety documentation | EU frameworks | The factory, per SKU | Product-level evidence, unchanged by France |
| REP registration and unique identifier (IDU) | ADEME, via SYDEREP | You | One IDU per producer per scheme, issued by ADEME since 1 January 2022 |
| IDU in conditions of sale and on your website | ADEME | You | Stated on ADEME's IDU page as a communication obligation |
| Triman marking and sorting information | Code de l'environnement art. L. 541-9-3 | You, on artwork | On the product, its packaging, or the documents supplied with it |
| French-language product information | Loi n° 94-665 (loi Toubon) | You | Designation, presentation, instructions and guarantee terms |
| Vaping-product declaration | ANSES | The party placing the finished product on the market | Scope for an empty device is not stated here; ask ANSES |
| Market surveillance | DGCCRF | Applies to you | Production, import, placing on the market and distribution |
Three things, on purpose. No fee schedule, because we found no published one we could cite. No law number for the disposable ban, because the DGCCRF page describing it cites none and Légifrance searches returned no text we could verify. And no statement on whether a Dutch seller needs a French representative, which is exactly the kind of claim this site has had to retract before.
Trade guidance for B2B buyers, not legal advice. We sell empty hardware only (no cannabinoids, no e-liquid), B2B trade only, 18+ / 21+ per market; you are responsible for the fill and for finished-product compliance in your market. The buyer that brands the device and places the finished product on the market carries the national registrations and should take its own French legal advice.
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