FR Early Warning Profile FINAL

Country profile
Early warning assessment related to the 2025 targets

for municipal waste and packaging waste
France
June 2022
Contents
Acknowledgements................................................................................................................................. 1
1 Introduction ..................................................................................................................................... 2
1.1 Background and purpose ........................................................................................................ 2
1.2 Approach ................................................................................................................................. 2
1.3 Country profile – context parameters .................................................................................... 3
2 Success and risk factors likely to influence future performance ..................................................... 9
2.1 Target for preparing for reuse and recycling of municipal waste........................................... 9
2.1.1 Current situation and past trends ....................................................................................... 9
2.1.2 Legal instruments .............................................................................................................. 11
2.1.3 Economic instruments ...................................................................................................... 13
2.1.4 Separate collection system ............................................................................................... 15
2.1.5 Extended producer responsibility (EPR) and similar schemes .......................................... 19
2.1.6 Treatment capacity for bio-waste..................................................................................... 21
2.2 Target for the recycling of packaging waste ......................................................................... 23
2.2.1 Current situation and past trends ..................................................................................... 23
2.2.2 Legal instruments .............................................................................................................. 27
2.2.3 Economic instruments ...................................................................................................... 28
2.2.4 Separate collection system ............................................................................................... 30
2.2.5 Extended producer responsibility (EPR) and similar schemes .......................................... 32
2.3 Target on landfill of municipal waste.................................................................................... 35
2.3.1 Current situation and past trends ..................................................................................... 35
Conclusion ............................................................................................................................................. 38
2.4 Prospects for meeting the recycling target for municipal solid waste ................................. 38
2.5 Prospects for meeting the recycling targets for packaging waste ........................................ 40
2.6 Prospects of meeting the landfill of municipal waste target ................................................ 41
List of abbreviations .............................................................................................................................. 42
References ............................................................................................................................................ 43
Annex 1 Detailed scoring of success and risk factors ........................................................................... 46
Acknowledgements
This assessment has been prepared by the ETC/WMGE and the successive ETC/CE under guidance of
the European Environment Agency and with inputs from a consortium led by Rambøll Group under
contract with the European Commission. It builds to a large extent on the answers provided by the
Ministry for the Ecological Transition/CGDD/SDES (Commissariat général au développement durable
(CGDD) / Service des données et études statistiques (SDES)) in March 2021 to a questionnaire to a
questionnaire developed by the EEA and ETC/WMGE. The EEA and ETC/CE would like to thank the
French authorities for the information provided and for the kind review of drafts of this assessment in
2021 and May 2022.
1
1 Introduction
1.1 Background and purpose
The Waste Framework Directive 2008/98/EC (as amended by Directive (EU) 2018/851) includes a
target to recycle and prepare for reuse, by 2025, 55 % of municipal waste generated. The Packaging
and Packaging Waste Directive (94/62/EC as amended by Directive (EU) 2018/852) includes targets
for the recycling of packaging waste, both in total and by material, to be achieved by 2025. The Landfill
Directive (1999/31/EC as amended by Directive (EU) 2018/850) requires to limit the landfilling of
municipal waste to 10 % of the generated municipal waste by 2035. The Directives also foresee that
the European Commission, in cooperation with the European Environment Agency, publishes early
warning reports on the Member States’ progress towards the attainment of the targets, including a
list of Member States at risk of not attaining the targets within the respective deadlines, three years
ahead of the target dates. This assessment is a contribution from the EEA to the early warning reports
according to Article 11b Waste Framework Directive and Art. 6b Packaging and Packaging Waste
directive.
This document is an early warning assessment for France. The document is based on the analysis of a
number of factors affecting recycling performance (success and risk factors). The assessment aims at
concluding whether France is at risk of missing the targets for municipal waste and packaging waste
set in EU legislation for 2025. In addition, it provides a preliminary assessment of the prospects for
meeting the 2035 target for landfilling of municipal waste.
The assessment takes into account information that was available before 10 May 2022.
1.2 Approach
The assessment follows a methodology developed by the EEA and ETC/WMGE and consulted with the
Eionet in 2020 (ETC/WMGE, 2021), which was adjusted in 2021 taking into account experiences with
applying the methodology in 2021 (ETC/CE & ETC/WMGE, 2022). This methodology uses a set of
quantitative and qualitative success and risk factors that have been identified to affect the recycling
performance. The assessment is to a large extent based on the information provided by the Member
State in the reply to an EEA-ETC/WMGE questionnaire as well as on available data and information
from Eurostat and other relevant sources. In addition, a consortium under contract with the European
Commission (led by Rambøll Group) has conducted a critical review of the draft assessment in
Q4/2021 and provided further information.
More specifically, chapter 2.1 assesses the likelihood for France to achieve the target to prepare for
reuse and recycle at least 55 % of municipal solid waste (MSW) for 2025. Chapter 2.2 assesses the
likelihood for France to achieve the overall packaging waste and specific packaging materials’ recycling
targets for 2025. Chapter 2.3 examines the prospects for France to landfill less than 10 % of the
generated municipal solid waste by 2035. The official early warning assessment for the landfilling
target is only due in 2032 and accordingly the assessment contained in Chapter 2.3 is only preliminary.
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1.3 Country profile – context parameters
Municipal waste generation and treatment
Municipal waste generation in France has remained rather stable over the past ten years. In 2020 the
country generated 36.1 million tonnes of municipal waste (Figure 1.1). This corresponds to 5371 kg/cap
in 2020, which is above the (estimated) EU average of 505 kg/cap for the same year. The municipal
waste generation data for 2020 include bio-waste that is recycled at source (home-composted).
Over the past five years, the recycling rate has decreased by 0.2 percentage points. French authorities
have, however, indicated that 2019 and 2020 data are on a broader scope than in the preceding years:
they include private collection, not just public waste management service collection, and recycling
includes home composting and metal recovery from incineration bottom ash. On the other hand, the
calculation point for recycling was chosen as close as possible to the point where a recycled material
is produced, by only accounting for material that leaves the processing facilities. The recycling rate lies
currently at 42.7 %. This is due to a number of effective measures, including a landfill ban and a
disposal tax diverting waste to recycling.
The country has a relatively high level of incineration of municipal waste generated, which has been
stagnating at about 35 % during the period 2016 – 2019, has gone up in 2020 to 38.1 %. France’s
recycling rate has been steadily increasing from 42.9 % in 2016 to 45.1 % in 2018, however going down
since then. In 2020 the recycling rate stands at 42.7 %. In parallel, the landfilling rate has decreased
from 22.4 % in 2016 to 18.1 % in 2020.
1
Provisional estimate, this figure has been revised but not yet officially released by EUROSTAT.
3
Figure 1.1 Municipal waste generation and treatment in France between 2016 and 2020, in thousand
tonnes
Note: Data for 2016 flagged as Eurostat estimates; data for 2018 and 2020 flagged as Eurostat
estimates and provisional
Source: Eurostat (2022a)
Legal Framework
In France, the Code de l’environnement groups together legal texts relating to environmental law.
Waste management is regulated in Book V, which repeals and replaces all the decrees, by regulatory
articles that take up their content (Code de l’environnement, 2000).
Until 2007 the heart of waste management legislation was the law n°92-646 of 13 July 1992 on the
elimination of waste and on installations classified for environmental protection, aiming at, inter alia,
reducing waste generation, promoting material or energy recovery and banning landfilling of
untreated waste (Loi No 92-646, 1992). This law did not specify any quantitative targets, except for
the landfill ban of untreated waste to be enforced by 2002. In 1993 a landfill tax was introduced and
since 2002 there has been a ban on landfilling of untreated waste. In 2008, an escalator for both landfill
and incineration tax was introduced (EEA, 2016).
Starting in 2007, a waste management strategy has been developed with a comprehensive
stakeholder engagement process, known as the Grenelle Environnement process in France. The results
of this consultation process, involving representatives from government, local authorities, industry,
unions, professional associations and non-governmental organizations, were the basis of the new
legislative framework with specific waste management targets at the national level. In 2009, the law
n°2009-967 of 3 August 2009 on the implementation of the Grenelle de l'environnement, known as
the first Grenelle Law, was implemented. The key points of this law included, inter alia, the reduction
of the generation of household and similar waste by 2014, the reduction of waste sent to landfill or
incineration by 2012 and the implementation of economic instruments, such as pay-as-you-throw
schemes by 2014. Quantitative targets of this law included, amongst others, an increase of recycling
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rates of household and similar waste of 35% by 2012 and 45% by 2015, and recycling rates of 75% for
non-household waste (excluding construction and demolition and agriculture) (Loi n° 2009-967, 2009).
In France, there is a strong national focus on extended producer responsibility (EPR) schemes to
promote recycling in particular sectors. The principle of EPR was first applied to household packaging
waste in 1993. Starting from 2001, the scope of EPR has been continuously extended to a range of
other product categories and material streams, such as WEEE, end-of-life vehicles (ELVs) and tires,
batteries, printed/graphic paper, textiles, furniture, household healthcare products and so on. Since
2016 there is even an EPR scheme for leisure boats (Agence de la transition écologique (ADEME),
2020).
EPR schemes are also key in law n° 2015-992 of 17 August 2015 on the energy transition for green
growth, (re)defining France’s waste and circular economy policy. It aims to move from the
management of waste to a better management of resources and establishes a waste prevention target
to cut household waste production by 10 % of 2010 levels by 2020 (Loi n° 2015-992, 2015). This law
also contains a number of measures designed to reach this target: it makes planned obsolescence
illegal, obliges food retailers to donate unsold goods to charity to reduce food waste and in general
strongly promotes waste prevention. This law also establishes waste recycling targets for the period
from 2020 to 2025, namely 55 % and 65 % respectively of all non-hazardous non-inert waste; it
extends separate collection to all organic waste by 2025 for all producers, including households.
Since 2016, professionals are obliged to sort at source and separately collect five waste streams:
plastics, paper, glass, wood and metal. This obligation was introduced by the decree of 10 March 2016
(Décret n° 2016-288 du 10 mars 2016, 2016). Since 16 July 2021, construction and demolition
professionals are obliged to sort at source and separately collect seven waste streams: paper, metal,
plastic, wood, glass, mineral fractions and plaster. This obligation was introduced by the decree
n°2021-950 of 16 July 2021 (Décret n° 2021-950 du 16 juillet 2021, 2021). This decree also introduces
the obligation of source separation and separate collection of textile waste from 1 January 2025 for
all professionals (Ministry for the Ecological Transition/ CGDD / SDES, 2021). Because of the focus on
separate collection, mechanical biological treatment (MBT) of waste is declared obsolete and excluded
from any new public financing for MBT installations. For incineration, treatment capacities should not
increase and their energy efficiency should improve, partly through phasing out installations without
energy recovery by 2025 (Loi n° 2015-992, 2015).
In 2016, France also adopted a decree stating that landfill capacities should be reduced by 30 % by
2020 compared to their 2010 levels, and by 50 % by 2025. Incineration is, with the new decree, to be
reduced by 25 % by 2020 and halved by 2025/2026. The decree also stipulates that waste
management plans must identify shared facilities for collecting and treating bio-waste from
households, businesses and farms (Décret n° 2016-811 du 17 juin 2016, 2016).
The ambitious roadmap for the circular economy adopted in April 2018 sets out some of the steps
that need to be taken to promote sustainable design, reuse, repair and recycling. The roadmap aims
to decrease resource use and consumption by 30 % by 2030, halve the amount of non-hazardous
waste landfilled by 2025, introduce the ambitious target of 100 % plastics recycling by 2025 and create
300 000 new jobs. Through EPR schemes, producers will be obliged to inform consumers about a
product’s lifespan, and repairability based on a specific new index (EC, 2019c). In March 2018, France’s
Ministry for Solidarity and Ecology Transition created the Green Transition Accelerator (AcTE), a think
tank that brings together companies, training centres and representatives of employers’ organisations
and trade unions. AcTEs’ goal is to promote green growth, support innovation, realise the circular
economy and ensure climate plans are implemented. Policies and activities supporting the transition
5
to a circular economy transition have become increasingly popular also in the administrative regions,
complementing the central government’s action (EC, 2019c).
In February 2020, the AGEC law on the fight against waste and on the circular economy (Loi n° 2020-
105, 2020) was adopted. It contains a large range of measures with relevance for municipal waste and
packaging waste, and it partly transposes the EU waste legislation amendments adopted in 2018.
Several new measures foster the reuse and prevention of waste and recycling, including measures
that aim to make sorting of waste more efficient, and phasing out single-use plastics.
The AGEC Law strengthens the framework of EPR channels and has included several provisions related
to packaging and eco-modulation. It obliges Producer Responsibility Organisations (PROs) to
participate in national collection targets for the recycling of plastic bottles for beverages, to contribute
to achieve the national target of 5% of reused packaging placed on the market in 2023, and to
reinforce the modulation of EPR contributions to encourage the integration of plastics from recycling,
while penalizing signs and markings likely to lead to confusion about the sorting rules. The
implementation of new EPR obligations, (e.g. for catering packaging and industrial and commercial
packaging), the extension of sorting instructions etc. are expected to help increase recycling rates for
packaging and municipal waste (Ministry for the Ecological Transition/ CGDD / SDES, 2021).
As part of the transposition of Law No. 2020-105, Decree N° 2021-1199 on the conditions for the
disposal of non-hazardous waste in non-hazardous waste storage facilities and in non-hazardous
waste incineration facilities was published in September 2021. More specifically, this decree, with the
addition of a ministerial order (Arrêté du 16 septembre 2021), defines 1) recoverable non-hazardous
waste for which landfilling is progressively prohibited and 2) the modalities for justifying compliance
with sorting obligations to be able to dispose of non-hazardous waste in landfills or incineration plants.
The first measure takes into account the deployment of EPR channels on French territory and the
evolution of source separation. The share of recoverable waste sent to landfill as defined in the draft
decree will therefore decrease over time, following the entry into force of these various measures
(Ministry for the Ecological Transition/ CGDD / SDES, 2021).
Waste management plan(s)

The National Waste Management Plan (NWMP) of France was legally adopted in October 2019 by the
Ministry for Ecological Transition and Solidarity (Plan National de Gestion des Déchets, 2019) and
updated in January 2020. This is the first National Waste Management Plan for France. This national
plan complements the regional system provided for by the NOTRe law (Loi portant nouvelle
organisation territoriale de la République), through more detailed regional waste prevention and
management plans, which are under revision in most regions.
Currently, 18 regional WMPs are being updated, covering most regions. The NOTRe law, passed in
2015, makes WMPs and WPPs the responsibility of the regions. The content of the regional plans is
specified in a Decree issued in 2016 and includes, inter alia, provisions for regional Circular Economy
(CE) action plans.
The application period of the National WMP starts in 2019; the evaluation of the WMP will be carried
out within the deadlines set by the Waste Framework Directive and it will be revised if necessary. No
end date is provided in the plan with regard to the application period.
Article L.541-11-1 of the Environment Code provides for the Minister responsible for the environment
to draw up national prevention and management plans for certain categories of waste, the list of
6
which is drawn up by decree by the Council of State, on the basis of their degree of harmfulness or
their particular management characteristics. To date, these provisions have not been implemented
for any type of waste. However, it should be noted that there is an inventory of waste containing PCBs
(Articles R.543-26 and following of the Environment Code).
The plan covers all types of waste with dedicated sections for targeted waste streams.
The WMP aims at gradually extending the sorting instructions to all plastic packaging throughout the
country before 2022, with a view, as a priority, to their recycling, taking into account the prerequisites
resulting from the experimentation with the extension of the instructions sorting of plastic packaging
initiated in 2011. Furthermore, the WMP aims to increase the quantity of waste subject to recovery
in the form of material, especially organic, by directing these towards recovery channels, respectively,
55 % in 2020 and 65 % in 2025 of non-hazardous non-inert waste, measured by weight, and to recover
70 % of the waste from the building and public works sector in the form of material in 2020. All the
targets are integrated into the French Environmental Code.
As regards packaging, the WMP sets a target of 100 % separate collection for household plastic
packaging by 2025.
Packaging waste generation and treatment

In France, 12.6 million tonnes (187 kg/cap) of packaging waste were generated in 2019, which is
above the EU average of 177 kg/cap. Packaging waste generation decreased by 3 % from 193 kg/cap
in 2010 to 187 kg/cap in 2019 (Figure 1.2).
Figure 1.2 Packaging waste generation in France between 2010 and 2019, in kg per capita
Source: Eurostat (2022b)
France has traditionally reported rather high levels of recycling for most types of packaging waste
fractions. Overall packaging waste recycling levels stood at over 50 % already in 2004. In more recent
years, packaging waste recycling has been stable, but slightly below 70 %, mainly driven by paper and
7
cardboard, metals and glass packaging recycling. Wooden packaging is stagnating at about 30 %.
However, the year 2018 represents an exception with a recycling rate of 55.6 %. Plastic packaging
recycling stands at the lowest level, compared with the other fractions at 26.9 % in 2019.
The high historical levels of packaging waste recycling can be explained by the fact that household
packaging waste was the first sector to implement the principle of EPR as early as 1992 in France
(Agence de la transition écologique (ADEME), 2020).
Capture rates for recyclables

The capture rate is a good performance indicator of the effectiveness of the separate collection
system. The capture rate is calculated by dividing the separately collected weight of a certain material
for recycling by the weight of the material in total municipal waste. For France, Table 1.1 shows the
calculated capture rates for different waste fractions.
Table 1.1 Capture rates for different waste fractions in France
Residual Residual Separately Materials in Capture rates

waste waste collected total MSW (%)
composition composition amounts (tonnes)
(%)(b) (tonnes)(a) (tonnes) (b)
Reference year 2019 2019 2019
Mixed municipal waste, total 16 610 681
Paper and cardboard 15 % 2 494 924 860 177 3 355 101 26 %
Metals 3% 571 407 588 044 1 159 451 51 %
Glass 5% 888 671 2 154 514 3 043 185 71 %
Plastic 15 % 2 440 109 43 639 2 483 748 2%
Bio-waste 33 % 5 441 659 5 298 609 10 740 268 49 %
Textiles 4% 661 105 126 177 787 282 16 %
Wood 0.3 % 53 154 1 237 355 1 290 509 96 %
Included in
Co-mingled dry recyclables - 2 994 439 - -
the above
(a) Note: Share of material in residual waste (household waste only) multiplied with the amount
of residual waste in 2018 as reported in the questionnaire by the Ministry for the
Ecological Transition/ CGDD / SDES (2021)
(b) Source: As reported in the EEA-ETC/WMGE questionnaire by the Ministry for the Ecological
Transition/ CGDD / SDES (2021)
The capture rates for municipal waste fractions amount to 49 % for bio-waste (see also section 2.1.7),
71 % for glass, 16 % for textiles and 96 % for wood. In addition, capture rates are calculated as 2 % for
plastic, 26 % for paper and cardboard, and 51 % for metals, but these capture rates only refer to those
materials that are collected as mono-fractions, while paper and cardboard, plastics and metals are to
a large extent collected commingled and then sorted. This means that the capture rates for these
three materials are likely much higher but challenging to quantify.
The capture rates indicate that there is especially room for improvement to capture higher shares of
the generated textile wastes, but also to some extent bio-waste and glass, while no conclusion is
possible for plastics, metals and paper/cardboard.
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2 Success and risk factors likely to influence
future performance
2.1 Target for preparing for reuse and recycling of municipal waste
This chapter aims at assessing the prospects of France to achieve the 55 % preparing for reuse and
recycling target for municipal waste in 2025. For a detailed description of the methodology followed,
the development of success/risk factors and their impact on recycling, please consult the methodology
report (ETC/CE & ETC/WMGE, 2022) .
2.1.1 Current situation and past trends

SRF MSWR-1.1: Distance to target
The overall recycling rate of France shows a small increase between 2016 and 2019, but went down
again after that and lies at 42.7 % in 2020 (Figure 2.1). As already explained in section 1.3, the figures
corresponding to 2019 and 2020 are, however, not entirely comparable with the data for the previous
years, although no break of series has been flagged in the corresponding Eurostat database.
In this analysis the recycling rate is calculated by dividing the summed amounts of recycling of
materials and of composting and digestion by the total generated amounts. The data source used is
the Eurostat data set Municipal waste by waste management operations [env_wasmun] (following the
OECD/Eurostat Joint Questionnaire); Data reported by Member States according to Article 10.2(a) of
the Waste Framework Directive are not used for this assessment as the reporting methods differ by
Member State, resulting in a lack of comparability between Member States. The data source used
here is assumed to be the best available proxy, given that data in accordance with the rules on the
calculation of the attainment of the targets as defined in Article 11a are not yet available.
9
Figure 2.1 Recycling rate in France between 2016 and 2020, in percentage
Note : Data for 2016 flagged as Eurostat estimates; data for 2018 and 2020 flagged as Eurostat
estimates and provisional
Source: Eurostat (2022a)
The actual distance to the target for the most recent data point is a key factor determining the
likelihood of meeting/not meeting the target. The closer the Member State is to the target already,
the more likely it becomes that the target will be met. For France, the recycling rate is 42.7 % in 2020,
which is 12.3 percentage points away from reaching the targets of 55 %. Furthermore, the data
reported to Eurostat, which are used in the current assessment, include metals recovered from
incineration residues and bio-waste recycled at source.
However, the data used for this analysis are not yet fully in line with the new calculation rules, as
defined in the Commission Implementing Decision (EU) 2019/1004 (EC, 2019b), that will modify the
recycling measurement point. A few Member States have provided quantified estimates indicating
how the application of the new reporting rules would influence the recycling rate (compared to the
data reported to Eurostat under the Joint Eurostat/OECD questionnaire), resulting in reductions
between 3.8 and 13 percentage points, and on average 5.5-6.7 percentage points. While the effect in
France will depend on the influence of the change of the recycling measurement point, a reduction
with 5 percentage points is assumed for this assessment, bringing the recycling rate down to 37.7 %
in 2020. This assumption results in a change of the assessment for this SRF.
10
Summary result
Based on the currently available data, France’s recycling rate was 42.7 %
in 2020, 12.3 percentage points below the 2025 target. Considering
Distance to target > 15
however the impact of the new calculation rules, we assume a reduction
percentage points
with 5 percentage points for this assessment, resulting in a recycling rate
of 37.7 %, 17.3 percentage points below the target.
The currently available Eurostat data for France do not yet reflect the
calculation rules applicable to the target. However, a recycling rate which
Robustness of the underlying
would be 5 percentage points below the currently reported one (due to
information
correction for the new rules), leads to a lower evaluation score for this
SRF.
SRF MSWR-1.2: Past trend in municipal solid waste recycling rate

The recycling rate over the past five years shows a decrease from 42.9 % in 2016 to 42.7 % in 2020
(Figure 2.1), a small drop of 0.2 percentage points. Meeting the 2025 target will require a significant
increase in pace as compared to the average yearly improvement over the previous five-year period.
More efficient separate collection practices with a special focus on plastics, a significant increase in
recycling of bio-waste and a significant increase in the landfill tax are seen as the key measures to
achieve the 55 % recycling rate by 2025 by the French government. Moreover, new EPR schemes are
being developed, such as EPR for professional packaging, sports and leisure items, do-it-yourself items,
construction and demolition products and materials, etc.
Summary result
The recycling rate has decreased by 0.2 percentage points over the past
RR < 45% and increase in last 5
five years. For France the application of the new calculation rules would
years < 10 percentage points
result in an estimated recycling rate of 37.7 %.
Robustness of the underlying There are no breaks in the time series data. The recycling rate is likely to
information change once the new calculation rules will be applied.
2.1.2 Legal instruments

SRF MSWR-2.1: Timely transposition of the revised Waste Framework Directive into national law
Timely transposition of the Waste Framework Directive as amended by Directive 2018/851 into
national law within the foreseen period is key for a waste management system in line with EU
requirements.
Although 44 national transposition measures have been communicated by France (EUR-LEX, 2021a),
as of May 2022, the revised Waste Framework Directive has not yet been fully transposed into national
law.
Summary result
The revised Waste Framework Directive has not yet been fully
No full transposition yet
transposed into national law.
Robustness of the underlying The information has been provided by the European Commission and
information reflects the status of November, 12th 2021.
11
SRF MSWR-2.2: Responsibilities for meeting the targets, and support and enforcement mechanisms, e.g.
tools, fines etc.
Clearly defined responsibilities, enforcement and support mechanisms for meeting the targets across
different entities and governance levels are important for achieving high recycling rates. The clearer
the responsibilities for meeting the targets and the accountability for failing the targets are, the higher
the chance that the targets will be met.
The French state is the only one responsible for achieving the objectives set out in the Environmental
Code, mostly being transposed from European Directives (Code de l’environnement, 2000). These
national objectives must be broken down at the regional level, by drafting regional waste prevention
and management plans which every regional Council must adopt, as described in L. 541-13 and R. 541-
16 and the following articles of the Environmental Code. Decisions taken by local authorities must be
in line with the framework defined in the regional waste management plan (cf. article L. 541-15) (Code
de l’environnement, 2000).
A number of obligations of means are defined for other stakeholders, meaning that they have to do
the best they can do for a specific goal, but without the guarantee that this goal will be reached. The
State promulgates, for example, the establishment of EPR schemes by legislative and regulatory
means and defines by decree the specifications of the PROs. Depending on the model chosen, an
obligation of results may be included in the specifications. Private actors are in charge of waste
collection and treatment by legislative and regulatory means. If local authorities decide to delegate
their powers, they can define responsibilities for these private players by contractual means (Ministry
for the Ecological Transition/ CGDD / SDES, 2021).
With respect to achieving the recycling rates of MSW and packaging waste the responsibilities are
divided between
• the central State, namely the Ministry for the Ecological Transition, the Ministry of the
Interior, the Ministry of Territorial Cohesion and Relations with Territorial Communities
and ADEME, the French Environment Agency;
• the territorial authorities, namely the regional Council, the community of municipalities,
the urban communities or metropolitan areas and municipalities; and
• the PROs.
PROs, created within the framework of EPR, aim to prevent and manage the production of specific
waste streams. The EPRs created for household packaging, graphic papers, furniture, textiles, specific
diffuse waste, sports and leisure articles, WEEE, sanitary textiles, etc. have an influence on the
recycling rate of packaging and municipal solid waste.
There are two operating models of PROs depending on the sector:
• Contributing or financial PROs collect eco-contributions from producers and redistribute them
to local authorities which collect and sort this waste. This model is applied e.g., for household
packaging and graphic paper waste;
• Operational PROs collect eco-contributions from producers and use these funds to contract
itself with service providers who collect and treat waste.
PROs, as included in their specifications, have an obligation of means and results. This obligation is
included in the specifications of the PRO (Ministry for the Ecological Transition/ CGDD / SDES, 2021).
The central State through the ministries and ADEME provides support to local authorities and private
actors via financial support (e.g. calls for projects from ADEME, recovery plan). Further, it provides
training materials and resources to local authorities, such as Waste and key figures by ADEME.
12
The state services, ADEME and the regional directorate for the environment, planning and housing
(DREAL) provide technical support to local authorities. DREALs also influence the recycling rate by
ensuring compliance with regulations in classified facilities for environmental protection, that is, waste
sorting centres, incineration plants, landfills, etc., through inspections. The regions are supporting
local authorities by setting waste management visions and goals (Ministry for the Ecological
Transition/ CGDD / SDES, 2021).
The local authorities draw up municipal waste prevention programs indicating the waste reduction
objectives and the measures put in place to achieve them. They also set up awareness-raising actions
for citizens and private actors. They are also financially supported by the European Regional
Development Fund. The PROs provide also financial and/or organizational support for the collection
and treatment activities (Ministry for the Ecological Transition/ CGDD / SDES, 2021).
If a PRO does not take enough actions in view of what is asked in the specifications, it can be fined
under article L. 541-9-5 of the Environmental Code. If inefficient, the PRO can receive a formal notice
to undertake the necessary actions (article L. 541-9-6 of the Environmental Code).
The fines referred to in article L. 541-9-5 are mainly applicable to producers that do not comply with
their EPR obligations. These provisions are enforced and have been supplemented by article 294 of
the Law n° 2021-1104 of 22 August 2021.
The local authorities cannot be fined if they do not take enough action. However, they will be
penalised through a higher taxation if municipal waste prevention programmes or other local actions
do not achieve to limit the generated waste volumes (Ministry for the Ecological Transition/ CGDD /
SDES, 2021).
In summary, responsibilities are well defined, although responsibilities to organize MSW management
are somewhat fragmented. In addition, support mechanisms are in place.
Summary result
Clearly defined responsibilities
and good set of support tools Responsibilities are defined and support mechanisms are in place, but
but weak/no enforcement there seem to lack motivating enforcement mechanisms towards the
mechanisms for meeting the responsible entities if the targets are not met.
recycling targets
Robustness of the underlying Credible information received from the French authorities through the
information EEA-ETC/WMGE questionnaire.
2.1.3 Economic instruments

SRF MSW-3.1: Taxes and/or ban for landfilling residual- or biodegradable waste
Bans and taxes on landfilling of residual municipal waste can help to discourage strong reliance on
residual waste treatment and thus support recycling.
Since 2002, there is a ban on landfilling of untreated waste in place in France. According to the NAF
ITEC/2017/0961 it is considered that the obligation of pre-treatment before landfill is fulfilled by the
obligation of sorting at source. Source separated waste collected for recycling, and waste originating
from municipalities and economic actors, who do not have source separation schemes in place, is
banned from landfilling. Exceptional authorisations can be issued by the prefect under specific
circumstances where landfill is the most beneficial situation (e.g. for corpses of animals which have
13
died in a fire in a building containing asbestos, and which are contaminated by asbestos) (Ministry for
the Ecological Transition/ CGDD / SDES, 2021).
In France, the general tax on polluting activities (Taxe Générale sur les Activités Polluantes or TGAP) is
applied to landfilling. In 2020 a broad range of different landfill rates for different types of landfills
was in place in mainland France and Corsica.
- 152 EUR/t for non-authorized landfills or non-authorized waste in authorized landfills (A); 2
The maximum fee is intended to penalize the illegal operation of an unauthorized waste
disposal site.
- 25 EUR/t in authorized landfills with 75 % energy recovery from captured biogas (B);
- 35 EUR/t in authorized bioreactor landfill cells with biogas recovery (C);
- 18 EUR/t for bioreactor landfills with 75 % energy recovery from captured biogas (D);
- and 42 EUR/t for other authorized landfills.
During the discussions on the finance bill which is voted on each year, the annual increase of this tax
is decided. All rates (B-D), except for (A), will be increased to 65 EUR/t by 2025 and for category A
landfills the rate will be 175 EUR/t (Code des douanes, 2019) (Ministry for the Ecological Transition/
CGDD / SDES, 2021).
Summary result
In France there is a ban on landfilling of untreated waste in place. The
landfill tax rates depend on the type of landfill. For most types of landfill,
Ban in place for landfilling
the tax is higher than 30 EUR/t, except for authorized landfills and
residual or biodegradable waste
bioreactor landfills that achieve 75 % energy recovery from captured
biogas The landfill tax will be further increased by 2025.
SRF MSWR-3.2: Taxes on municipal waste incineration

Taxes on incineration of residual municipal waste can help to discourage strong reliance on waste
incineration and thus support recycling.
In France, the general tax on polluting activities (Taxe Générale sur les Activités Polluantes or TGAP) is
also applied to incineration activities. During the discussions on the finance law which is voted on each
year, the annual increase of this tax is decided (Ministry for the Ecological Transition/ CGDD / SDES,
2021).
The incineration tax was implemented in 2009 and increased from 7 EUR/t in 2009 to 14 EUR/t in
2015. However, incineration with energy recovery and high energy efficiency are subject to a tax break
(1.5 EUR/t in 2009 to 3 EUR/t in 2015) (EEA, 2016). It is worth noting that more than 90 % of all
operators subject to the incineration tax benefit from the tax break, potentially reducing the strength
of the instrument. A substantial increase in the TGAP for thermal treatment facilities is planned, again
with the aim of making reuse and material recovery more competitive. Thus, in 2025, the rates will be
2
Non-authorized once they are identified, they are subject to :
• an administrative procedure to lead to their regularization, either by obtaining an authorization, or by
closure with measures (restoration, containment of waste, etc)
• possibly, a penal procedure
• possibly, a tax adjustment with application of the increased TGAP
14
between EUR 7.5 and EU 25 per tonne of waste (Ministry for the Ecological Transition/ CGDD / SDES,
2021).
Summary result
France has an incineration tax in place, which was increased from 7
Yes, taxes > 7 EUR/t(a) with
EUR/t in 2009 to 14 EUR/t in 2015 (corresponding to 12.3 EUR/t rescaled
escalator
based on purchasing power parities) and further increases each year.
(a)Note: rescaled based on purchasing power parities (Eurostat, 2020)
SRF MSWR-3.3: Pay-as-you-throw (PAYT) system in place

PAYT systems are designed to incentivize citizens to make a bigger effort in separating their waste at
source. However, a PAYT system should be designed with the appropriate level of source separation
encouragement to ensure that citizens do not misplace waste in recycling bins in order to avoid
residual waste charges. Overall, PAYT usually has a positive effect on source separation and thus
recycling rates through direct involvement of citizens.
In France, only about 9 % of the population is covered by PAYT charging systems (Ministry for the
Ecological Transition/ CGDD / SDES, 2021). According to ADEME, the majority of these systems (84 %)
relate to the frequency of collection and could be categorised as ‘weak’ as the economic incentive to
sort waste at source is not very visible, while in some areas households are charged based on the
weight (10 %) or volume (5 %) of collected waste. Some also use pre-paid waste bags (Ministry for the
Ecological Transition/ CGDD / SDES, 2021)
Summary result
Only experimental PAYT (less
than 50% of the population Only 9 % of the population is covered by PAYT charging systems.
covered)
2.1.4 Separate collection system

SRF MSWR-4.1: Convenience and coverage of separate collection systems for the different household
waste fractions
Separate collection systems are a key enabler for high recycling rates and for collecting recyclables at
adequate quality. Generally, the more convenient and accessible these systems are for their users,
the better results they deliver. The assessment methodology categorises different types of collection
systems (door-to-door, bring points with a density of > 5 per km2, bring points with a density of < 5
per km2, civic amenity site) for assessing the degree of convenience, and differentiates between cities
(densely populated), towns and suburbs (intermediate densely populated) and rural (thinly populated
areas). It then calculates which share of the population is served by which type of system. The
assessment is done on a material basis and takes into account the different materials according to
their average share in municipal waste. This is described in more detail in the methodology (ETC/CE &
ETC/WMGE, 2022).
France’s authorities indicate that residual waste is collected door-to-door across the country. Paper
and cardboard, ferrous metals and aluminium are collected mainly co-mingled door-to-door in cities,
15
towns and suburbs, but also via nearby bring points and civic amenity sites. For paper and cardboard
there are also nearby bring points. In voluntary drop-off centres (civic amenity sites), paper and
cardboard are collected separately, and plastics with metals. In rural areas these fractions are
collected similarly via co-mingled door-to-door collection, via nearby bring points and civic amenity
sites.
Glass is collected door-to-door and in bring points in cities and suburbs, and in rural areas via bring
points. Plastics are collected via co-mingled door-to-door collection together with paper and
cardboard and metals, and in the countryside there are also bring points. Currently, the separate
collection is restricted to plastic bottles and flasks in most municipalities, but by the end of 2022, the
separate collection of all plastic waste will be mandatory as prescribed by the Law on Anti-Waste for
a Circular Economy (AGEC): all plastic packaging will be collected separately, implemented by an
extension of the sorting instructions. This required the modernisation of household waste sorting
centres in order to be able to sort these different plastic flows and direct them to the appropriate
sorting and recycling channel (Ministry for the Ecological Transition/ CGDD / SDES, 2021).
Food waste is collected via separate door-to-door collection and bring points in cities and towns and
suburbs, and in rural areas via bring points. However, the separate collection of bio-waste is not
common in France. Reseau Compost Plus estimated in 2018 that only a share of 9 % of the population
was covered by this type of collection (Zero Waste Europe, 2020). By 2025 the separate collection of
organic waste will be mandatory for all waste producers, including households and non-household
sources (Loi n° 2015-992, 2015).
Garden waste in cities, towns and suburbs is collected mainly via civic amenity sites and in some
municipalities via separate door-to-door collection. In rural areas, garden waste is only collected via
civic amenity sites. Textiles are mainly collected via civic amenity sites and to some extent also via
bring points in cities, towns and suburbs, and rural areas. For WEEE collection both civic amenity
sites and bring points are used equally. Wood is collected mainly via civic amenity sites, and in rural
areas to some extent also via bring points. Composite packaging is collected door-to-door co-
mingled and in rural areas to some extent also via bring points (Ministry for the Ecological
Transition/ CGDD / SDES, 2021). Table 2.1 gives an overview of the collection system in France.
16
Table 2.1 Characterisation of the collection system in France
Cities Towns and suburbs Rural areas

(densely populated areas) (intermediate density areas) (thinly populated areas)
Door-to-door -
Door-to-door -
Door-to-door -
Door-to-door -
Door-to-door -
Door-to-door -
Civic amenity
Civic amenity
Civic amenity
(>5 per km²)
(<5 per km²)
(>5 per km²)
(<5 per km²)

co-mingled
co-mingled
co-mingled
Bring point
Bring point
Bring point
Bring point
Bring point
separate
separate
separate
site
site
site
Mixed
/Residual x x x
waste
Paper and
xx x x xx x x x x x
Cardboard
Ferrous metals xx x x xx x x x x
Aluminium xx x x xx x x x x
Glass x x x x x
Plastic xx xx x x
Bio-waste
x x x x x
Food
(n.c.) (n.c.) (n.c.) (n.c.) (n.c.)
x x
Garden xx xx x
(n.c.) (n.c.)
Textiles x xx x xx x xx
Wood xx xx x xx
WEEE x x x x x x
Composite
xx x x x
packaging
Note: xx: dominant system; x: other significant systems. If the systems vary between municipalities,
the largest city can be used as proxy. Grey cells are considered as ‘high convenience’.
n.c. = not common
Source: Ministry for the Ecological Transition/ CGDD / SDES (2021)
Summary result
Co-mingled door-to-door collection and nearby
A high share of the population is
Paper and bring points is the dominant system in cities and
covered by high convenience collection
cardboard towns and suburbs in France for collection of paper
services
and cardboard wastes.
Co-mingled door-to-door collection and nearby
A high share of the population is
bring points is the dominant system in cities and
Metals covered by high convenience collection
towns and suburbs in France for collection of metal
services
wastes.
Plastic waste is collected by high convenience
collection points, mainly via co-mingled door-to-
A high share of the population is door collection in cities, towns and suburbs.
Plastics covered by high convenience collection However, plastics collection is limited to plastics
services packaging and in many cases even to plastic bottles
and flasks, limiting the amount of plastics captured
for recycling.
17
A high share of the population is Door-to-door collection and nearby bring points is
Glass covered by high convenience collection the dominant system in cities and towns and
services suburbs in France for collection of glass wastes.
The separate collection of bio-waste is not common
A low share of the population is
in France. In 2018 it was estimated that only 9% of
Bio-waste covered by high convenience collection
the population was covered by this kind of
services
collection.
A low share of the population is
Wood waste is only collected via civic amenity sites,
Wood covered by high convenience collection
which is considered as a low convenience system.
services
A low share of the population is Textile waste is only collected via civic amenity sites
Textiles covered by high convenience collection and low-density bring points, which are considered
services as low convenience systems.
Different bring-systems are in place over the whole
Medium convenience collection
WEEE country, including take-back at retailers and civic
services dominate
amenity sites.
Credible information received from the French
Robustness of the underlying information authorities through the EEA-ETC/WMGE
questionnaire.
SRF MSWR-4.2: Firm plans to improve the convenience and coverage of separate collection for the
different household waste fractions
While for paper and cardboard, metals, plastics, and glass a high share of the population is already
covered by high convenience collection points, there is still room for improvement for WEEE, textiles,
wood, and bio-waste.
French authorities report that there are no changes planned for WEEE and wood (Ministry for the
Ecological Transition/ CGDD / SDES, 2021). With respect to bio-waste, separate collection will be
mandatory by 2024. According to the Ministry for the Ecological Transition, the choice of technical
solutions for local management and separate collection of bio-waste lies with the local authorities, as
this depends very much on the local context, opportunities, and technical solutions already available
on the territory. However, the joint collection decree (Ministère de la transition écologique and
Ministère de l’agriculture et de l’alimentation, 2022) lists the types of waste and packaging that can
be collected jointly with source-separated bio-waste. This joint collection is, however, not mandatory.
The communities remain free to choose, among the wastes listed in the decree, the wastes that they
wish to collect jointly with bio-waste. In addition, ADEME provides guidance on good practices for the
local management of bio-waste. There is also a steering committee of actions led by training and
certification organizations for the training of master composters etc. Financial support is provided
through the calls for projects launched by ADEME in favour of source separation and separate
collection of bio-waste. (Ministry for the Ecological Transition/ CGDD / SDES, 2021)
As of 2025, separate collection of textiles will be mandatory for companies, which will likely lead to
higher recycling for municipal waste and thus contribute to the 2025 target. (Ministry for the
Ecological Transition/ CGDD / SDES, 2021).
Although for plastics a high share of the population is already covered by high convenience collection
points, currently the separate collection is restricted to plastic bottles and flasks in most
municipalities, but by 2022 the separate collection of all plastic waste will be mandatory. For this
purpose, a public awareness campaign will be organized to inform citizens about changes in the sorting
18
instructions for plastic packaging. Moreover, sorting centres will be modernised, which is financially
supported by ADEME and the stimulus plan.
Summary result
N/A (for countries already covering a
Paper and A high share of the population is already covered by
high share of the population by high
cardboard high convenience collection points.
convenience points)
A high share of the population is already covered by
Metals high share of the population by high
high convenience collection points.
convenience points)
high convenience collection points. But the
Firm plans to cover a high share of the collection which had been limited to bottes and
Plastics population by high convenience flasks so far will be extended to all plastics. This plan
collection points does however not affect the convenience and
coverage of the already existing plastic collection
systems, although widening their materials’ scope.
Glass high share of the population by high
high convenience collection points.
convenience points)
Bio-waste separate collection will become
mandatory by 2024.
There are plans to improve the
The choice of technical solutions for the local
Bio-waste collection service but unclear plan for
implementation management and separate collection of biowaste is
left to local authorities with substantial support
provided by the central authorities.
No firm plans to improve the type and
Wood No changes planned.
coverage
Firm plans for mandatory separate Separation at source for textiles will be mandatory
Textiles collection for the non-household part in 2025 for companies, which will likely lead to an
of municipal waste increased recycling for municipal waste.
No firm plans to improve the type and
WEEE No changes planned.
coverage
Robustness of the underlying information
authorities through a questionnaire.
2.1.5 Extended producer responsibility (EPR) and similar schemes

SRF MSWR-5.1: Fee modulation in EPR schemes for packaging
Within EPR schemes, fee modulation (or eco-modulation) is a system with different fees for different
types of packaging material and designs. While basic fee modulation, i.e. different fees for the main
material groups, are common, advanced fee modulation can create stronger incentives for packaging
producers to design for recycling and thus create favourable conditions for higher recycling rates. The
level of advancement of the fee modulation is assessed against four criteria that have been selected
as benchmarks for a well-designed eco-modulated fee system:
• recyclability, for example differentiating between PET and PS, between different colours of
PET, or between 100 % cardboard boxes and laminated beverage cartons;
• sortability and disruptors, for example a malus for labels/caps/sleeves made of other
materials, which are not fitted for the recycling technologies of the main packaging;
• recycled content; and
19
• if there is a transparent compliance check by the Producer Responsibility Organisation (PRO)
that producers report correctly.
In France, since 2012, the fees charged to producers have been modulated according to environmental
criteria, rewarding good sorting practices and eco-design (bonus), and penalising packaging which
hinders recycling (malus). The criteria are defined by the producers, based on discussions with
recyclers (Institute for European Environmental Policy, 2017). For instance, a 50 % penalty (malus) is
applied to specific packaging which cannot be recycled or which presents features that hamper the
recycling process. A maximum of 100 % penalty applies to packaging which cannot be recovered.
Currently a bonus of maximum 24 % is applied to packaging with eco-design features and which is
associated with awareness initiatives. So the total fee is calculated based on the fee for weight plus
the fee for number of units multiplied with a bonus or malus (Ministry for the Ecological Transition/
CGDD / SDES, 2021).
New eco-modulation tariffs have been introduced for the period 2018-2022, replacing fees per
packaging unit by fees per consumer sales unit3 (CSU) in 2018.
The AGEC law of 10 February 2020 has strengthened the framework of EPR channels and has included
several provisions related to packaging and eco-modulation (Loi n° 2020-105, 2020). It obliges PROs
to participate in national collection targets for the recycling of plastic bottles for beverages, to
contribute to achieve the national target of 5 % of reused packaging placed on the market in 2023,
and to reinforce the modulation of EPR contributions to further encourage the integration of recycled
plastics, while penalising signs and markings are likely to lead to confusion about the sorting rules
Monitoring of producers’ activities is ensured through annual reports and activity reports, including
information on collection and recycling rates, and tonnages put on the market. Producers’
declarations are then regularly cross-checked to those of local authorities to check for coherence. This
monitoring system provides a valuable tool to predict future quantities of waste that will need sorting
in the future, and their characteristics (Institute for European Environmental Policy, 2017)
Summary result
There is advanced fee
For paper and cardboard, plastics, ferrous metals, aluminium, glass and
modulation for at least two of
composite packaging, fee modulation is applied taking into account
the main packaging fractions(a)
recyclability and sortability. In addition, for paper and cardboard and
AND fee modulation for one
plastics, fee modulation also builds on recycled content. Proper
packaging fraction meets three
monitoring is ensured.
assessment criteria
(a) Note: Paper and cardboard, ferrous metals, aluminium, glass, plastic
3
A CSU is a unit of packaged product that a consumer can purchase separately from others. Parcel and
steward packaging are considered to be CSUs, e.g., a bottle of wine, a laptop or a tray of strawberries.
A packaging unit is a component of the packaging that can be separated from the product when it is
consumed or used by the household. All corking or closing elements (detachable caps, lids, lids,
elements of blisters without pre-cut, etc.) are considered as full packaging units and must be declared
separately (Ministry for the Ecological Transition/ CGDD / SDES, 2021).
20
2.1.6 Treatment capacity for bio-waste
SRF MSWR-6.1: Capacity for the treatment of bio-waste
Bio-waste is the largest single waste fraction in municipal waste, and adequate treatment capacity
needs to be made available.
The overall residual waste as reported by France’s authorities amounts to 16.6 million tonnes in 2019.
The reported share of bio-waste in residual waste is 33 %, meaning that a total of 5.44 million tonnes
of bio-waste is present in residual waste. The amount of home-composted bio-waste is estimated at
1.7 million tonnes. Adding the volumes reported as separately collected bio-waste in 2017 of 5.3
million tonnes, results in an overall amount of generated bio-waste of 10.7 million tonnes, or 12.4
million tonnes if the home-composted amounts are included. Another 306 000 tonnes (2018) of bio-
waste are extracted from residual waste treated in MBT plants to produce compost from MBT
The exact available treatment capacity for bio-waste in France is unknown (Ministry for the Ecological
Transition/ CGDD / SDES, 2021). But in 2019, 7.4 million tonnes of bio-waste were composted or
digested, including 1.7 million tonnes home-composted (Eurostat, 2022a), which means that the
capacity is at least 60 %.
France’s authorities report that the sorting errors, the cost for collection and treatment, and the
reluctance of communities and the limited acceptance of compost by the population are the major
issues hampering the collection and treatment of municipal bio-waste (Ministry for the Ecological
Summary result
Bio-waste treatment capacity
below 80% of generated
No exact capacity information is available, but it is estimated that a
municipal bio-waste and no
treatment capacity for about 60 % of generated bio-waste is available.
plans to extend capacity, or no
capacity information available
Credible information received from the French authorities through the
EEA-ETC/WMGE questionnaire, but data on treatment capacity is not
information
available and is therefore estimated for the assessment.
SRF MSWR-6.2: Legally binding national standards and Quality Management System for
compost/digestate
To create a market for compost and digestate, compost should be of a good quality for use as a soil
improver or fertilizer. Legally binding standards provide guarantees regarding the quality of the
compost/digestate produced. A quality management system aims at addressing different elements of
a production process to ensure a stable and high-quality output (product) which helps toward reaching
a defined quality for the product.
France has mature national standards for compost quality embedded in national legislation and a
quality management system in place (EEA, 2020).
21
Summary result
Legally binding national
standards for France reported having mature national standards for compost quality
compost/digestate quality in embedded in national legislation and a quality management system in
place, and quality management place.
system in place
22
2.2 Target for the recycling of packaging waste
This chapter aims at assessing the prospects of the France to achieve the 65 % recycling target for
packaging waste in 2025 as well as the material specific packaging waste recycling targets (50 % of
plastic; 25 % of wood; 70 % of ferrous metals; 50 % of aluminium; 70 % of glass; 75 % of paper and
cardboard). In order to conclude on this likelihood, the analysis takes stock of the status of several
factors that are proven to influence the levels of recycling in a country. For a detailed description of
the methodology followed, the development of success/risk factors and their impact on recycling,
please consult the methodology report (ETC/CE & ETC/WMGE, 2022) .

SRF P-1.1 Distance to target
The actual distance to the target for the most recent data point is a key factor determining the
likelihood of meeting or not meeting the target. This analysis is based on data reported by France to
Eurostat in accordance with Commission Decision 2005/270/EC as last amended by the Commission
Implementing Decision 2019/665 (EC, 2019a), published in the dataset Recycling rates of packaging
waste for monitoring compliance with policy targets, by type of packaging [env_waspacr]. The latest
available data refer to 2019. The performance of France for 2019 is illustrated in Figure 2.2.
Figure 2.2 Packaging recycling rates for France in 2019, in percentage
Source: Eurostat (2022c), EU (2018)
In France, the reported recycling rates for reference year 2019 of nearly all packaging waste materials
lie above the 2025 targets. The only exception is a comparatively low plastic recycling rate of 26.9 %,
being at about 22.1 percentage points below the 2025 target of 50 %. This is due to the fact that the
EPR schemes do not cover all plastic packaging product types in all parts of the country, they do not
cover non-household plastic packaging waste and there is no deposit-return scheme for any plastic
packaging. However, France plans on making separate collection for household plastic packaging
mandatory by the end of 2022 and to expand collection to all plastic waste.
23
However, the recycling rates presented are based on the calculation rules of the Commission Decision
C(2005)854 and will likely differ from the recycling rates to be reported according to the calculation
rules laid down in Commission Implementing Decision 2019/665. Application of the new reporting
rules will only be mandatory by 2022 for the 2020 data. France has not yet assessed the impact of the
new calculation rules on the recycling rates. There are a few signs that the recycling rates could be
lower than currently reported once the new calculation are applied: 1) The current reporting of the
amounts of packaging generated does not take into account possible underreporting due to, e.g., free-
riding, online sales or amounts below de minimis thresholds; 2) the reporting of recycled amounts
according to the new calculation rules requires deducting losses within the recycling plants, while the
available data does not systematically account for these losses. ADEME is currently assessing the
impact of the new calculation method. The preliminary results seem to indicate a decrease of the
recycling rates which vary depending of the considered material (Ministry for the Ecological
As a matter of sensitivity analysis, to assess what the impact of these new calculation rules could be
(change in calculation point), losses in recycling plants found in literature (EXPRA, 2014) are applied
to the packaging recycling rates as reported for reference year 2019:
• Paper and cardboard packaging: decrease by 10 %, from 91.4 % to 82.3 %
• Metal packaging: decrease by 14 %, from 87.5 % to 75.3 % (note that due to lack of separate
data, the same reduction is assumed for both ferrous metals and aluminium in the assessment
below)
• Glass packaging: decrease by 5 %, from 77.1 % to 73.2 %
• Plastic packaging: decrease by 21 %4, from 26.9 % to 21.2 %
• Wooden packaging: decrease by 11 % from 35.6 % to 31.7 %
• Total packaging: Calculated based on the amounts of each packaging material generated and
recycled in 2019, the recycling rate would drop from 65.6 % to 59.1%.
Taking these possible recycling rates into account, the distance to the recycling target for total
packaging is likely to be larger when the new calculation rules will be applied, namely between 5 and
15 percentage points, while for the fractions of packaging waste the assessment would not change as
the margins are large enough.
Summary result
France reports a recycling rate of 65.6 %. However if
the new calculation rules are applied (taking into
Total
5 - 15 percentage points below target account losses in the recycling plants), the estimated
packaging
recycling rate would drop to 59.1 %, 5.9 percentage
points below the 2025 target.
France reports a recycling rate 91.4 %. However if
Paper and the new calculation rules are applied (taking into
cardboard Target exceeded account losses in the recycling plants), the estimated
packaging recycling rate would drop to 82.3 %, 7.3 percentage
points above the 2025 target.
4
This is the weighted recycling loss taking into account the 29 % recycling loss for packaging waste from
household sources (66 %) and the 5 % recycling loss for packaging waste from commercial sources
(33 %).
24
Ferrous the new calculation rules are applied (taking into
metals Target exceeded account losses in the recycling plants), the estimated
packaging recycling rate would drop to 75.3 %, 5.3 percentage
Aluminium
Target exceeded account losses in the recycling plants), the estimated
packaging
Glass
packaging
Plastics
> 15 percentage points below target account losses in the recycling plants), the estimated
packaging
recycling rate would drop to 21.2 %, 28.8
percentage points below the 2025 target.
Wooden
packaging
The assessment is limited by the fact that the
recycling rates for 2019 reported by France to
Robustness of the underlying information Eurostat do not yet reflect the new calculation rules,
and the impact of the new calculation rules has
therefore been estimated based on literature.
SRF P-1.2: Past trend in Packaging Waste Recycling

The development of the historical trend in the recycling rate indicates previous efforts towards
packaging waste recycling. In this analysis the recycling rate reported in the Eurostat dataset Recycling
rates of packaging waste for monitoring compliance with policy targets, by type of packaging
[env_waspacr] (latest data year: 2019) is used. The recycling trends for packaging waste by material
in France are illustrated in Figure 2.3.
25
Figure 2.3 Trend in packaging waste recycling rates in France between 2015 and 2019, in percentage
Source: Eurostat (2022c)
The recycling rates for all packaging slightly increased over the past five years. Only for paper and
cardboard there is a slight decrease of 0.6 percentage points.
Summary result
The recycling rate increased by 0.1 percentage
Total RR > 55%, and increase in last 5 years points over the past five years and is estimated at
packaging < 10 percentage points 59.1 % if the new calculation rules would be applied
(taking into account losses in the recycling plants).
The recycling rate decreased by 0.6 percentage
Paper and
points over the past five years and is estimated at
cardboard RR > 75%
82.3 % if the new calculation rules would be applied
packaging
Ferrous
points over the past five years and is estimated at
metals RR > 70%
75.3 % if the new calculation rules would be applied
packaging
Aluminium points over the past five years and is estimated at
RR > 50%
packaging 51.3 % if the new calculation rules would be applied
Glass points over the past five years and is estimated at
RR > 70%
26
Plastics RR < 40% and increase in last 5 years < points over the past five years and is estimated at
packaging 10 percentage points 21.2 % if the new calculation rules would be applied
Wooden points over the past five years and is estimated at
RR > 25%
The assessment is limited by the fact that the
recycling rates for 2019 reported by France to
Robustness of the underlying information Eurostat do not yet reflect the new calculation rules,
and the impact of the new calculation rules has
therefore been estimated based on literature.
2.2.2 Legal instruments

SRF P-2.1: Timely transposition of the revised Packaging and Packaging Waste Directive into national
law
Timely transposition of the Packaging and Packaging Waste Directive as amended by Directive
2018/852 into national law within the foreseen period is key for a waste management system in line
with EU requirements.
As of May 2022, France has not yet fully transposed the revised Packaging and Packaging Waste
Directive into national law. However 21 individual transposition measures have been communicated
to the European Commission (EUR-LEX, 2021b).
Summary result
As of May 2022, the revised Packaging and Packaging Waste Directive
No full transposition yet
has not yet been fully transposed into national law.
Robustness of the underlying The information has been provided by the European Commission (status
information as of 12 November 2021).
SRF P-2.2: Responsibilities for meeting the targets, and enforcement mechanisms, e.g. fines etc.
Responsibilities for meeting the targets, and support and enforcement mechanisms with respect to
packaging waste are described in detail in section 2.1.2 under SRF MSWR-2.2. Additionally, with
respect to plastic packaging waste, a new frame for the collection and recycling has been introduced
in the updated specifications for the PRO, in order to accelerate the recycling of plastic packaging
streams, linked with the extension of collection to all plastic resins by the end of 2022 (Ministère de
la transition écologique et al., 2022) (Ministère de la Transition Écologique et Solidaire and Ministère
de la Cohésion des Territoires et des Relations avec les Collectivités Territoriales, 2022). One of the
goals of the corresponding decree is to entrust the streams of resins that are hard to recycle to the
PRO for consolidation and improving their sorting and their recycling in the next years.
27
Summary result
Responsibilities are defined and support mechanisms are in place, and
Clearly defined responsibilities
there are direct consequences for the PROs if the targets are not met. No
and enforcement mechanisms
support tools to PROs for increasing recycling performance, other than
but no/weak support tools for
financial support for responding to the extension of the plastic packaging
meeting the recycling targets
collection scope as from the end of 2022.
2.2.3 Economic instruments

SRF P-3.1: Taxes and/or ban for landfilling residual- or biodegradable waste
Bans and taxes on landfilling of residual waste can help to discourage landfilling and thus support
recycling, also of packaging waste.
As described in Section 2.1.3, France has different rates of landfill taxes in place, and an increase of
the tax has been decided. Since 2002 there is a ban on landfilling of untreated waste in place.
Moreover, source separated waste collected for recycling and waste from municipalities and
economic actors which do not have source separation schemes in place is banned from landfilling.
Summary result
In France there is a ban on landfilling of untreated waste in place. The
landfill tax rates depend on the type of landfill. For most types of landfill,
Ban in place for landfilling
the tax is higher than 30 EUR/t, except for authorized landfills and
residual or biodegradable waste
bioreactor landfills that achieve 75 % energy recovery from captured
biogas The landfill tax will be further increased by 2025.
SRF P-3.2: Taxes on municipal waste incineration

Taxes on incineration of residual waste can help to discourage strong reliance on residual waste
treatment and thus support recycling. As described in Section 2.1.3 in more detail, France has an
incineration tax in place which was increased from 7 EUR/t in 2009 to 14 EUR/t in 2015, and a further
increase of the tax has been decided.
Summary result
France has an incineration tax in place, which was increased from 7 EUR/t
Yes, taxes > 7 EUR/t(a) with
in 2009 to 14 EUR/t in 2015 (corresponding to 12.3 EUR/tonne rescaled
escalator
based on purchasing power parities) and further increases each year.
(a)Note: rescaled based on purchasing power parities (Eurostat, 2020)
SRF P-3.3: Packaging taxes

Packaging taxes can support the aim to reduce packaging waste generation and/or to influence the
choice of packaging materials and encourage recyclability and eco-design.
According to the information available, France does not have a packaging tax in place.
28
Summary result
No packaging taxes No packaging taxes in place.
SRF P-3.4: Pay-as-you-throw (PAYT) system in place

As a large share of packaging waste is generated in households, incentivising households to separate
packaging waste at source, e.g. by applying PAYT systems, is relevant for meeting the recycling targets
for packaging waste.
The PAYT system is described in detail under SRF MSWR-3.3.
Summary result
Only experimental PAYT (less
than 50% of the population Only 9 % of the population is covered by PAYT charging systems.
covered)
SRF P-3.5: Deposit-return systems

Deposit Return Systems (DRS) generate high capture rates for packaging covered by the system and
thus contribute to increased recycling rates.
At the moment, in France there are no DRSs in place. As the French government has pledged to recycle
100 % of its plastic by 2025, a DRS for plastic bottles is under discussion. According to the AGEC law,
reflections are in progress, and a decision is planned in 2023 on the implementation of deposit systems
for reuse and recycling of beverage bottles. For the moment, there are no plans to introduce a deposit
Summary result
Aluminium
No DRS for drink cans
drink cans
Glass drink
No DRS for drink bottles
bottles
Plastic drink There are discussions to introduce a DRS for plastic
No DRS for drink bottles
bottles bottles.
Plastic
No DRS for plastic crates
crates
Wooden
No DRS for wooden packaging
packaging
questionnaire.
29
2.2.4 Separate collection system
SRF P-4.1: Convenience and coverage of separate collection for different packaging waste fractions
As a large part of packaging waste comes from households, separate collection systems for households
and similar sources are a key condition for achieving high recycling rates of packaging waste and for
collecting recyclables at adequate quality. Generally, the more convenient and accessible these
systems are for their users, the better results they can deliver. The material specific assessment
considers packaging waste from both household and non-household sources. For assessing the
convenience and coverage of separate collection systems for households, the same methodology is
used here as described in section 2.1.4.
The separate collection system for households is described in detail under SRF MSWR-4.1 in section
2.1.4.
Although the coverage and convenience level for the collection of plastic packaging waste is high, it
has to be noted that the volumes of separately collected plastic packaging are limited because not all
types of packaging are currently separately collected; for now separate collection is restricted in most
municipalities to plastic bottles and flasks. Also, there is no DRS in place. However, France plans on
extending the separate collection of plastic waste in 2022.
Summary result
1. Packaging waste from households
A high share of the population is covered by high
Paper and convenience collection points
cardboard
packaging 2. Packaging waste from non-household sources
Separation at source is mandatory for non-
household paper and cardboard packaging waste

Ferrous
convenience collection points
metals
Separation at source is mandatory for non- A high share of the population is
household ferrous metals packaging waste covered by high convenience
Packaging waste from households collection points for all packaging
Aluminium
A high share of the population is covered by high wastes. Separation at source is
packaging
convenience collection services mandatory for non-household
1. Packaging waste from households packaging wastes.
Glass convenience collection points
household glass packaging waste
Plastics convenience collection services
household plastic packaging waste
30
Packaging waste from non-household sources
Wooden
packaging Separation at source is mandatory for non-
household wooden packaging waste
Credible information received
from the French authorities
Robustness of the underlying information
through the EEA-ETC/WMGE
questionnaire.
SRF P-4.2: Firm plans to improve the convenience and coverage of separate collection for different
packaging waste fractions
Concrete plans are needed to improve the convenience and coverage of separate collection. This SRF
is only relevant for MS and materials that do not score ‘green’ in SRF P-4.1. The assessment is done
on a material basis, and summing up the scores of the different materials according to their average
share in packaging waste5. Again, the material specific assessment considers packaging waste from
both household and non-household sources.
To increase the capture rate and thereby the recycling rate for plastics packaging, the sorting
instructions for household packaging will be extended to all plastic packaging by 2022, including plastic
films and trays (Ministry for the Ecological Transition/ CGDD / SDES, 2021).
Further sorting instructions and bin colours will be gradually harmonized by 2025: it will then be easier
to identify the appropriate bin or container throughout France (Ministère de la Transition écologique,
2021).
Summary result
N/A (for countries in which a very high
share of the population is already
Paper and covered by high convenience
cardboard collection services)
packaging 2. Packaging waste from non-
household sources
N/A (for countries already having
mandatory sorting at source)
1. Packaging waste from households This SRF is not relevant for France, since the
N/A (for countries in which a very high coverage and convenience level for the collection of
share of the population is already packaging waste from households is high and the
Ferrous covered by high convenience separate collection for non-households is
metals collection services) mandatory for all fractions.
packaging 2. Packaging waste from non-
household sources
Packaging waste from households
Aluminium
packaging
covered by high convenience
collection services)
5
Based on data from Eurostat on the share of packaging materials in total packaging generated in 2018.
31
Glass
packaging
2. Packaging waste from non-
household sources
Plastics
collection services).
packaging
2. Packaging waste from non-
household sources
Packaging waste from non-household
Wooden sources
packaging N/A (for countries already having
Robustness of the information authorities through the EEA-ETC/WMGE
questionnaire.
2.2.5 Extended producer responsibility (EPR) and similar schemes

SRF P-5.1: Coverage of EPR schemes
Eco-Emballages, now CITEO, is a collective EPR scheme for household packaging waste in France. It
was implemented by the first French PRO which was founded in 1992 as a response to a packaging
decree issued in France in the same year. In May 2017, a new PRO, LÉKO, was approved and was
initially expected to enter the packaging compliance scheme market in January 2018. However, LÉKO
has started operations three years late, leaving CITEO as the only PRO in operation during the 2018 to
2020 period of the 2018-2022 agreement (Ministère de la Transition écologique, 2021).
In France, there are EPR schemes in place for packaging waste from households, including paper and
cardboard packaging, ferrous metals packaging, aluminium packaging, glass packaging and plastic and
composite packaging. Packaging materials from non-household sources will be reportedly included as
of 2025 for all materials (Ministry for the Ecological Transition/ CGDD / SDES, 2021) and, for packaging
intended for catering professionals, the principle of EPR should be implemented from 2023.
To prevent free-riding, a recent French law stipulates that marketplaces will have to verify that the
products of which they facilitate the sale have contributed to EPR, and failing that, will have to assume
this obligation (Loi n° 2020-105, 2020).
In France, the EPR financial mechanism is developed in such a way that the eco-tax collected from the
producers is redistributed at a variable rate per tonne of waste to the municipalities which collect and
sort the waste. In accordance with the waste hierarchy, municipalities with higher quantities of
recycled waste receive higher subsidies. Both the rate of the eco-tax and the rate of the subsidy are
reviewed and audited by the government on a regular basis (EEA, 2016).
32
Summary result
All main packaging fractions(a)
In France, all main packaging fractions are covered by EPR schemes but
are covered by EPR schemes
only targeting household packaging. EPR will be extended to non-
but none or only one covers
household packaging as of 2023 for packaging from catering and 2025 for
household and non-household
other professional packaging.
packaging
(a) Note: Paper and cardboard, Ferrous metals, Aluminium, Glass, Plastic
SRF P-5.2: Fee modulation in EPR schemes for packaging

As explained in Section 2.1.5, fee modulation (or eco-modulation) is a system with different fees for
different types of packaging material and designs. The assessment is the same as described in Section
2.1.5
In France there is eco-modulation for paper and cardboard packaging and plastic packaging
considering the four criteria (recyclability, recycled content, sortability and compliance check) in place.
For ferrous metals, aluminium, glass and composite packaging fees are modulated based on the
criteria recyclability, sortability and compliance check. For wood packaging no eco-modulation is in
place (Ministry for the Ecological Transition/ CGDD / SDES, 2021).
Summary result
There is advanced fee
modulation in at least two of In France, for paper and cardboard and plastic packaging there is a fee
the main packaging fractions(a) modulation in place that covers all four criteria. For ferrous metals,
AND fee modulation for one aluminium, glass and composite packaging three out of four criteria are
packaging fraction meets three covered.
assessment criteria
(a) Note: Paper and cardboard, Ferrous metals, Aluminium, Glass, Plastic
SRF P-5.3 Material specific EPR assessment

The material specific assessment is based on a combination of the coverage of the material-specific
EPR schemes and the use of fee modulation for the specific packaging material. The assessment takes
the different situations for different types of materials into account: Plastics packaging is the
packaging material that is the most difficult to recycle out of the packaging materials targeted by the
Packaging and Packaging Waste Directive. Fee modulation therefore plays a larger role for plastic
packaging than for the other materials and is therefore rated differently from paper/cardboard,
ferrous metals, aluminium and glass. The methodology foresees a green score for plastics packaging
only if all four fee modulation assessment criteria mentioned above are met. On the other hand,
wooden packaging is mainly generated by commercial and industrial sources and fee modulation is
less relevant, therefore the methodology only relies on EPR schemes for wooden packaging from
commercial and industrial sources.
Now, there are three PRO operating in France: CITEO, its corporate subsidiary Adelphe, and as
mentioned earlier, LéKO, which contributes financially to the collection and recycling of packaging
waste. Only Citeo has contracts with municipalities and waste operators. These PRO represent a
collective EPR scheme only for household packaging waste, covering all major material fractions.
33
Summary result
SRF P-5.3.1
EPR scheme for EPR scheme covering only
In France, the EPR scheme only covers household
Paper and household, industrial OR
packaging.
cardboard commercial packaging
packaging waste
SRF P-5.3.2
EPR scheme covering only
EPR scheme for In France, the EPR scheme only covers household
household, industrial OR
Ferrous metals packaging.
commercial packaging
packaging waste
SRF P-5.3.3
Aluminium packaging.
packaging waste
SRF P-5.3.4
Glass packaging packaging.
waste
SRF P-5.3.5
Plastic packaging packaging.
waste
SRF P-5.3.6
EPR scheme for In France, there is no EPR scheme for wood
No EPR scheme
Wooden packaging.
packaging waste
questionnaire.
34
2.3 Target on landfill of municipal waste
SRF LF-1.1: Distance to target
The Landfill directive (1999/31/EC), as amended by Directive (EU) 2018/850, sets a target to reduce,
by 2035, the amount of municipal waste landfilled to 10 % or less of the total amount of municipal
waste generated (by weight).
Data to show the current rate of landfilling in line with the reporting rules will only be reported by
mid-2022. Therefore, this analysis calculates the landfilling rate based on the current Eurostat dataset
Municipal waste by waste management operations [env_wasmun]; by dividing the amount of
landfilled waste by the total amount of waste generated. The overall landfilling rate of France was
18.1 % in 2020.
Summary result
Distance to target < 10 The landfilling rate of France was 18.1 % in 2020, 8.1 percentage points
percentage points below the target.
The data are derived from Eurostat and are considered to be rather
robust. However, the reported landfill rate might increase once the new
Robustness of the underlying calculation rules laid down in the Commission Implementing Decision
information (EU) 2019/1885 will be applied. Based on the available information, it is
currently not possible to quantify the impact of the new calculation rules
on the landfill rate.
SRF LF-1.2: Past trend in municipal solid waste landfill rate

Over the past five years, the overall landfilling rate of France has decreased from 22.4 % in 2016 to
18.1 % in 2020 (Figure 2.4).
35
Figure 2.4 Landfilling in France between 2016 and 2020, in percentage
Source: Eurostat (2022a).
Summary result
Landfill rate in 2020 < 20%,
During the past five years the landfilling rate in France decreased by 4.3
and decrease in last 5 years <
percentage points, from 22.4 in 2016 to 18.1 in 2020.
5 percentage points,
There are no breaks in the time series data.
information
SRF LF-1.3: Diversion of biodegradable municipal waste from landfill

According to Art. 5(2c) of the EU Landfill Directive, Member States had to ensure that by 2016,
biodegradable municipal waste going to landfills is reduced to 35 % of the total amount (by weight) of
biodegradable municipal waste produced in 1995 or the latest year before 1995 for which
standardised Eurostat data is available.
France generated about 18.6 million tonnes of biodegradable municipal waste in the reference year
1995. In 2016 (and 2017), a volume equivalent to 15 % of the biodegradable municipal waste
generated in 1995 was still being landfilled.(EC, 2022)
36
Summary result
Target for reducing the amount
of biodegradable municipal
waste (BMW) landfilled to 35% France has reported 15 % biodegradable waste landfilled (of the total
of BMW generated in 1995 has amount of biodegradable municipal waste produced in the reference
been achieved in 2016 or in the year) for 2016 and therefore performs well within the target.
year specified in the derogation
where applicable
Based on data officially reported to the European Commission which is in
line with otherwise reported statistical data on landfilling of municipal
information
waste.
37
Conclusion
This risk assessment indicates whether France is at risk of not meeting the targets. The ‘total risk’
categorization is the result of the sum of the individual scores of each SRF as described in the previous
chapter, where the assessment of each SRF results in a score of 2 points (green), 1 point (amber) or
0 points (red), depending on the assessment of the SRF. As some SRFs are considered to have a higher
impact on meeting the target, the score of the SRF is multiplied by the defined weight of the SRF. As
some SRFs might not be applicable to France, only the SRFs relevant to France are taken into account
to define the maximum score. France is considered to be ‘not at risk’ if its score is more than 50 % of
this maximum score, and ‘at risk’ if its score is less than 50 % of this maximum score.
2.4 Prospects for meeting the recycling target for municipal solid waste
Based on the provided information and the analysis done, it is

35 % concluded that France is at risk for not meeting the MSW
recycling target in 2025.
of maximum score
The recycling rate is reported to be 42.7 % in 2020, which is

12.3 percentage points away from reaching the targets of
55 %. Considering the impact of the new calculation rules, the
Current situation and past
recycling rate would be estimated around 37.7 %, 17.3
trends:
percentage points below the target.
The recycling rate over the last five years shows a decrease
with 0.2 percentage points.
The revised Waste Framework Directive has not yet been fully
transposed into national law.
Legal instruments:
Responsibilities are defined and support mechanisms are in
place, but enforcement mechanisms are suboptimal.
France has an incineration tax in place, which was increased

from 7 EUR/t in 2009 to 14 EUR/t in 2015 and will increase by
2025.
The landfill tax rates depend on the type of landfill and there is
an escalator in place. For most types of landfill, the tax is
Economic instruments:
higher than 30/t EUR, except for authorized landfills and
bioreactor landfills that achieve 75% energy recovery from
captured biogas. There is a ban on landfilling untreated waste.
Only 9 % of the population is covered by a Pay-As-You-Throw
system.
38
A high share of the population is covered by high convenience
collection services for paper and cardboard, glass and metals.
For plastics, a high share of the population is covered by high
convenience collection services but not all plastics are
targeted.
A low share of the population is covered by high convenience
collection services for bio-waste, wood and textiles.
Separate collection systems: For WEEE medium convenience collection services dominate.
For plastics and textiles there are firm plans to improve the
separate collection system, with clear responsible entities and
defined targets and timeline.
For bio-waste there are plans to improve the collection service
but the plan for implementation is still unclear.
For wood and WEEE there are no plans to improve the
collection service.
For paper and cardboard, plastics, ferrous metals, aluminium,

glass and composite packaging, fee modulation is applied
Extended producer
taking into account recyclability and sortability. In addition, for
responsibility:
paper and cardboard and plastics, fee modulation also builds
on recycled content. Proper monitoring is ensured.
No exact capacity information is available, but it is estimated

that a treatment capacity for around 60 % of generated bio-
Bio-waste treatment capacity waste is available.
and quality management: France reported having mature national standards for compost
quality embedded in national legislation and a quality
management system in place.
39
2.5 Prospects for meeting the recycling targets for packaging waste

53 % concluded that France is not at risk for not meeting the 65 %
recycling target for packaging waste in 2025
of maximum score
70 % of maximum score Paper and cardboard Not at Risk
70 % of maximum score Ferrous metals packaging Not at Risk
66 % of maximum score Aluminium packaging Not at Risk
66 % of maximum score Glass packaging Not at Risk
26 % of maximum score Plastics packaging At Risk
66 % of maximum score Wooden packaging Not at Risk
The total packaging recycling rate, after an estimated correction

for the new calculation rules, is 59.1 %, 5.9 percentage points
below the 2025 target.
Current situation and past The only waste stream with more than 15 percentage points
trends: below the target is plastic packaging.
The total packaging recycling rate has hardly increased over the
past five years. The packaging waste stream of most concern is
plastic.
The revised Packaging and Packaging Waste Directive has not yet
been fully transposed into national law.
Responsibilities are defined and enforcement mechanisms are in
Legal instruments: place. There are no support tools to PROs for increasing recycling
performance, other than financial support for responding to the
extension of the plastic packaging collection scope as from the
end of 2022.
France does not have a packaging tax in place.

There is incineration and a landfill tax with escalator in place.
Economic instruments: Only 9 % of the population is covered by a Pay-as-you-throw
system.
There is no mandatory DRS in place.
The coverage and convenience level for the collection of

packaging waste from households is high, and separation at
Separate collection systems:
source is mandatory for commercial and industrial packaging
waste.
40
All main packaging fractions are covered by EPR schemes but
none for non-household packaging. EPR will however be extended
Extended producer
to non-household packaging as of 2023 for packaging from
responsibility:
catering and 2025 for all other non-household packaging. Fee
modulation is implemented.
2.6 Prospects of meeting the landfill of municipal waste target

93 % concluded that France is not at risk for not meeting the 2035 target
to reduce the amount of municipal waste landfilled to 10 % or less
of maximum score
of the total amount of municipal waste generated.
Over the past five years, the landfilling rate has decreased from
22.4 % in 2016 to 18.1 % in 2019 in France, meaning that the
Current situation and past
distance to target is 8.1 percentage points, with a slightly
trends:
decreasing trend, with 4.3 percentage points in total over the past
five years.
Diversion of biodegradable France has reported 15 % biodegradable waste landfilled for 2016
municipal waste from of the total amount (by weight) of biodegradable municipal waste
landfill: produced in 1995, and therefore met the target.
41
List of abbreviations
Abbreviation Name
ADEME Agence de la transition écologique (French Environment Agency)
AcTE Green Transition Accelerator
CEa Circular Economy
DREAL Regional directorate for the environment, planning and housing
DRS Deposit Return System
EC European Commission
EEA European Environment Agency
EPR Extended producer responsibility
ETC/CE European Topic Centre on Circular Economy and resource use
ETC/WMGE European Topic Centre on Waste and Materials in a Green Economy
MBT Mechanical biological treatment
MS Member state
MSW Municipal solid waste
NOTRe Nouvelle Organisation Territoriale de la République
NWMP National Waste Management Plan
PAYT Pay-as-you-throw
PPWD Packaging and Packaging Waste Directive
PRO Producer Responsibility Organisation
R&D Research and development
RR Recycling rate
SRF Success and risk factor
WEEE Waste Electric and Electronic Equipment
WFD Waste Framework Directive
42
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(https://ieep.eu/uploads/articles/attachments/9665f5ea-4f6d-43d4-8193-
454e1ce8ddfe/EPR%20and%20plastics%20report%20IEEP%2019%20Dec%202017%20final%
20rev.pdf?v=63680919827) accessed 5 June 2021.
Ministère de la Transition écologique, 2021, ‘Déchets des emballages ménagers’

(https://www.ecologie.gouv.fr/dechets-des-emballages-menagers) accessed 7 May 2021.
Ministère de la transition écologique, et al., 2022, Arrêté du 15 mars 2022 portant

modification de l’arrêté du 29 novembre 2016 modifié relatif à la procédure d’agrément et
portant cahier des charges des éco-organismes de la filière des emballages ménagers (JORF
n°0063 du 16 mars 2022).
44
Ministère de la Transition Écologique et Solidaire and Ministère de la Cohésion des Territoires
et des Relations avec les Collectivités Territoriales, 2022, Annexe à l’arrêté du 15 mars 2022
portant modification de l’arrêté du 29 novembre 2016 modifié relatif à la procédure
d’agrément et portant cahier des charges des éco-organismes de la filière des emballages
ménagers. (TREP2135200A).
Ministère de la transition écologique and Ministère de l’agriculture et de l’alimentation, 2022,

Arrêté du 15 mars 2022 listant les emballages et déchets compostables, méthanisables et
biodégradables pouvant faire l’objet d’une collecte conjointe avec des biodéchets ayant fait
l’objet d’un tri à la source (JORF n°0069 du 23 mars 2022).
Ministry for the Ecological Transition/ CGDD / SDES, 2021, Questionnaire to Member States
for providing information into the Early Warning analyses – France. 17/3/2021.
Zero Waste Europe, B. industries consortium, 2020, Bio-waste generation in the EU: Current
capture levels and future potential.
1992, Loi No 92-646.
2000, Code de l’environnement.
2009, Loi n° 2009-967.
2015, Loi n° 2015-992.
2016, Décret n° 2016-288 du 10 mars 2016.
2016, Décret n° 2016-811 du 17 juin 2016.
2019, Code des douanes.
2019, Plan National de Gestion des Déchets,

(https://www.ecologie.gouv.fr/sites/default/files/Plan%20national%20des%20dechets_octo
bre%202019.pdf) accessed 25 March 2022, Ministère de la Transition Ecologique et Solidaire.
2020, Loi n° 2020-105.
2021, Décret n° 2021-950 du 16 juillet 2021.
45
Annex 1 Detailed scoring of success and risk
factors
46
Assessment sheet - Recycling target for municipal waste
MS France
Date Jun-22
SRF Assessment result Weight Score

Current situation and past trends
Distance to target > 15 percentage points or no data

MSWR-1.1 Distance to target 5 0
reported
RR < 45% and increase in last

MSWR-1.2 Past trends in municipal solid waste recycling rate 1 0
5 years < 10 percentage points
Legal instruments
Timely transposition of the revised WFD into national Transposition with delay of > 12 months, or no full
MSWR-2.1 1 0
law transposition yet
Clearly defined responsibilities and good set of support

tools but weak/no enforcement mechanisms for
OR
Unclear responsibilities but clearly defined
Clearly defined responsibilities for meeting the targets
MSWR-2.2 enforcement mechanisms and a good set of support 1 1
and support and enforcement mechanisms tools for meeting the recycling targets
OR
Clearly defined responsibilities and enforcement
mechanisms but no/weak support tools for meeting the
recycling targets
Economic instruments
Taxes and/or ban for landfilling residual or biodegradable Ban, or landfill tax > 30 EUR/t* with escalator, or landfill
MSWR-3.1 1 2
waste tax > 45 EUR/t
MSWR-3.2 Taxes on municipal waste incineration Taxes > 7 EUR/t* with escalator, or tax > 18 EUR/t 1 2
MSWR-3.3 Pay-as-you-throw (PAYT) system No or less than 50% of the population covered by PAYT 1 0
Separate collection systems
Convenience and coverage of separate collection

MSWR-4.1
systems for the different household waste fractions

Paper and cardboard 0.46 0.92
convenience collection services

Metals 0.08 0.16

Plastics 0.28 0.56

Glass 0.18 0.36
A low share of the population is covered by high

Bio-waste 0.84 0

Wood 0.06 0

Textiles 0.06 0
WEEE Medium convenience collection services dominate 0.04 0.04

Firm plans to improve the convenience and coverage of
MSWR-4.2 separate collection systems for the different household
waste fractions
N/A (for countries in which a very high share of the
Paper and cardboard population is already covered by high convenience 0.23 0

Metals population is already covered by high convenience 0.04 0
Firm plans to improve the separate collection system,

Plastics with clear responsible entities and defined targets and 0.14 0.28
timeline

Glass population is already covered by high convenience 0.09 0
There are plans to improve the collection service but

Bio-waste 0.42 0.42
unclear plan for implementation
No firm plans to improve the convenience and

Wood 0.03 0
coverage
Firm plans to improve the separate collection system,

Textiles with clear responsible entities and defined targets and 0.03 0.06
timeline
No firm plans to improve the convenience and

WEEE 0.02 0
coverage
Extended producer responsibility (EPR) and similar schemes
There is an advanced fee modulation for at least two of

MSWR-5.1 Fee modulation in EPR schemes for packaging the main packaging fractions* AND fee modulation for 1 2
one packaging fraction meets three assessment criteria
Bio-waste treatment capacity and quality management
Bio-waste treatment capacity below 80% of generated

MSWR-6.1 Capacity for the treatment of bio-waste municipal bio-waste and no plans to extend capacity, or 1 0
no capacity information available
Legally binding national standards for

Legally binding national standards and Quality
MSWR-6.2 compost/digestate quality in place, and quality 1 2
Management System for compost/digistate management system in place
Total score 11.80

Maximum score 33.28
35%
Assessment sheet - Recycling target for packaging waste
MS France
Date Jun-22

P-1.1 Distance to target - Overall packaging 5 - 15 percentage points below target 5 5
Distance to target - Paper and cardboard packaging < 5 percentage points below target, or target exceeded 5 10
Distance to target - Ferrous metals packaging < 5 percentage points below target, or target exceeded 5 10
Distance to target - Aluminium packaging < 5 percentage points below target, or target exceeded 5 10
Distance to target - Glass packaging < 5 percentage points below target, or target exceeded 5 10
> 15 percentage points below target, or no data
Distance to target - Plastics packaging 5 0
reported
Distance to target - Wooden packaging < 5 percentage points below target, or target exceeded 5 10
RR > 60% and increase in
last 5 years < 5 percentage points,
or
RR > 55%, and increase in
P-1.2 Past trends in packaging waste recycling rate 1 1
last 5 years < 10 percentage points,
or
RR < 55% and increase in
last 5 years > 10 percentage points
last 5 years > 5 percentage points,
or
Past trends in paper and cardboard packaging recycling RR > 65% and increase in 1 2
last 5 years > 10 %,
or
RR > 75%

or
Past trends in ferrous metals packaging recycling RR > 60% and increase in 1 2
or
RR > 70%

or
Past trends in aluminium packaging recycling RR > 40% and increase in 1 2
or
RR > 50%

or
Past trends in glass packaging recycling RR > 60% and increase in 1 2
or
RR > 70%
RR < 40% and increase in last 5 years < 10 percentage
Past trends in plastic packaging recycling 1 0
points

or
Past trends in wooden packaging recycling RR > 15% and increase in 1 2
or
RR > 25%
Legal instruments
Timely transposition of the revised Packaging and Transposition with delay of > 12 months, or no full
P-2.1 1 0
Packaging Waste Directive into national law transposition yet
Clearly defined responsibilities and good set of support

tools but weak/no enforcement mechanisms for
OR
Unclear responsibilities but clearly defined
Clearly defined responsibilities for meeting the targets
P-2.2 enforcement mechanisms and a good set of support 1 1
and support and enforcement mechanisms tools for meeting the recycling targets
OR
Clearly defined responsibilities and enforcement
mechanisms but no/weak support tools for meeting the
recycling targets
Economic instruments
Taxes and/or ban for landfilling residual or biodegradable
P-3.1 Ban, or landfill tax > 30 EUR/t* with escalator 1 2
waste
P-3.2 Taxes on municipal waste incineration Taxes > 7 EUR/t* with escalator, or tax > 18 EUR/t 1 2
P-3.3 Packaging taxes No packaging taxes 1 0
P-3.4 Pay-as-you-throw (PAYT) system No or less than 50% of the population covered by PAYT 1 0
P-3.5 Deposit-return systems for aluminium drink cans No or voluntary DRS for some drink cans 1 0
Deposit-return systems for glass drink bottles No or voluntary DRS for some drink bottles 1 0
Deposit-return systems plastic drink bottles No or voluntary DRS for some drink bottles 1 0
Deposit-return systems for plastic crates No or voluntary DRS for some plastic crates 1 0
Deposit-return systems for wooden packaging No or voluntary DRS for some wooden packaging 1 0
Separate collection systems
Convenience and coverage of separate collection

P-4.1
systems for the different packaging waste fractions

Paper and cardboard packaging (household) 1 2
Separation at source is mandatory for non-household

Paper and cardboard packaging (non-household) 1 2
paper and cardboard packaging waste

Ferrous metals packaging (household) 1 2

Ferrous metals packaging (non-household) 1 2
ferrous metals packaging waste

Aluminium packaging 2 4
A high share of population is covered by high

Glass packaging (household) 1 2

Glass packaging (non-household) 1 2
glass packaging waste

Plastics packaging (household) 1 2

Plastics packaging (non-household) 1 2
plastic packaging waste

Wooden packaging 2 4
wooden packaging waste
Firm plans to improve the convenience and coverage of
P-4.2 separate collection systems for the different packaging
waste fractions
N/A (for countries in which a high share of the
Paper and cardboard (household) population is already covered by high convenience 0.5 0
N/A (for countries already having mandatory sorting at

Paper and cardboard (non-household) 0.5 0
source)

Ferrous metals packaging (household) population is already covered by high convenience 0.5 0

Ferrous metals packaging (non-household) 0.5 0
source)

Aluminium packaging population is already covered by high convenience 1 0

Glass packaging (household) population is already covered by high convenience 0.5 0

Glass packaging (non-household) 0.5 0
source)
Plastics packaging (household) population is already covered by high convenience 0.5 0

Plastics packaging (non-household) 0.5 0
source)

Wooden packaging 1 0
source)
Extended producer responsibility (EPR) and similar schemes

Not all main packaging fractions* are covered by EPR
schemes
OR
P-5.1 Coverage of EPR schemes 1 0
All main packaging fractions are covered by EPR
schemes but none or only one covers household and
non-household packaging
There is fee modulation in at least two of the main

P-5.2 Fee modulation in EPR schemes for packaging packaging fractions* AND fee modulation for one 1 2
packaging fraction meets three assessment criteria
Material specific EPR assessment - Paper and cardboard No EPR scheme or EPR scheme covering only
P-5.3 1 0
packaging waste household, industrial OR commercial packaging
Material specific EPR assessment - Ferrous metals No EPR scheme or EPR scheme covering only household
1 0
packaging waste OR non-household packaging
Material specific EPR assessment - Aluminium packaging No EPR scheme or EPR scheme covering only household
1 0
waste OR non-household packaging
No EPR scheme or EPR scheme covering only household

Material specific EPR assessment - Glass packaging waste 1 0
OR non-household packaging
No EPR scheme or EPR scheme covering only

Material specific EPR assessment - Plastics packaging
household, industrial OR commercial packaging OR EPR 1 0
waste scheme but without fee modulation
Material specific EPR assessment - Wooden packaging No EPR scheme or EPR scheme covering only industrial
1 0
waste OR commercial packaging
Total packaging recycling target 17.00

Maximum score 32.00
53%
Paper and cardboard recycling target
Total score 21.00
Maximum score 30.00
70%
Ferrous metals packaging recycling target
Total score 21.00
Maximum score 30.00
70%
Aluminium packaging recycling target
Total score 21.00
Maximum score 32.00
66%
Glass packaging recycling target
Total score 21.00
Maximum score 32.00
66%
Plastics packaging recycling target
Total score 9.00
Maximum score 34.00
26%
Wooden packaging recycling target
Total score 21.00
Maximum score 32.00
66%
Assessment sheet - Target for landfilling of municipal waste
MS France
Date Jun-22

Distance to target < 10 percentage points, or target
LF-1.1 Distance to target 5 10
exceeded
Landfill rate in 2020 < 20% and decrease in last 5 years

< 5 percentage points,
or
Landfill rate in 2020 < 25%, and decrease in last 5 years
LF-1.2 Past trends in municipal solid waste landfill rat 1 1
< 10 percentage points,
or
Landfill rate in 2020 > 25% and decrease in last 5 years
> 15 percentage points
Target for reducing the amount of biodegradable

municipal waste (BMW) landfilled to 35% of BMW
LF-1.3 Diversion of biodegradable municipal waste from landfill 1 2
generated in 1995 has been achieved in 2016 or in the
year specified in the derogation where applicable
Total score 13.00

Maximum score 14.00
93%

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Country profile

Early warning assessment related to the 2025 targets

Waste management plan(s)

Packaging waste generation and treatment

Source: Eurostat (2022b)

Capture rates for recyclables

Table 1.1 Capture rates for different waste fractions in France

Residual Residual Separately Materials in Capture rates

2.1.1 Current situation and past trends

SRF MSWR-1.2: Past trend in municipal solid waste recycling rate

2.1.2 Legal instruments

2.1.3 Economic instruments

SRF MSWR-3.2: Taxes on municipal waste incineration

SRF MSWR-3.3: Pay-as-you-throw (PAYT) system in place

2.1.4 Separate collection system

Cities Towns and suburbs Rural areas

(<5 per km²)

(>5 per km²)

(<5 per km²)

2.1.5 Extended producer responsibility (EPR) and similar schemes

2.2.1 Current situation and past trends

Figure 2.2 Packaging recycling rates for France in 2019, in percentage

Source: Eurostat (2022c), EU (2018)

SRF P-1.2: Past trend in Packaging Waste Recycling

Source: Eurostat (2022c)

2.2.2 Legal instruments

2.2.3 Economic instruments

SRF P-3.2: Taxes on municipal waste incineration

SRF P-3.3: Packaging taxes

SRF P-3.4: Pay-as-you-throw (PAYT) system in place

The PAYT system is described in detail under SRF MSWR-3.3.

SRF P-3.5: Deposit-return systems

1. Packaging waste from households

2.2.5 Extended producer responsibility (EPR) and similar schemes

SRF P-5.2: Fee modulation in EPR schemes for packaging

SRF P-5.3 Material specific EPR assessment

SRF LF-1.2: Past trend in municipal solid waste landfill rate

Source: Eurostat (2022a).

SRF LF-1.3: Diversion of biodegradable municipal waste from landfill

Based on the provided information and the analysis done, it is

The recycling rate is reported to be 42.7 % in 2020, which is

France has an incineration tax in place, which was increased

For paper and cardboard, plastics, ferrous metals, aluminium,

No exact capacity information is available, but it is estimated

Based on the provided information and the analysis done, it is

70 % of maximum score Paper and cardboard Not at Risk

70 % of maximum score Ferrous metals packaging Not at Risk

66 % of maximum score Aluminium packaging Not at Risk

66 % of maximum score Glass packaging Not at Risk

26 % of maximum score Plastics packaging At Risk

66 % of maximum score Wooden packaging Not at Risk

The total packaging recycling rate, after an estimated correction

France does not have a packaging tax in place.

The coverage and convenience level for the collection of

2.6 Prospects of meeting the landfill of municipal waste target

Based on the provided information and the analysis done, it is

EUR-LEX, 2021b, National transposition measures communicated by the Member States

Eurostat, 2020, ‘Comparative price levels of consumer goods and services’

Eurostat, 2022a, ‘Municipal waste by waste operations [env_wasmun]’