Pharma and medical device companies can sit in up to four French EPR streams: medicines, patient sharps, electrical equipment and packaging. The medicines stream covers human medicines; its producers are the exploitants of medicines defined in article R. 5124-2 3° of the Public Health Code, and its only approved eco-organisme is Cyclamed (1 January 2022 to 31 December 2027). 
ADEME The sharps stream covers perforating medical devices used by patients in self-treatment and self-test users, including the electrical or electronic equipment attached to them since 1 January 2021; DASTRI is approved for it from 1 January 2023 to 31 December 2028. ADEMESources (3)ADEMEADEME — Filière REP Médicaments non utilisés (MNU)ADEMEADEME — Filière REP Dispositifs médicaux perforants (DISP-MED)
LégifranceLégifrance — article L. 541-10-9-1 of the Environmental Code (full text) Sources (2)ADEMEADEME — the French ecological transition agency
Ministère de la Transition éMinistère de la Transition écologique — filières REP
Stream by stream
| Product | Stream | Producer |
|---|---|---|
| Human medicines with a marketing authorisation | Unused medicines (MNU), Cyclamed ADEME | The exploitant (R. 5124-2 3° CSP) ADEME |
| Lancets, pen needles, syringes with needle, catheters, micro-infusers, self-test lancing devices | Patient sharps (DISP-MED), DASTRI ADEME | Medicine exploitants and device manufacturers, or their mandataire ADEME |
| Inserters and pumps with electronics, for patients in self-treatment ADEME | Patient sharps, electronic flow, DASTRI ADEME | As above ADEME |
| Other electrical devices (thermometers, blood-pressure monitors, TENS units) | Electrical and electronic equipment | Manufacturer or importer |
| Boxes, blisters, bottles, leaflets of medicines and devices | Household packaging Sources (2)ADEMEADEME — Filière REP Médicaments non utilisés (MNU)ADEMEADEME — Filière REP Dispositifs médicaux perforants (DISP-MED) | The brand owner or importer |
What the medicines stream excludes
- Empty primary and secondary packaging: it belongs to household packaging. ADEME
- Sharps of patients in self-treatment: they have their own stream. ADEME
- Medicines and care waste of health professionals. ADEME
- Veterinary medicines and other pharmacy products that are not medicines: parapharmacy, food supplements, medical devices. ADEME
Private label and reseller brands
When a medical device is sold under a reseller's or principal's brand under a written agreement, the reseller is the producer for the sharps stream. ADEME DASTRI publishes 14 product families: 12 for sharps and 2 for electronic devices (inserters and pumps). ADEME
Not the same as the MDR representative
A non-EU device manufacturer already has an EU authorised representative under the Medical Device Regulation. That role does not cover French EPR: membership, IDUs and declarations need a representative established in France under the environmental code.
A company with no establishment in France that is the producer must appoint a representative established in France by written mandate, since 10 July 2026. Légifrance The representative joins the eco-organismes in your name and you receive the IDUs.
Price
Our fee. Standard is €190 a year per eligible stream for household packaging, textiles, furniture, toys, graphic paper, sports and DIY goods, up to 1 tonne a year per stream. Every other stream (electrical equipment, batteries, wipes) and anything above 1 tonne is on Plus: €990 a year for up to three streams. Plus Pro, also €990, when you sell to businesses too. Setup is €0, and eco-contributions are paid at the eco-organisme's rate with 0% markup. See pricing.
Frequently asked questions
Are vitamins and supplements in the medicines stream?
No. Food supplements and parapharmacy are excluded from the medicines stream; their packaging is household packaging. Sources (2)ADEMEADEME — Filière REP Emballages ménagers et papiers (EMPAP)ADEMEADEME — Filière REP Médicaments non utilisés (MNU)
We make insulin pumps. Which stream?
Pumps with electronics used by patients in self-treatment are in DASTRI's electronic flow, not the general electrical equipment stream. Sources (2)ADEMEADEME — Filière REP Équipements électriques et électroniques (EEE)ADEMEADEME — Filière REP Dispositifs médicaux perforants (DISP-MED)
Do hospital-only products count?
Medicines and care waste of health professionals are outside the medicines stream; their packaging may fall under professional packaging from 2027. Sources (2)ADEMEADEME — professional packaging (EPRO) scheme pageADEMEADEME — Filière REP Médicaments non utilisés (MNU)
Razvan Toma is the founder of EPR France Rep, a France-established authorised representative (mandataire) for producers with no French establishment. He has worked in waste management and recycling since 2009, running waste-separation programmes inside large B2B organisations in France for clients including Chanel, Microsoft, Decathlon, Pirelli, IKEA, Vinci, Capgemini and E.Leclerc.
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