France: CITEO packaging declarations
CITEO requires component level declarations per conditional sales unit, submitted as CSV, with a separate household and commercial split. France operates the most explicit eco-modulation in Europe: recyclability earns a bonus, disrupting materials attract a malus, and the schedule is published so the financial effect of a design choice can be looked up.
What you must do
- Declare at component level per CSU (conditional sales unit) rather than at product level. Each component row carries material, weight and format data.
- Flag eco-modulation on each row: the bonuses the component qualifies for and the maluses it attracts.
- Provide the household and commercial split separately. CITEO expects both, and the split is not derivable after the fact if it was never recorded.
- Assess plastics recyclability through COTREP, and use CEREC where it applies, because those assessments feed the eco-modulation position.
- Record recycled content, since content above defined thresholds triggers additional bonuses.
What data you need
| Field | What the scheme needs |
|---|---|
| CSU structure | Which components belong to which conditional sales unit, because the declaration is organised around the CSU rather than the SKU. |
| Material per component | Mapped to the CITEO material rows, which split materials differently from both the VerpackG codes and the PPWR PP codes. |
| Component weight | Per component, carried on each declaration row. |
| Format | Carried on the row alongside material and weight, and part of what determines the eco-modulation position. |
| Household or commercial | The split CITEO expects as a separate breakdown. |
| Bonus and malus flags | Which bonuses apply and which disrupting materials attract a malus, recorded per component rather than estimated at portfolio level. |
| Recycled content | Per component, as a nullable value. Content above the relevant thresholds triggers additional bonuses. |
How fees work
France applies the most explicit eco-modulation of the schemes we generate for. Packaging meeting recyclability criteria receives a bonus, which is a fee reduction. Packaging using disrupting materials, meaning materials that contaminate recycling streams, receives a malus, which is a surcharge.
Recycled content above defined thresholds triggers further bonuses on top of the recyclability position.
Because the schedule of bonuses and maluses is published in detail, the financial effect of a specific material change can be looked up directly rather than estimated. That makes France the market where design decisions are easiest to cost before they are made.
What Merchant produces
- CITEO CSV with component level rows per CSU, carrying material, weight and format, plus the eco-modulation bonus and malus flags.
- The household and commercial split as CITEO expects it.
- Excel export of the same data set for review before submission.
Common mistakes
- Declaring at product level. CITEO is component level per CSU, and an aggregated declaration cannot carry the per component bonus and malus flags that determine what you pay.
- Treating a malus as unavoidable. The maluses attach to specific disrupting materials, and the published schedule means the cost of keeping one is knowable rather than a surprise on the invoice.
- Assuming a recyclability gain elsewhere carries into France. A change that improves a ZSVR assessment in Germany can leave the French position unchanged if the component still attracts a malus for a separate reason.
- Leaving the household and commercial split to be reconstructed later. It is a separate expectation of the declaration, and reconstruction after the period has closed is guesswork.
- Mapping CITEO materials from your German or UK mapping. The three schemes split materials differently, and a mapping reused across them is the most common source of wrong declared volumes.
How Merchant helps
- Generate the CITEO CSV with eco-modulation flags per component
- Assess components against COTREP and CEREC
- Model what a bonus or malus change is worth
Questions
Component level, organised per conditional sales unit. Each row carries material, weight and format data along with the eco-modulation flags.
A bonus is a fee reduction earned by meeting recyclability criteria or by including recycled content above a threshold. A malus is a surcharge applied for using disrupting materials, meaning materials that contaminate recycling streams.
In France, more readily than in most markets. The schedule of bonuses and maluses is published in detail, so the effect of a specific change on CITEO fees can be looked up rather than modelled from assumptions.
COTREP for plastics recyclability, and CEREC where it applies. Those assessments feed the eco-modulation position, which is what drives the fee.
Yes. CITEO expects the split as a separate breakdown regardless of how uneven it is, and it cannot be reconstructed accurately once the reporting period has closed.
Related reading
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