Product Compliance Resources provided by ProductIP


French Decree 2022-748 - Why a Verifeyer Form?

Disclaimer: This document provides guidance and is not a legally binding interpretation and shall therefore not be relied upon as legal advice.

The French government has made circular economy and supply chain transparency-related aspects around non-food consumer goods a high priority. They don’t want to wait on various EU initiatives, they want to make progress now, and significantly. So they have developed legislation that impacts companies/brands making products available on the French market. 
This French Decree 2022-748 is part of this program and it focuses on being clear about the following aspects:
- recyclability of materials used in products packaging, box and paper
- % of recycled material used in products packaging materials, and no green-washing
- recyclability of electronic products and if relevant batteries
- the use of precious metals and rare earths in electronic products and batteries, how much and how much comes from recycled sources
- has the product ever be found in conflict with ECO design regulations and fined for that?
- for relevant product categories an indication of the repairability
- SVHC's in the product over 0.1%. These should be reported in the ECHA SCIP database anyway. That information is public but they want it to be more prominent in the face of consumers
- for apparel and footwear transparent about various steps of the supply chain
This information needs to be publicly available - via the Internet - to consumers. So not part of the product but to be found on the brand related website. One could look at this as a first step towards a Digital Product Passport.

So why a Verifeyer form?

The smart-form we have created helps you to collect the relevant data from your supply chain. The result is a PDF in proper FRENCH with the relevant data fields and format that you can use one on one as source to be published. The preferred way to do so is of course to activate the Digital Product Passport / Public File layer of your ProductIP technical file and set the status of this document to PUBLIC. The URL and related QR code can be used in communication and for example on your website. You can of course also download the PDF and upload it to your own webserver. Enterprise customers can benefit from an CSV based API with ProductIP where activated PUBLIC FILE URLs can be exchanged in order for your side to implement these at your website. Contact your account manager for more information. 
Note that you can also fill in the form yourself from within the technical file.
This is a first release. The end result is now a PDF. We will closely monitor how this is working and as a next step we will consider also to release the data layer, not as PDF but as web-searchable information. There is no timeline for this currently.


Q. So what should I do with the information?
A You need to make it publicly available via the Internet when you are responsible of making a product available in the French market.
Q Is this mandatory?
A Yes it is for France
Q Do I need to do this for every article I sell in France?
A Not for all products yet, but already for many including packaging. Rely on ProductIP’s requirements list. Note that the information set is not the same for each type of article. The form will guide you via questions to determine what is relevant. Packaging and SVHC related information always is.
Q We don’t have a facility on our website to deal with this, how can you help?
A Use the Digital Product Passport / Public File functionality that is integrated in each ProductIP technical file already (since November 2010)
Q Does the document not require a signature?
A It does not. Making it publicly available is already the statement. Information provided to consumers should be true!
Q Is there not a template that I can fill in?
A Not this moment and we don’t consider it. We have opted for a smart form (in English) that generates a proper output in French.

Q Why do I need to fill this in when I am clearly not in the scope according to the table?
A This French Decree 2020-748 applies to the one offering products under their brand onto the French market. The request, and the need, to supply data could come from your customer, or even their customer, as it is applicable to them. That confirmation option will be visible when you select NO to the first question. You then select YES to the second option. See example screenshot.

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