The multi-pronged plan will encourage a collaborative national effort to dispose of France’s “consume and discard” model.

By Paul A. Davies

The French Prime Minister recently unveiled the country’s circular economy roadmap. The 50-item scheme, announced on 23 April 2018, is the result of consultation with stakeholders (November 2017 —January 2018) and a two-stage online public participation involving the solicitation of comments and then the submission of draft roadmap (November 2017—February 2018).

The roadmap

Some measures are new and some derive from Law n°2015-992 of 17 August 2015 on energy transition, which was the catalyst for the nation’s circular economy scheme in a variety of respects. By 2019, the roadmap will be followed by a bill and regulatory measures transposing the EU’s Circular Economy Package objectives, which will lead to the amendment of the following directives:

  • Waste
  • Packaging waste
  • Landfill
  • Waste Electrical and Electronic Equipment Directive (WEEE)
  • End-of-life vehicles
  • Waste batteries
  • Accumulators

This roadmap calls for a broad effort (from citizens, consumers, local governments, businesses, and the state) to secure a successful energy/ecology transition and to conclude France’s linear produce-consume-discard model. The roadmap reflects the national societal initiative to get rid of the “consume and discard” model.

In quantitative terms, the roadmap’s aims include:

  • Reducing resource consumption 30% by 2030 (in relation to 2010 French GNP)
  • Reducing the quantity of non-dangerous waste landfilled 50% by 2025 (in relation to 2010 French GNP)
  • Moving towards a 100% plastic recycling rate by 2025
  • Reducing greenhouse gas emissions by about eight million tons per year through enhanced plastics recycling
  • Creating up to 300,000 new jobs, including in new business activities

The roadmap is structured as a four-prong scheme designed to improve production methods, enhance consumption behaviour, advance waste recycling, and secure the broadest possible stakeholder involvement.

Production methods

One key roadmap production method objective is to increase the range of products and achieve improved product differentiation via environmental performance. Incorporating an increased share of recycled materials will be pursued for plastics in particular, while financial risks in relation to the fluctuations of recycled materials will be transferred from recycling operators to those government-certified bodies which collect fees paid by waste producers to recover, sort and recycle the waste when such producers do not put an individual scheme in place. Certifications acknowledging certain reuse, repair, and recycling skills will also be created for vocational training programmes.

Consumption habits

The roadmap aims to achieve long-term, sensible consumption habits through:

  • Improved consumer information
  • Extended product lifecycles
  • Environmental reward-penalty system promoting eco-conceived products
  • In-depth assessment of the existing web of environmental/green labels
  • A reinforced fight against food waste

Waste management

Unsurprisingly, waste management forms the centrepiece of the roadmap. France’s track record in this respect is mediocre compared to that of its EU neighbours. During the preparation of the roadmap, the public voiced two specific expectations: simplifying waste sorting, and encouraging returnable bottle and container schemes. Among the 23 waste management measures, the following are particularly important:

  • Adapting taxation to render reuse and recycling more advantageous than disposal (through reduced VAT rates and redeployed General Tax of Polluting Activities (TGAP) in accordance with waste treatment priorities)
  • Incentivising waste collection tariffs and fees
  • Improving bio-waste recycling and empowering the agricultural sector in the overall circular economy scheme
  • Expanding the extended producer liability principle to new product categories
  • Easing the end-of-waste criteria and enforcement

Raising awareness

Raising awareness will be essential if France is to meet the roadmap’s objectives across the 50-item scheme. The government identifies the following specific roadmap targets to achieve these objectives:

  • Targeting citizens and businesses in an unprecedented communication and information effort
  • Supporting the move towards the circular economy via dedicated financings at local, national, and EU levels
  • Securing the continued participation of the scientific community
  • Contemplating heavily public procurement (15% of France’s GDP) as a lever to deploy the circular economy programme

Latham will continue to monitor France’s progress on its initiative.

This post was prepared with the assistance of David Desforges, Avocat à la Cour (Paris).