FRENCH WEEE REGISTER FOR PRODUCERS OF ELECTRICAL AND ELECTRONIC EQUIPMENT
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1 FRENCH WEEE REGISTER FOR PRODUCERS OF ELECTRICAL AND ELECTRONIC EQUIPMENT USER GUIDE FOR AUTHORISED REPRESENTATIVES January 2018 ADEME Angers Direction Économie Circulaire et Déchets Service Produits et Efficacité Matière
2 TABLE OF CONTENTS TABLE OF CONTENTS... 2 GLOSSARY 2 I. REGULATORY REQUIREMENTS... 3 I.1. GENERAL INFORMATION... 3 I.1.1. What is an authorised representative?... 3 I.1.2. Who can serve as authorised representative?... 3 I.1.3. Which companies are already registered as authorised representatives on SYDEREP?... 4 I.2. WHAT ARE THE OBLIGATIONS OF EUROPEAN PRODUCERS? WHO HAS TO APPOINT AN AUTHORISED REPRESENTATIVE IN FRANCE?... 4 I.2.1. Scenario 1: Foreign producers putting equipment on the French market through distance selling... 5 I.2.2. Scenario 2: Foreign producers putting equipment on the French market through distributors... 6 I.2.3. Scenario 3: Foreign producers putting equipment on the French market both through distributors and distance selling... 6 I.2.4. Scenario 4: Foreign producers selling directly to professional users in France (excluding distance selling)... 6 I.2.5. Documents to be provided... 6 II. SYDEREP DECLARATIONS... 8 II.1. SIGN-IN TO WEEE REGISTER... 8 II.1.1. Who is required to register with the Register?... 8 II.1.2. How can an authorised representative register?... 8 II.1.3. How to register a European producer using an authorised representative account? II.2. REGISTRATION AND DECLARATION TO THE WEEE REGISTER II.2.1. Registration of the equipment status and the related collection and treatment organisation II.2.2. Declaration to the Register III. WHO DO I CONTACT IF I HAVE A QUESTION? GLOSSARY WEEE: Waste of Electrical and Electronic Equipment EEE: Electrical and Electronic equipment PRO: Producer Responsibility Organisation (in French éco-organisme ) WEEE Register Explanatory note regarding authorised representative 2/22
3 I. REGULATORY REQUIREMENTS I.1. GENERAL INFORMATION I.1.1. What is an authorised representative? Directive 2012/19/EU and its transposition into French law (Decree ) established the authorised representative, a producer established in another EU Member State may designate by written mandate a natural or legal person established in France as the appointed person for ensuring compliance with the obligations under the regulations for waste of electrical and electronic equipment (unofficial translation). Warning Not to be confused with actor category appointed person already existing in the Register. The appointed person is a person or company that has obtained a mandate to represent an appointing producer in a legal act (in this case, the obligation to report to the WEEE Register). It is an intermediary only on the administrative aspects of the declaration (recording of the types of equipment for which the appointing person must make declarations, carry out the reports annually). The appointed person differs from the authorised representative who has more obligations (financial, organisational in addition to administrative aspects). This includes joining a PRO or setting up an individual scheme on behalf of the producer. The authorised representative bears responsibility for the management of the WEEE of the producer it represents. I.1.2. Who can serve as authorised representative? The authorised representative must satisfy the conditions set in the Order of October 8, The authorised representative must be an entity based in France. No list or set of criteria have been laid down regarding which structure can take on the role of the authorised representative. However, the authorised representative appointed by the producer must be able to satisfy the producer s obligations: administrative, financial, logistical, etc. The authorised representative may be a subsidiary of the company, a company offering its services as authorised representative, a PRO (which will perform its services as authorised representative separately from its activities as a PRO), etc. The contract between an authorised representative and a producer established in another EU Member State must cover all electrical and electronic equipment put on the French market by economic operators as part of direct business relationship with the producer or through distance selling by the producer directly to households or users other than private households (Order of October 8, 2014, on authorised representative, Article 1). A producer can only have one authorised representative in France. Warning: In cases where PRO serve as authorised representative In cases where a PRO is appointed as authorised representative, it will be responsible for ensuring compliance with all of the producer s obligations. A PRO can take on this function if such activity is separated from its main activities as PRO and must therefore, as an authorised representative, adhere to its own PRO. In case the producer puts equipment on the market, including some equipment which does not fall within the categories for which the PRO is accredited, the PRO must adhere to its own PRO for the categories for which it is accredited and join another PRO for the other categories that are not covered by its accreditation. WEEE Register Explanatory note regarding authorised representative 3/22
4 I.1.3. Which companies are already registered as authorised representatives on SYDEREP? On the SYDEREP homepage, it s possible to do a public actors research (in the bottom left corner of the homepage). You can click on and then on the EEE tab on the left. Then select authorised representative in the Type of reporter drop-down menu. Finally click on Search to display the list of authorised representatives registered on SYDEREP. I.2. WHAT ARE THE OBLIGATIONS OF EUROPEAN PRODUCERS? WHO HAS TO APPOINT AN AUTHORISED REPRESENTATIVE IN FRANCE? WEEE Register Explanatory note regarding authorised representative 4/22
5 I.2.1. Scenario 1: Foreign producers putting equipment on the French market through distance selling Important: what is distance selling? Distance selling is a sales contract in which a means of distance communication is used. The definition of a means of distance communication pursuant to Directive 97/7/EC is as follows any means which, without the simultaneous physical presence of the supplier and the consumer, may be used for the conclusion of a contract between those parties. This covers purchases made on the Internet, over the phone, by standard letter, press advertising with order form, catalogue, etc. Purchases using a smartphone application are also considered distance selling. However, contactless mobile payments made in stores with the simultaneous physical presence of the supplier and the consumer are not considered as distance selling. Distance sellers established in a given EU Member State and putting equipment on the market of another EU country have different obligations regarding the appointment of an authorised representative. They have the obligation (rather than the possibility) to appoint an authorised representative in the country where they sell EEE, as stated in Article 17 of Directive 2012/19/EU: each Member State shall ensure that a producer as defined in Article 3(1)(f)(iv) and established on its territory, which sells EEE to another Member State in which it is not established, appoints an authorised representative in that Member State as the person responsible for fulfilling the obligations of that producer, pursuant to this Directive, on the territory of that Member State. Producers established in an EU country other than France and putting EEE on the French market through distance selling have the obligation to appoint an authorised representative in France. This obligation is enshrined in the regulations of the Member State where the producer is established. Warning This rule applies to companies based in France and selling EEE in other EU Member States: they must appoint an authorised representative in such states to ensure the compliance with the producer s obligations. A producer established in France selling electrical and electronic equipment by means of distance communication directly to households or to users other than households in another EU Member State appoints by written mandate a natural or legal person established in that State to be responsible for ensuring compliance with the producer s obligations under the regulations for electrical and electronic equipment applicable in that State. (unofficial translation, Art. R of the French Environmental Code, added by Decree ). The following decision flow chart specifies who has the obligation to appoint an authorised representative, depending on the country of the producer. WEEE Register Explanatory note regarding authorised representative 5/22
6 I.2.2. Scenario 2: Foreign producers putting equipment on the French market through distributors Producers established in a foreign country (in or outside the EU) putting EEE on the French market through distributors have no obligation to declare to the French WEEE Register. If their equipment is introduced or imported into France by French companies (distributors), the distributors are considered to be the producers, and in their quality of introducers or importers they shall themselves make such declarations. However, producers (excluding distance sellers, see cases specified in I.2.1) established in another Member State and exporting into France have the possibility (not the obligation) to appoint an authorised representative. Therefore it may choose to register instead of its French distributors and bears the obligations pertaining to EEE producers. For the record, the contract between an authorised representative and a producer established in another EU Member State must cover all electrical and electronic equipment put on the French market by economic operators as part of direct business relationship with the producer or through distance selling by the producer directly to households or users other than private households (Order of October 8, 2014, on authorised representative, Article 1). In such cases, the authorised representative appointed by the producer is therefore responsible for the management of the EEE put on the market by all EEE distributors. The regulation has not provided the possibility for a foreign producer (outside the EU) to appoint an authorised representative to satisfy the obligations of the distributors to whom it sells EEE in France. In such cases, the distributors are therefore considered to be the producers according to the regulation and must register on the French WEEE Register and declare the EEE put on the French market. Note: this does not cover the EEE sold under the brand name of a French distributor. The authorised representative can only be responsible for satisfying the obligations of introducers. I.2.3. Scenario 3: Foreign producers putting equipment on the French market both through distributors and distance selling Producers selling equipment through distributors and distance selling are required to appoint an authorised representative (Article 17 of Directive 2012/19/EU) covering all of such EEE (Order of October 8, 2014 regarding authorised representatives, Article 1). It is therefore not possible to appoint an authorised representative to manage equipment sold through distance selling only. The distributors in question are not required to make a declaration to the SYDEREP regarding such equipment. I.2.4. Scenario 4: Foreign producers selling directly to professional users in France (excluding distance selling) In rare cases, a purchase can be concluded between a foreign producer and a French professional user, without using a means of distance communication or an intermediary distributor. To be considered as falling in this category, the foreign company must be indicated on the client s invoice. Example of sales concluded between a foreign producer and professional users without means of distance selling: - Act of purchasing concluded in France with a representative of a company based in another Member State, invoiced by a foreign entity (e.g. during a trade show or fair). - Act of purchasing concluded with a company based in France, but invoiced by a foreign entity (e.g. parent company). Regarding the definition of authorised representative, it is the same as in the case of a distributor: producers established in a foreign country (in or outside the EU) selling EEE on the French market through direct sales to users have no obligation to make a declaration to the French Register. If their equipment is imported into France by French companies (users), these users are considered to be the producers, and in their quality of importers they shall themselves make such declarations. Producers (excluding distance sellers, see cases specified in I.2.1) established in another Member State and exporting into France have the possibility (not the obligation) to appoint an authorised representative. Therefore they may choose to register instead of their French user companies and bears the obligations pertaining to EEE producers. I.2.5. Documents to be provided Any producer appointing an authorised representative must establish a contract. A contract template can be downloaded from the homepage of SYDEREP, section EEE, Documents to download WEEE Register Explanatory note regarding authorised representative 6/22
7 Warning Any authorised representative setting up an individual scheme for professional WEEE management on behalf of a producer must also provide a certificate for setting up an individual scheme. A specific template for authorised representatives can be downloaded from the homepage of SYDEREP, section EEE, Documents to download : WEEE Register Explanatory note regarding authorised representative 7/22
8 II. SYDEREP DECLARATIONS Important If the regulation applies to you as a European producer, your authorised representative will perform all the administrative aspects with the WEEE Register on your behalf. The European producer is not required to register, only the authorised representative must register with the SYDEREP s WEEE Register. Indeed, the authorised representative will register the European producer who appointed him and remains the only contact point with the WEEE Register. This document outlines the registration procedure specific to authorised representatives and European producers. For general information about the use of SYDEREP, please refer to the User Guide available on the homepage of SYDEREP (under Documents to download ): II.1. SIGN-IN TO WEEE REGISTER II.1.1. Who is required to register with the Register? Only the authorised representative is required to register. The producer will be registered directly by its authorised representative. II.1.2. How can an authorised representative register? Sign-in as an authorised representative is performed by clicking on the sign-in link on SYDEREP home page: Warning In case your company is already registered on SYDEREP for the WEEE sector (as a producer, for example), you must create a new account to submit declarations as an authorised representative. In such case, if your producer account was registered using your SIREN numbers (9 numbers + 5 times 0 ), you must use your SIRET number to register as an authorised representative (14 numbers), and vice versa. In exceptional cases (SIRET and SIREN numbers already in use for different accounts), please contact the administrator. Data is not saved as it is input. Warning Only after all requested fields have been completed and you have clicked on Validate the signing-in at the bottom of the screen and get the message for confirmation of subscription is the data input saved. WEEE Register Explanatory note regarding authorised representative 8/22
9 II ENTER YOUR COMPANY INFORMATION Field to be completed IDENTITY Country *: SIREN/SIRET *: Legal category *: Corporate name *: Address *: Postal code or Distributor office *: Person in charge: Explanations, comments, constraints Fields to be completed to provide your company s details. Each asterisk (*) shows that the information is compulsory. The default country is France. Overseas departments (Guadeloupe, French Guyana, Martinique, Mayotte and Réunion) should select France. French regulations require the authorised representative to be based in France. Any registration of an authorised representative based in another country will therefore be rejected. Enter your company SIREN or SIRET. A message appears on screen if when you attempt to sign-in your entity, your company is already signed-in. Choose from the proposed list (select SAS for SASU). Name of the company (and not its legal status). 3 address fields are available Continuation of the address where necessary Continuation and end of the address where necessary Enter the first 3 digits of the postal code or the first 3 letters of the distributor office: a list comprising the characters entered appears. Select the entry corresponding to your locality. Name of the officer or manager in charge of the company. Phone (switchboard): The following formats are accepted: 10 digits, potentially separated by spaces or dots +33 followed by 9 digits, potentially with separators. Where the company has a number outside France, enter and indicate the actual telephone number in the Comment field (preceded by Tel:). Website *: NAF code NAF *: Comment: Enter the company s website address with care, commencing with www (do not enter If you do not have a website, tick the box No website. Enter the first 3 digits and select the code corresponding to your activity: main activity exercised using the NAF codes in effect since January 1, 2008 (you can check your NAF code by visiting Enter any additional address details or information concerning the head office, parent company or management of your company. Telephone numbers outside France (see Phone field above). WEEE Register Explanatory note regarding authorised representative 9/22
10 II ENTER THE DESIGNATED CONTACT OF YOUR COMPANY We draw your attention to the fact that the address chosen is to be used as your login name when you log into SYDEREP in the future. Warning The person who registers using their personal address shall be designated by default as the DESIGNATED CONTACT PERSON, i.e. said person alone shall have modification rights for the company (registration for a new sector, management of all the company addresses and the contacts and their rights). Once the ADEME has validated the registration request, the DESIGNATED CONTACT PERSON may add other contacts to the company and assign a different designated contact person, should they so desire. The people added by the designated contact person shall receive their own login names ( address and personal password), thus avoiding the passing around of login names and increasing the security of the data generated by the site. They may have viewing rights or modification rights (allowing them to make the declarations). The rights are allocated by the DESIGNATED CONTACT PERSON. Field to be completed DESIGNATED CONTACT Explanations, comments, constraints Fields to be completed to provide the details of the designated contact who will have editing rights for the company; i.e. he/she alone will be able to request the registration to a new sector, unsubscribe and manage the set of addresses and contacts for the company. *: Professional address of the company s designated contact: you will use this address as your login name. confirmation *: Re-input the preceding field (the copy/paste function is disabled). Title *: Name *: First name *: Same address as the company: Function/Capacity: Language *: Phone 1 *: Phone 2 *: Choose from the proposed list. This box is ticked by default. It is unnecessary to re-input the designated contact s address if it is identical to that entered in the Identity section. Where this is not the case, un-tick the box and the fields to be completed with the contact s address will appear (see Identity section for information on these fields). The default language is French. As the site is bilingual, you can select English if you prefer, in order to consult the SYDEREP screens in English on your future visits. See the Phone field above (Identity section) A cell phone number can be entered WEEE Register Explanatory note regarding authorised representative 10/22
11 Fax : Comment: Add a contact The addition of a second contact at the time of sign-in is optional. By default, this second contact will only have viewing rights for your company. II SELECT THE SECTOR FOR WHICH YOU WANT TO SIGN UP AND YOUR CATEGORY The appointed representative must sign up by selecting the Authorised Representative category. II CERTIFY THE COMPLIANCE OF THE DATA ENTERED Enter the code ( captcha code) to allow ADEME to ensure the sign-in request is being made by a user ENTER THE CODE and not an IT program. If you cannot read the number, click to change the image CERTIFY THE To complete your sign-in request, you must certify the conformity of the entered data by ticking the box ENTERED DATA at the bottom of the screen. WEEE Register Explanatory note regarding authorised representative 11/22
12 II VALIDATE YOUR REGISTRATION You must validate signing in order to send your request to the administrators. When you click on the Validate the signing in button, all mandatory fields must be completed and valid. If a mandatory field is empty, validation is impossible. If a mandatory field is invalid, signing in can similarly not be validated. A message appears in red at the top of the sign-in screen listing the fields requiring entries or for which the data input format is invalid. The fields to be completed or corrected appear in red in the body of the sign-in form: When all mandatory fields are complete and valid a sign-in confirmation screen appears. A summary containing all data input in the sign-in form can be downloaded: Warning Note: the summary document cannot be downloaded after the confirmation screen has been closed; you are therefore strongly advised to save this document on your computer by clicking on Download the summary before clicking on the Close button. WEEE Register Explanatory note regarding authorised representative 12/22
13 Warning The account can t be accessed before this registration validation phase (maximum deadline: 1 week). II SIGN-UP CONFIRMATION Your sign-up request is sent to the administrator. You will receive a single-use link to activate your account when it has been validated, enabling you to access your account with your login (= address your entered when signing in) and you password. In case of refusal, the contains a message from the administrator explaining the refusal. If another contact was created during registration, this contact will also receive an with the link to activate the second account. If you lose the sign-in confirmation containing the link to activate your account go to the SYDEREP homepage and click on the Forgot your password link. Enter the address provided during the sign-in process. You will be sent an containing a new link. Once you are logged into this account, you can access via the Appointing Producers menu: a registration window to register a European producer (this page is not accessible if you are not logged in); the contact details of the European producers you have registered. II.1.3. How to register a European producer using an authorised representative account? Important The authorised representative will register the European producer who appointed him and remains the only contact point with the Register. The contact details (name, , phone) of appointing producers are not registered in SYDEREP. To register a producer, select the Appointing producers menu then click on Create a European producer. WEEE Register Explanatory note regarding authorised representative 13/22
14 To register, follow the four following steps: II FILL IN THE INFORMATION REGARDING THE IDENTITY OF THE APPOINTING PRODUCER (EUROPEAN PRODUCER) Field to be completed IDENTITY Country *: Explanations, comments, constraints Fields to be completed to provide your European producer details. Each asterisk (*) shows that the information is compulsory. The default country is France. It is possible to select another country from the proposed list. National identifier *: This corresponds to the identifier on the trade register of the country of origin. Legal category : Corporate name *: Address *: Postal code: Locality: Person in charge: Phone (switchboard): Choose from the proposed list if relevant. Name of the company (and not its legal status). 3 address fields are available Continuation of the address where necessary Continuation and end of the address where necessary Enter the postal code of the European producer if relevant. Enter the city of the European producer. Name of the officer or manager in charge of the company. Enter the phone number, beginning with + (compulsory). WEEE Register Explanatory note regarding authorised representative 14/22
15 Website *: Comment: Enter company website address, commencing with www (do not enter If the company doesn t have a website, tick the box No website. Enter any additional address details or information concerning the head office, parent company or management of your company. Telephone numbers outside France (see Phone field above). II ENTER THE MANDATE START AND END DATES Field to be completed MANDATE Mandate start date*: The three fields are mandatory. Explanations, comments, constraints The start date of the mandate should cover the period for which data are reported. Example: An authorised representative must submit declarations for the year 2017 and was mandated by the producer on 01/01/2018. The start date of the mandate should be 01/01/2017 for a declaration covering the year Mandate end date*: Indicate 31/12 of the last year covered by the authorised representative's declaration. PDF File* of the mandate: It s not possible to extend an ended mandate. If no date has been set yet, indicate a date in the future (50 years from now, for example), which can be modified when the mandate comes to an end. The mandate must be submitted in PDF format. Submitting the file is necessary to complete the registration. Warning It is now possible for an authorised representative to modify the start and/or end date of the mandate whose status is in progress (a mandate that is already ended cannot be extended). It is not required to upload the PDF mandate on SYDEREP again. II SELECT THE SECTOR The Sectors section cannot be modified as only one combination of Category / Type of reporter is possible to register a European producer. WEEE Register Explanatory note regarding authorised representative 15/22
16 II VALIDATE YOUR REGISTRATION To complete your sign-in request, you must certify the conformity of the entered data by ticking the box at the bottom of the screen. When you click on the Validate the signing in button, all mandatory fields must be completed and valid. If a mandatory field is empty, validation is impossible. If a mandatory field is invalid, signing in can similarly not be validated. A message appears in red at the top of the sign-in screen listing the fields requiring entries or for which the data input format is invalid. The fields to be completed or corrected appear in red in the body of the sign-in form: Important If you wish to register a producer but the latter is already registered on SYDEREP, you will receive a message upon trying to validate the registration. WEEE Register Explanatory note regarding authorised representative 16/22
17 In this case, you shall ask the administrators of the sector to unsubscribe him, and then proceed to register him as a European producer. You can then register the producer following the procedure presented in II The account used till then can still be accessed by the company, if necessary. Note: the accounts of European companies registered with SYDEREP have been deactivated to avoid this problem. Exceptions are expected to be rare. When all mandatory fields are complete and valid a sign-in confirmation screen appears. A summary containing all data input in the sign-in form can be downloaded: The registration is automatically validated (no prior validation by the administrator). Information Once the registration of the European producer is complete, the dates of the mandate and PDF file can be modified at any time in the Appointing producers menu by clicking on the edit section (pencil) to the right of the line corresponding to the producer in question: II.2. REGISTRATION AND DECLARATION TO THE WEEE REGISTER The steps to follow to register the equipment to be declared and submit a declaration are detailed in the Guide for Declarants, available on the homepage of SYDEREP (parts IV and V). Only the instructions specific to authorised representatives are detailed here. They depend on the selected method for the management of the WEEE of the European producer: If the choice was made to manage professional WEEE by making the European producers join a PRO, the authorised representative must provide the PRO with the registration number of the European producer with the Syderep (FR followed by 6 numbers) and request the PRO to add this membership to the account and transmit the declarations directly to the account of the European producer. The authorised representative has no other tasks to perform after that. He can consult the declarations made by the PRO. WEEE Register Explanatory note regarding authorised representative 17/22
18 If the choice was made to manage WEEE by setting up an individual system managed by the authorised representative, the authorised representative has to: o o provide a certificate for setting up an individual scheme (a specific template for authorised representatives can be downloaded from the homepage of SYDEREP, section EEE, Documents to download : follow the registration and declaration procedures. II.2.1. Registration of the equipment status and the related collection and treatment organisation In order to submit declarations on behalf of Appointing producers, you must first register the equipment to be reported on each of the accounts of the Appointing producer. Follow the following steps to register the equipment of an Appointing producer. Step 1: Go to the Appointing producers menu: Step 2: Click on the registration number of the client for which you want to register the equipment: Step 3: Click on the EEE registration tab WEEE Register Explanatory note regarding authorised representative 18/22
19 Step 3.1: Define the status of the equipment. The Status of the equipment tab serves to define the status (household or professional) and the mode of organisation chosen by the producer for the collection and treatment of the WEEE generated from EEE introduced to the French market. Warning In case of adhesion to a PRO, the authorised representative must provide the PRO with the registration number (FR followed by 6 numbers) of the registered European producer in order to create the adhesion of the latter. It will then be accessible in the EEE Registration tab, Memberships tab. Step 3.2: Define the types of the produced equipment. The Type of equipment produced tab serves to define the equipment which must be subject to declarations. WEEE Register Explanatory note regarding authorised representative 19/22
20 Click on the Add a line button at the bottom of the table to open the Detail of a product line window: Warning The Producer status which must be selected depends on the European producer s sale conditions: - European producers putting equipment on the French market through distance selling: Distance Seller from abroad (in such cases the European producer is required to appoint an authorised representative) - European producers putting equipment on the French market through distributors or selling directly to professionals: Introducers (in such cases the producer can choose to appoint an authorised representative which will fulfil the obligations of the distributors and the professional users). II.2.2. Declaration to the Register The reports of appointing producers are accessible in two ways: - Via the Reporting menu A search engine in the Reports of my appointing producers tab gives you access to the reports of appointing producers according to selected criteria. WEEE Register Explanatory note regarding authorised representative 20/22
21 Note: The Import tab should not to be taken into account because, to date, it is not possible to automatically import data on appointing producers. - Via the Appointing producers menu, by clicking on the registration number of the company: Using the WEEE Reporting tab you can enter or access reports regarding a given producer. For more information on the reporting procedure and advice on the Register, please refer to the User Guide available on the homepage of SYDEREP (under Documents to download ): WEEE Register Explanatory note regarding authorised representative 21/22
22 III. WHO DO I CONTACT IF I HAVE A QUESTION? A help service is available: Need help? By , all year: registredeee@ademe.fr. By phone, from Monday to Friday, from 9.00 to and to 18.00, from January to April at Remarque The registration number corresponds to your account on SYDEREP and allows administrators to easily find your company. We recommend you provide this number to the administrators upon contacting them (by or phone). For any more general question relative to the WEEE sector, we invite you to refer to the website of the French Environmental Agency (ADEME): then type DEEE or WEEE (documents available in English) into the search box. WEEE Register Explanatory note regarding authorised representative 22/22
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