New EPR obligations in France for toys, sports equipment and gardening and DIY products from 2022


Extended Producer Responsibility (EPR) is a system in which manufacturers or distributors take financial and organisational responsibility for the disposal or recycling of products they produce or sell. In addition to the declaration for packaging, obligations for electrical and electronic equipment (WEEE) as well as batteries are also widespread in Europe. These obligations generally apply mainly to online merchants, who must submit detailed declarations for their household packaging that is placed on the market, as well as for certain types of products such as WEEE or batteries.

France: pioneer in the field of EPR
In addition to the obligations for packaging, WEEE and batteries mentioned above, other sectors are subject to extended producer responsibility in France, such as textiles, graphic paper and furniture and furniture elements. France currently has 12 EPR fields and is thus among the countries with the largest number of product categories that can be subject to extended producer responsibility. France will certainly remain at the top of this list in the future, as the law against waste and for a circular economy (AGEC law), introduced in 2020, foresees that additional areas will be covered.

New EPR obligations from 2022 onwards
This year, three new EPR schemes have been introduced for toys, sports equipment and gardening and DIY products. In practice, this means that from this year on, companies must declare toys, sports equipment and gardening and DIY products in France, as they already do for household packaging.
To be able to sell these products on the French market in compliance with the legislation, it is now possible to join one of the collective compliance schemes concerned.

Who is concerned by the take-back obligation?
For these three new EPR fields, foreign companies are only required to join an authorised compliance scheme and to take back and dispose of their products placed on the French market in the case of direct sales to French households, for example via e-commerce. In the case of delivery to French distributors or traders, it is generally the French distributors or retailers who are obliged to join a compliance scheme and to ensure the take-back and disposal of the products placed on the market.

Which compliance schemes have been approved?
The compliance schemes that have been approved for the new EPR fields are already responsible for some existing EPR fields. For example, the compliance scheme Eco-mobilier, already approved for the furniture and furniture elements, has also been approved for the toys and gardening and DIY products. EcoLogic, the approved compliance scheme for the WEEE, has just obtained approval for the sports articles as well as for the gardening and DIY products. The EcoDDS compliance scheme is now approved for the gardening and DIY products, in addition to household waste of chemical products.

Which products are concerned?
Toys include products such as board games, outdoor games, or stuffed toys. Sporting and leisure goods include products such as bicycles, fishing equipment or skis. Gardening and DIY items include products such as toolboxes, raised bed garden or lawnmowers.
Products that are already subject to another EPR field in France or that are exclusively used by professionals are excluded. For example, a car toy with an integrated electronic component falls within the scope of WEEE.

Your business is concerned, what to do next?
The Environmental Department of the Franco-German Chamber of Commerce and Industry (FGCCI)
has a wide range of expertise in the field of extended producer responsibility. As a neutral partner, it supports companies in fulfilling their obligations in France and offers a comprehensive range of services on a European scale in waste management, including packaging, WEEE and batteries.

The FGCCI is also at your side as a partner for EPR compliance and to support you for the new reporting obligations regarding the new EPR fields. We are happy to take care of the administrative part: centralise the reporting procedures and let the FGCCI be your single point of contact for EPR obligations in France!

If you need further information on the new reporting procedures, you can have a look at our detailed brochure on the EPR reporting procedures specific to France.

This brochure can be ordered here free of charge.

If you sell toys, sports and leisure goods or gardening and DIY products in France, you may be affected by one of the new reporting requirements.
Not sure if you are affected by the new reporting obligation? Then our Compliance Check is made for you! Book a one-hour consultation with us by clicking on the following link and we will tell you whether you have a take-back obligation in France:

EPR France - Compliance Check