Toys EPR France: What companies need to know

Toys EPR France? The toy EPR (Extended Producer Responsibility) in France is a crucial part of the French circular economy law. Companies that place toys on the French market need to familiarize themselves with the specific EPR obligations for this waste stream. In this article, we provide an overview of the legal framework, registration obligations and future challenges.

Toys EPR France: Legal framework

The EPR for toys was introduced by the Act on Combating Waste and Promoting the Circular Economy of February 10, 2020. The aim is to promote the collection, reuse and recycling of toys through the polluter-pays principle. Companies that market toys in France for the first time are obliged to pay a fee (“eco-fee”). The Ecomaison organization is responsible for coordinating and monitoring compliance with the regulations.

Toys EPR France: Who is obliged to register?

Marketers who place toys on the French market for the first time must register with Ecomaison. Marketers within the meaning of the EPR regulations are manufacturers, importers or companies that sell toys under their own brand. Also included are retailers who sell toys via online marketplaces and foreign companies that supply French end customers directly.

Further information on EPR guidelines for online trading and online marketplaces can be found here.

Which toys are covered by the EPR scheme in France?

1. Toys as defined in Article 2 of Decree No. 2010-166 of February 22, 2010, which are designed or intended exclusively or also for the purpose of play by children under 14 years of age. This includes:

Outdoor games
Indoor games (dolls, soft toys, construction games, action games, etc.)
Board games and puzzles (less than 500 pieces)
Gift toys (e.g. toys distributed free of charge to consumers as part of the sale of another product, such as a children’s meal or magazine).

2. Also included are models, puzzles (more than 500 pieces) and board games for children aged 14 and over which, although outside the scope of Decree No. 2010-166, are nevertheless part of EPR requirements for toys.

A non-exhaustive list of products can be found on the Ecomaison website.

Attention: Some products are explicitly excluded in this guide by Ecomaison on pages 8-9.

Important for sellers of electronic toys

In addition to the Toy EPR, sellers of electronic toys must also comply with the specific regulations for electrical and electronic equipment (WEEE – Waste Electrical and Electronic Equipment). In France, electrical toys are not only subject to registration with Ecomaison, but also to extended producer responsibility for electrical equipment, which is managed by the ecosystem organization.

Companies that sell battery-powered or electronic toys must therefore also register with ecosystem, submit quantity declarations and pay a separate environmental levy. Furthermore, special requirements apply to the disposal and recycling of old appliances, including the take-back obligation for certain sales models. Companies can find more details on the WEEE requirements in France on the ecosystem website.

What about the packaging of toys?

In addition to the toys themselves, their packaging is also subject to extended producer responsibility (EPR). In France – and throughout Europe – specific registration obligations and recycling fees apply to household packaging.

Companies that sell toys in packaging to end customers must therefore also register for the packaging EPR and pay the corresponding license fees.

In France, packaging registration is carried out by organizations such as CITEO, while other EU countries have their own systems. Online retailers selling to multiple European countries must ensure that they meet the relevant EPR requirements for packaging in each country.

The EPR regulations in Europe are complex, but with our digital advisory service you can stay on top of things. We help you to fulfill your obligations in all relevant markets in a simple and legally compliant way.

Toys EPR France: fulfill requirements

To meet the legal requirements, companies must:

Register with Ecomaison and sign a service contract
Declare the quantity and type of toys marketed on a quarterly or annual basis
Pay the corresponding eco-fee

Toys must be correctly coded in order to calculate the appropriate eco-fee. This is done using an 11-digit coding system that takes into account material, weight and product type. Further information on the codes used and current prices can be obtained from Ecomaison.

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Future prospects and challenges

The toy EPR in France is constantly evolving to promote a sustainable circular economy. The challenge for companies is to keep pace with regulatory changes while integrating environmentally friendly solutions.

Future topics such as promoting toy donations, optimizing in-store recycling and improving the recyclability of materials are becoming increasingly important and will have a positive impact on the eco-fee to be paid.

Conclusion

The Toy EPR in France is a key step towards a sustainable future. Companies operating in this sector should see the legal requirements not only as an obligation, but also as an opportunity to promote environmental awareness and innovation.

We will be happy to support you in complying with your EPR obligations. Simply contact us free of charge!