Since January 1, 2022, theEPR DIY and Gardening” (ABJ)EPR Scheme has required manufacturers, importers, and end distributors to fund the end-of-life management of their products. Understanding when one is legally considered a “producer” under the AGEC Act determines the full scope of EPR obligations that must be fulfilled.

This guide outlines the rules applicable to large retailers, brands, and online sellers to ensure their compliance.

EPR and Gardening: What Are the Requirements for Retailers and Brands?

Reading time: ~10 min

Key reminders about the EPR and Gardening EPR

The Scheme stems from the AGEC Act and applies to any DIY or gardening product placed on the domestic market for the first time. It applies to entities that manufacture, import, assemble, or distribute these items in France for end users.

Who is considered a producer?

• Made in France

• Import

• Assembly

• First launch on the domestic market

A distributor becomes a manufacturer as soon as it sells a product under its own brand or imports it directly.

Affected products

Painting supplies: rollers, brushes, sleeves…

Gas-powered machinery and equipment: lawn mowers, chainsaws, rotary tillers…

DIY supplies not included in categories 1 and 2: hand tools, workbenches, toolboxes…

Products and equipment for garden maintenance and landscaping: wheelbarrows, watering cans, hand tools…

Hardware, masonry work, products intended solely for professional use, and electrical equipment (covered under the WEEE Directive) are excluded.

Who is affected by the EPR and Gardening EPR based on your role

General or specialty retail stores

A retailer is considered a producer when it sells under its own brand, imports directly, or engages in cross-border e-commerce. In such cases, it must register with an eco-organization, obtain a unique identifier, report its product placements on the market, and fund waste collection. When it resells products already covered by the system, responsibility remains with the supplier, but the retailer must require proof of EPR registration.

Brands, manufacturers, and importers

Any manufacturer or importer in France is considered a producer and must join an ABJ eco-organization, categorize its product catalog, periodically report quantities, and comply with labeling requirements (recycled materials, recyclability, hazardous substances). In private-label contracts, the producer may act as the distributor depending on the brand name used.

Marketplace sellers and cross-border e-commerce

A foreign seller supplying an end user in France is considered a producer. They must register, obtain an ID, report sales volumes, and pay the eco-contribution. Failure to comply may result in a fine of up to €100,000 and the removal of their listings.

Private labels and special cases

As soon as an item bears only the retailer’s brand, the retailer assumes responsibility for EPR contributions, labeling, and traceability must therefore be managed by the retailer.

Common Requirements for EPR and Gardening EPR

All manufacturers must join one of the four approved eco-organizations (or establish a validated individual system), fund collection, reuse, and recycling, and meet the targets set for 2024 and 2027 (for example, 25% collection rate for painters’ tools by 2027, 5% reuse for thermal machinery).

The decree of September 22, 2021, also requires environmental labeling that specifies the percentage of recycled materials, recyclability, and the possible presence of substances of very high concern.

Ensure compliance based on your role

Large retailers and brick-and-mortar chains

Map private-label and imported brands, organize product data by ABJ category, require EPR ID, and coordinate in-store returns.

Brands, manufacturers, and importers

Verify the Scheme (ABJ or other), incorporate the pricing schedules into the ERP systems, adjust the labeling, and provide the EPR identifier EPR distributors.

Online sellers and marketplaces

Centralize the catalog, automate the calculation of contributions, generate reports, and, if necessary, delegate operational management to an agent.

How CompliancR EPR and Gardening

CompliancR, a certified agent, automatically analyzes catalogs, identifies the EPR sectors, applies the fee schedules, and prepares the declarations. The platform provides a consolidated dashboard, a history of actions taken, and regulatory alerts. For more information: compliancr.io.

Quick FAQ on EPR and Gardening

Does the EPR apply to overseas territories?

Yes, with specific logistical arrangements set forth by the environmental agencies for each region.

Does this apply to a simple reseller?

No, if the products are already covered by a registered producer, but the producer must be able to prove it and participate in the buyback when required.

Do neighborhood noise regulations fall under the EPR

No, they are governed by separate municipal ordinances.

What are the risks of non-compliance?

Warnings, fines of up to €100,000, and removal of listings from marketplaces.

In summary

Identifying when you become a producer, structuring your product data, and complying with EPR requirements EPR now essential for players in the DIY and gardening sectors. CompliancR the support of an expert like CompliancR manage these obligations with confidence and avoid penalties.