Christmas 2026 is shaping up to be a pivotal moment for theEPR Scheme EPR : increased inspections, new European safety regulations, and stricter requirements from online marketplaces are forcing manufacturers, importers, and distributors to go beyond mere minimum compliance. These obligations now come on top of the future digital product passport and ambitious targets for collection, recycling, and reuse.

If you sell toys in the French market, it’s time to start preparing for the 2026 holiday season. This guide breaks down the key points of the EPR and outlines practical steps to ensure your end-of-year sales, particularly in e-commerce.

EPR : What Manufacturers and Distributors Need to Know for Christmas 2026.

Reading time: ~11 min 1. EPR : what’s really changing for manufacturers and distributors 2. Your EPR obligations to address before Christmas 2026 3. New toy safety rules to anticipate 4. How to practically prepare for Christmas 2026 5. EPR and e-commerce: support CompliancR 6. Frequently asked questions

EPR : What’s really changing for manufacturers and distributors

Who is affected?

Effective January 1, 2022 (AGEC Act, Decree 2021-1213), the EPR scheme EPR applies to all entities placing toys on the French market. This includes, in particular:

Manufacturers, importers, or assemblers

Distributors who purchase goods abroad and then resell them in France

Distributors selling under their own or exclusive brands

Les jouets concernés sont ceux destinés aux enfants de moins de 14 ans (décret 2010-166) : poupées, peluches, jeux de construction, puzzles < 500 pièces, jeux de société, etc. En revanche, les jouets électriques relèvent des DEEE, tandis que vélos, trottinettes ou skateboards relèvent de la filière articles de sport et de loisir.

For Christmas 2026, these requirements will directly affect your ability to sell in France and remain listed on marketplaces.

Your EPR obligations regarding EPR safety ahead of Christmas 2026

Registration and ADEME unique number

Registration in the national producer registry through an eco-organization (e.g., Ecomaison) provides you with a unique identification number that must be displayed in your terms and conditions and on online marketplaces. Without this registration, you risk administrative penalties and being delisted.

User fees and funding

Every toy placed on the market must be subject to an eco-fee that funds collection, recycling, and reuse. Nearly all operators are members of an eco-organization, as individual systems remain complex. The amount depends on the type of toy, the materials used, and sometimes the weight: manual management quickly becomes time-consuming.

Labeling and Hazardous Substances

If the concentration of a substance of very high concern exceeds 0.1%, REACH reporting is mandatory. This is in addition to toy labeling requirements and CE marking. The 2027 environmental targets (45% collection, 55% recycling, 9% reuse) already promote more sustainable and repairable toys.

New toy safety regulations to look out for

Digital Passport and Chemical Restrictions

A European regulation adopted in late 2025 introduces a digital passport for toys and tightens restrictions on certain substances (endocrine disruptors, PFAS, bisphenols). The first effects will be visible in mid-2026: it is best to avoid materials that are close to the thresholds starting now.

Risk analysis, CE marking, and in-line inspections

Directive 2026-192 amends Annex II of Directive 2009-48 EC: stricter chemical and physical requirements, comprehensive risk analysis, and robust technical documentation. Online sales are subject to stricter controls; studies from 2025 revealed non-compliance rates of up to 80% for certain toys. Platforms now require an EPR number EPR proof of compliance.

How to practically prepare for Christmas 2026

Priority 1: Categorize your products

• Toys covered by the Extended EPR Responsibility ( EPR

• Electric/electronic toys (WEEE)

• Bicycles, scooters, sports and recreational equipment

• Accessories or kits related to other fields

Accurate classification is essential before launching any campaign.

Priority 2: Securing your recordings

Get your unique EPR number EPR , verify consistency with other sectors (packaging, textiles, batteries, etc.), and update your terms and conditions and marketplace accounts. Retroactive declarations are still possible, but it’s best to get everything in order before an audit.

Priority 3: Ensuring the reliability of your product data

For each toy: category, rating scale, materials, weight (if applicable), and regulated substances. This data determines the calculation of fees and the future digital passport.

Priority 4: Automate multi-channel management

Manual compliance reporting becomes unsustainable for large product catalogs. Outsourcing compliance to a service provider like CompliancR comprehensive coverage and helps avoid fines of up to €100,000.

EPR and E-commerce: Support from CompliancR

Automatic catalog analysis

The AI-powered CompliancR platform recognizes references, applies the correct rates, and prepares your tax returns. No more need for complex spreadsheets. Read more: Automatic detection of EPR supply chains.

Centralized management of all your supply chains

A single dashboard tracks registrations, contributions, and reporting history for toys, packaging, WEEE, and batteries. This consolidation becomes strategic in light of the upcoming European packaging regulation.

Frequently Asked Questions

Do I need to be registered if I only sell on a marketplace?

Yes. You are considered a distributor, and the platforms now require your EPR credentials.

What are the consequences for a seller who fails to comply with regulations for Christmas 2026?

Fines of up to €100,000, retroactive corrections, delisting, and damage to reputation in the event of a product recall.

I am an international seller who ships to France. Does this apply to me?

Yes. The EPR regulations EPR apply as soon as you make toys available to French consumers. An authorized representative based in France simplifies compliance from a distance.

EPR thus becomes a strategic tool for gaining sustainable access to the French market. By centralizing your obligations and automating your reporting, CompliancR this regulatory requirement into a competitive advantage. Learn more: Extended Producer Responsibility or explore our solutions.