Which French EPR Schemes Apply? A SKU Decision Guide

Export the active French catalogue with a stable SKU, EAN or internal product identifier. For each line, record the product's function, materials, electrical characteristics, battery, dimensions, intended user, professional or household use, brand owner, supplier, packaging and French sales route. Keep the technical file or product sheet that supports those facts.

Break kits and bundles into their constituent items. A rechargeable device, replacement battery, charger, textile pouch and printed sales box may not share one EPR classification or one producer. Accessories, refills and packaging added by the seller require their own analysis.

Our French producer registration and UIN service starts with this catalogue map, because a registration unsupported by product facts is difficult to maintain when a marketplace, eco-organisation or authority asks what it covers.

First identify the marketed item and its principal function. Second isolate included batteries, electrical parts, consumables and packaging. Third determine whether the product is intended for households, professionals or both. Fourth identify the manufacturer, importer, own-brand seller, distance seller and any upstream French supplier. Fifth compare the evidence with the current ADEME page, legal definition, exclusions and operational nomenclature for each candidate scheme.

Do not treat an unknown as exempt. Record the unresolved fact, the evidence owner and the date for decision. Product scope and producer status are separate questions: a product may be covered while the assessed seller is not the producer for that particular stream, or the reverse may be true after the seller changes packaging or assembles a bundle.

The table is a starting screen, not a final classification. Each row assumes a sale into France and must still be tested against the exact product facts, producer entity and current scheme rules.

ADEME's current scheme directory displays 19 accredited EPR schemes in force. This operational directory should not be confused with every category named in Article L541-10-1 of the Environmental Code: the statutory list and the accredited scheme directory are not identical snapshots. Use the current scheme page for operational scope and the law for the legal framework.

The word toy does not always lead to the Toys stream. ADEME's Toys page excludes products that fall within the EEE stream. Its Sports and Leisure page also excludes EEE and toys intended for children under 14, while the DIY and Garden page excludes EEE. A rechargeable electric toy is therefore screened as EEE, battery and packaging; it is not automatically declared again as a toy.

Use the same discipline for an electric garden tool, connected sports equipment or a battery-powered leisure product. Determine which definition governs the product, retain the exclusion evidence and only then assess components and packaging. Do not use multiple registrations as a substitute for classification.

ADEME explains that producer status can attach to a manufacturer, importer or own-brand distributor that first places covered products on the French market. For online sales, the legal entity and supply route matter. A marketplace may face a fallback responsibility where a third-party seller has not complied, but that does not make the seller's own analysis optional.

Match upstream evidence to the exact supplier entity, scheme and product range. A supplier's IDU for batteries does not prove that the seller's added packaging is covered; an IDU displayed on an invoice does not prove that it belongs to the entity or products in the catalogue. If the responsible producer is not established in France, review the current written French-representative route after scope and producer status are settled.

Create one component row for each separately covered element. Record whether the element is manufactured, imported, bought from a French supplier or added during fulfilment. A bundle assembled by the seller can change the result because the seller may introduce an accessory, battery or packaging that the upstream supplier never placed on the French market.

For batteries incorporated into EEE or vehicles, ADEME's battery page still includes the battery in its scheme scope. Keep the battery specification and quantity even when the customer cannot remove it. Separately record the equipment and the packaging, and reconcile each future declaration back to the same component map.

Household packaging covers packaging of products consumed or used by households, including consumption at and away from home, under the merged household-packaging and graphic-paper scheme. Record every packaging layer and whether it reaches the household waste stream rather than assuming that a B2B invoice makes the pack professional.

Professional packaging is in transition. The restaurant-professional packaging segment is already operational. On 11 August 2026, the Ministry's current announcement states that broader professional-packaging implementation will be operational from 1 January 2027, after the previously planned July 2026 launch was deferred. Flag these SKUs for dated review instead of applying a timeless rule.

Use one row per SKU, component, legal entity and candidate scheme. Include the scheme, product family, conclusion, producer entity, supplier evidence, packaging route, source page, reviewer, open question and review date. Link the exact technical and contractual evidence rather than writing covered or exempt without a reason.

Set change triggers for a new supplier, modified product, battery, packaging, brand owner, importer, sales channel, customer type or legal entity. Only after the scope map is approved should the business join the appropriate eco-organisation or individual system, obtain one IDU for each relevant scheme and set its declaration calendar. ADEME confirms that a producer needs as many IDUs as relevant schemes.

A company outside France imports a rechargeable electric toy and sells it directly to French consumers. The toy contains an incorporated battery and arrives in a printed retail box. A supplier document displays one identifier but does not name the French market placer or all relevant schemes.

The product's electrical function brings the main item into the EEE screen. ADEME's Toys page excludes EEE, so the same main item should not be added to Toys merely because it is sold as a toy. The incorporated battery is screened under Batteries, and the retail box under household packaging. The seller must then establish the producer for each of those three elements and validate any upstream evidence against the exact entity, scheme and product range.

The resulting register records EEE, Batteries and household packaging as candidate obligations, documents the Toys exclusion and keeps any representative or eco-organisation step separate. This is an illustrative classification method, not a client case or a conclusion for every electric toy.

Complete this control before using an IDU in a listing or opening declarations. Add the exact nomenclature and evidence requested by the selected eco-organisation.