France's new EPR for toys Regulation
Over the past few years, France has been adding to its existing list of extended producer responsibility (EPR) regulations and one of the more recent additions is the introduction of EPR for toys.
France’s toys sector
France’s toy recycling sector was formed as a result of its Anti-Waste Law for a Circular Economy (AGEC), which came into force on 20 February 2020.
What products are in scope?
Toy products in scope of this new regulation were determined by Decree No. 2021-1213, which was implemented on 22 November 2021. The Decree deems toys (as defined in article 2 of decree no. 2010-166 on 22 February 2010), models, puzzles, and board games as within scope, including the following:
- Outdoor games (sports toys, ride-on toys, summer toys, toy tricycles, etc.)
- Indoor games (dolls, stuffed animals, construction toys, action games, etc.)
- Board games and puzzles with fewer than 500 pieces
- Gift toys
In order for the above products to fall into scope they must be designed for, or intended to be used by, children under the age of 14. However, models and puzzles containing more than 500 pieces, as well as board games intended for children 14 years or over, although falling outside the scope of the Decree, are still required to be reported to the relevant compliance scheme.
Some products are exempt from this EPR regulation, including writing and drawing articles, such as markers, brushes, and paints, all of which do not need to be declared. In addition, products like children’s furniture or toys classified as electrical or electronic equipment (EEE) are also exempt as these fall into scope of other French EPR regulations.
Who is obligated?
Companies that are obligated under this regulation include manufacturers and industrial producers as well as importers of in-scope toys that place these products onto the market for the first time and have a physical presence in France.
This EPR regulation also requires those businesses that distance sell to French end-users from overseas to comply.
Penalties for non-compliance
Companies guilty of violating their obligations under this Decree may face monetary fines of up to €15,000.
Valpak International Compliance Services
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