
Since 1 January 2022, the "DIY and garden" EPR scheme (ABJ) requires manufacturers, importers and final distributors to fund the end-of-life of their products. Understanding when you are legally a "producer" under the AGEC law determines all the EPR steps you need to take.
This guide details the rules applicable to large retailers, brands and online sellers to help secure their compliance.
Reading time: ~10 min
The ABJ scheme stems from the AGEC law and applies to any DIY or garden product placed on the national market for the first time. It covers businesses that manufacture in France, import, assemble or introduce these items for the end user.

• Manufacturing in France
• Importing
• Assembly
• First placing on the national market
A distributor becomes a producer as soon as it sells an item under its own brand only or imports it directly.
Painting tools: rollers, brushes, sleeves…
Motorised petrol-powered machines and appliances: mowers, chainsaws, cultivators…
DIY equipment outside categories 1 and 2: hand tools, workbenches, toolboxes…
Products and equipment for garden maintenance and landscaping: wheelbarrows, watering cans, hand tools…
Hardware, masonry works, purely professional products and electrical equipment (covered by WEEE) are excluded.
The retailer is a producer when it sells under its own brand, imports directly or operates cross-border e-commerce. It must then register with a producer responsibility organisation (PRO), obtain an EPR unique identification number (UIN), declare the quantities it places on the market and fund waste take-back. When it resells products already covered, responsibility remains with the supplier, but the retailer must require proof of EPR registration.
Any manufacturer based in France or importer is a producer and must join an ABJ PRO, segment its catalogue, declare quantities periodically and comply with labelling requirements (recycled content, recyclability, hazardous substances). In private label contracts, the producer may become the distributor depending on the brand applied.
A foreign seller delivering to an end user in France is a producer. It registers, obtains a UIN, declares volumes and pays the eco-contribution. Non-compliance can result in fines of up to €100,000 and the delisting of offers.

As soon as an item carries only the distributor's brand, the distributor takes on the EPR obligations: contributions, labelling and traceability must then be managed by the retailer.
All producers must join one of the four approved PROs (or set up a validated individual system), fund collection, reuse and recycling, and meet the targets set for 2024 and 2027 (for example 25% collection for painting tools by 2027, 5% reuse for petrol-powered machines).
The decree of 22 September 2021 also requires environmental labelling stating the share of recycled materials, recyclability and any presence of substances of very high concern.
Map out own brands and imports, structure product data by ABJ category, require the EPR UIN from suppliers and organise in-store take-back.
Check the applicable scheme (ABJ or other), integrate fee scales into your ERP systems, adjust labelling and provide the EPR UIN to distributors.
Centralise the catalogue, automate contribution calculations, generate declarations and, if needed, delegate operational management to an authorised representative.
CompliancR, an authorised representative, automatically analyses catalogues, identifies the relevant EPR schemes, applies fee scales and prepares declarations. The platform provides a consolidated dashboard, a history of your submissions and regulatory alerts. More information: compliancr.io.
Yes, with logistical details specified by the PROs for each territory.
No, if the products are already covered by a registered producer, but the reseller must be able to prove it and take part in take-back when required.
No, they are governed by separate municipal orders.
Formal notices, fines of up to €100,000 and removal of offers from marketplaces.

Identifying when you become a producer, structuring your product data and complying with EPR requirements are now essential for DIY and garden businesses. Support from an expert such as CompliancR helps you manage these obligations with confidence and avoid penalties.