Christmas 2026 will be decisive for the toys EPR scheme: increased checks, new European safety rules and stricter marketplace requirements are forcing manufacturers, importers and distributors to go beyond minimum compliance. These obligations now add to the future digital product passport and to ambitious collection, recycling and reuse targets.

If you place toys on the French market, preparation for the Christmas 2026 campaign starts now. This guide breaks down the key points of the toys EPR scheme and the practical steps to secure your year-end sales, particularly in e-commerce.

Toys EPR: what manufacturers and distributors need to know for Christmas 2026.

Reading time: ~11 min 1. Toys EPR: what really changes for manufacturers and distributors 2. Your toys EPR obligations to secure before Christmas 2026 3. New toy safety rules to anticipate 4. How to prepare concretely for Christmas 2026 5. Toys EPR and e-commerce: how CompliancR helps you 6. Frequently asked questions

Toys EPR: what really changes for manufacturers and distributors

Who is affected?

Since 1 January 2022 (the AGEC law, decree 2021-1213), the toys EPR scheme applies to any producer placing products on the French market. This includes in particular:

Manufacturers, importers or assemblers

Importers buying abroad and reselling in France

Distributors selling under their own or an exclusive brand

The toys concerned are those intended for children under 14 (decree 2010-166): dolls, plush toys, construction sets, puzzles with fewer than 500 pieces, board games, etc. Electric toys, however, fall under the WEEE scheme, while bicycles, scooters and skateboards fall under the sports and leisure equipment scheme.

For Christmas 2026, these obligations directly determine your ability to sell in France and to remain listed on marketplaces.

Your toys EPR obligations to secure before Christmas 2026

Registration and ADEME unique identification number

Registering with the national producer register through a producer responsibility organisation (PRO) (e.g. Ecomaison) issues an EPR unique identification number (UIN) that must be displayed in your terms and conditions and on marketplaces. Without this registration, you risk administrative penalties and delisting.

Eco-contribution and funding

Every toy placed on the market must carry an eco-contribution funding collection, recycling and reuse. Almost all operators join a PRO, as individual systems remain complex. The amount depends on the type of toy, the materials and sometimes the weight: manual management quickly becomes time-consuming.

Labelling and hazardous substances

Above 0.1% of a substance of very high concern, REACH information is mandatory. This is in addition to toy labelling requirements and CE marking. The 2027 environmental targets (45% collection, 55% recycling, 9% reuse) are already encouraging more durable and repairable toys.

New toy safety rules to anticipate for Christmas 2026

Digital passport and chemical restrictions

A European regulation adopted in late 2025 introduces the 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 close to the thresholds now.

Risk analysis, CE marking and online checks

Directive 2026-192 amends Annex II of Directive 2009/48/EC: stricter chemical and physical requirements, a comprehensive risk analysis and solid technical documentation. Online sales are subject to stricter checks; 2025 studies found up to 80% non-compliance for certain toys. Platforms now require your EPR number and proof of compliance.

How to prepare concretely for Christmas 2026

Priority 1: classify your products

• Toys covered by the toys EPR scheme

• Electric/electronic toys (WEEE)

• Bicycles, scooters, sports/leisure equipment

• Accessories or kits covered by other EPR schemes

Accurate classification is essential before any campaign.

Priority 2: secure your registrations

Obtain your toys EPR unique identification number, check consistency with other schemes (packaging, textiles, batteries, etc.) and update your terms and conditions and marketplace accounts. Retroactive declarations remain possible, but it is better to regularise before an inspection.

Priority 3: ensure reliable product data

For each toy: fee scale category, materials, weight if applicable, regulated substances. This data determines the contribution calculation and the future digital passport.

Priority 4: automate multi-scheme management

Manual declarations become unmanageable for large catalogues. Outsourcing compliance to an authorised representative like CompliancR secures the entire scope and avoids fines that can reach €100,000.

Toys EPR and e-commerce: how CompliancR helps you

Automatic catalogue analysis

The CompliancR platform, powered by AI, recognises your products, applies the correct fee scales and prepares your declarations. No more complex spreadsheets. Detailed article: automatic detection of EPR schemes.

Centralised management of all your schemes

A single dashboard tracks registrations, contributions and declaration history for toys, packaging, WEEE and batteries. This consolidation becomes strategic with 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 producer, and platforms now require your EPR identifiers.

What are the risks for a non-compliant seller at Christmas 2026?

Fines of up to €100,000, retroactive regularisations, delisting and reputational damage in case of a product recall.

I am a foreign seller delivering to France, does this apply to me?

Yes. The toys EPR scheme applies as soon as you make toys available to French consumers. An authorised representative based in France simplifies remote compliance.

The toys EPR scheme thus becomes a strategic lever for sustained access to the French market. By centralising your obligations and automating your declarations, CompliancR turns this regulatory requirement into a competitive advantage. To find out more: extended producer responsibility or discover our solutions.