✅ Who is in scope?

You are usually impacted if you manufacture, brand, import, distribute, or sell (including e-commerce/marketplaces) products to customers in France, especially when products fall under a REP (EPR) stream.

What you must comply with (AGEC essentials)

1) ♻️ REP/EPR: register, finance, declare (by REP stream)

If your products (and often their packaging) are in a REP stream, you must be properly registered and meet declaration/financing obligations—commonly via an approved eco-organism. The key compliance proof is the IDU.

IDU (Identifiant Unique): mandatory proof of REP registration

• The IDU proves you are registered in SYDEREP for a REP stream.
• One IDU is delivered per REP stream; companies can have multiple IDUs if they are in multiple streams.

What to implement

• 🧾 Map your product portfolio to REP streams (including packaging where applicable).
• 🤝 Join the correct eco-organism(s) per stream/category.
• 🆔 Capture and govern IDU(s) per legal entity and per stream.
• 📤 Build a reporting process: data owner → validation → submission → evidence retention.

2) 🏷️ Triman + Info-tri: mandatory consumer sorting information

France requires the Triman logo and sorting instructions (Info-tri) for many in-scope products/packaging, with practical placement rules and exceptions described in official guidance.

What to implement

• 🧩 SKU-level labeling rules (where Triman/Info-tri must appear: product, packaging, or accompanying documents depending on case).
• 🎨 Artwork governance: versions, approvals, effective dates, and country variants.
• 🧾 Proof pack: final artwork files + decision log showing which rule was applied.

3) 🌿 Article 13 / L541-9-1: “environmental qualities & characteristics” information (QCE)

AGEC requires digital consumer information on specified environmental qualities/characteristics for certain product categories, implemented through Decree 2022-748 and updated government FAQs.

What compliant companies do

• 📌 Determine applicability (product categories + any thresholds/conditions in the FAQ).
• 📄 Publish a controlled “fiche produit” (product information sheet) per SKU/family with required fields.
• ✅ Keep calculations and substantiation (supplier declarations, certificates, test reports) linked to each published statement.
• 🔁 Operate change control (supplier/material changes, packaging redesigns, updated recyclability).

4) 🚫 Environmental & plastic claims: control wording + keep substantiation

France restricts certain “green” wording on plastic products/packaging. For example, plastic items generally cannot carry claims like “biodégradable” or equivalent; “compostable” is restricted, and compostable plastics may require the statement “Ne pas jeter dans la nature”.

What to implement

• 🧪 Claims substantiation file (tests/standards/certificates/methods).
• 🧾 Mandatory pre-approval workflow for packaging text and product pages.
• 🔎 Periodic audit of live product pages and artwork libraries.

5) 🧴 Plastic packaging trajectory (“3R” objectives): reduction, reuse, recycling

The “Décret 3R” (Decree 2021-517) sets objectives for single-use plastic packaging for the 2021–2025 period.

What to implement

• 📦 Packaging BOM down to component + weight + material.
• 🔄 A packaging roadmap (reduction, reuse/refill, substitution, recyclability design).
• 📊 KPI tracking aligned to the 3R objectives + documented decisions.

6) 🚚 Unsold new non-food products: ban on destruction + valorisation pathways

AGEC’s rules culminate in full application from 1 January 2024: unsold new non-food products must be directed to donation, reuse, or recycling rather than destruction.

What to implement

• 🧾 “Unsold goods” SOP (decision tree: donation → reuse → recycling; exceptions documented).
• 🤝 Contracts with charities/reuse operators/recyclers.
• 🗂️ Traceability: quantities, dates, destination proofs, and partner receipts.

7) 🛠️ Repairability & durability indices (when you sell covered EEE)

France requires display of repairability for certain EEE and is rolling out a regulated durability index with defined display and calculation rules (e.g., via Decree 2024-316 and related orders).

What to implement

• ✅ Confirm whether your EEE categories are in scope and which index applies.
• 🧮 Controlled calculation + evidence set per model.
• 🛒 Publish the score and make the details available as required (including online sales).

Company compliance checklist (operational, not theoretical)

Phase 1 — Scope & ownership

• ✅ Product/SKU list for France + legal entity roles (manufacturer/importer/marketplace).
• ✅ REP stream mapping + IDU needs per stream.

Phase 2 — Data model & evidence

• 📦 Packaging BOM (component/material/weight).
• 🌿 Article 13 fields (QCE) + source-of-truth per field (supplier/test/cert).
• 🗃️ Evidence retention rules and naming conventions.

Phase 3 — Reporting & controls

• 📤 REP declarations workflow (ownership, approvals, submission cadence, proof).
• 🏷️ Artwork governance for Triman/Info-tri (versions, effective dates).

Phase 4 — Claims + unsold goods compliance

• 🚫 Claims approval gate + substantiation library.
• 🚚 Unsold goods SOP + destination traceability from 1 Jan 2024.

What this service delivers

• 🧭 AGEC applicability assessment (REP streams, labeling, Article 13/QCE, claims, unsold goods)
• 🆔 IDU readiness pack (per stream) + controls for “no IDU, no launch” governance
• 🏷️ Triman/Info-tri labeling rulebook + artwork approval workflow
• 🌿 Article 13 “fiche produit” template + field mapping + evidence checklist
• 🚫 Claims governance checklist aligned to French restrictions and substantiation expectations
• 🚚 Unsold goods SOP + traceability template

⭐ Why ComplyMarket

ComplyMarket is a great and exceptional partner for AGEC compliance because its Material Compliance Management & Reporting Platform centralizes product, packaging, labeling, and evidence workflows—so AGEC becomes repeatable, provable, and scalable.

How ComplyMarket supports compliance with France AGEC Law

• 🧾 Single source of truth for product + packaging BOM, weights, materials, and required attributes
• ♻️ REP/EPR reporting readiness with standardized data capture, validation rules, and audit trail
• 🏷️ Labeling & claims governance for Triman/Info-tri rollouts, artwork version control, and claim approvals
• 🌿 Article 13/QCE structured data linked to evidence (supplier declarations, certificates, calculations) to publish consistent product sheets
• 🚚 Unsold goods traceability with stored proof (donation/reuse/recycling) for inspections
• 🔐 Inspection-ready evidence via role-based approvals, time-stamped changes, and controlled outputs