In France, in addition to packaging, WEEE (Waste Electrical and Electronic Equipment) and batteries, other product streams are also subject to Extended Producer Responsibility (EPR). Since 2022, this has also included the product stream for sports and leisure articles, known as "Articles de Sport et de Loisirs (ASL)".
Which articles are affected?
"Sports and leisure articles" covers all equipment used for sporting activities or outdoor leisure activities. This includes accessories and consumables. Affected articles include for example:
Cycling and mobility: bicycles, scooters, skateboards, roller skates, as well as tyres and spare parts
Water sports: diving equipment, fishing gear, surfboards, kayaks
Team sports: basketballs, footballs, handballs, rugby balls
Protective equipment: helmets, ropes, carabiners
Fitness and bodybuilding: fitness mats, dumbbells, non-electric strength equipment
Hunting and shooting sports: hunting equipment, sporting ammunition
Excluded are electrical and electronic products (e.g. e-bikes), non-sport-specific textiles, firearms, toys, professional equipment, and boats over 2.5 metres in length.
Legal framework
The legal basis for Extended Producer Responsibility for sports and leisure articles is anchored in the French Environmental Code, in particular Articles L. 541-10 and R. 543-330. These articles require manufacturers to organize and finance the disposal, reuse, and recycling of their products. The regulations are part of the Anti-Waste and Circular Economy Law (AGEC) introduced in 2020, which aims to minimize the environmental impact of products and promote the circular economy.
What obligations do I have as a manufacturer?
Registration in the national register
Annual declaration of the total quantities and weight of products placed on the market
Informing end users about disposal and recycling
Financing the collection and processing of equipment
Annual reporting on collection and processing to the authorities
What obligations do I have as a distributor?
Since 1 January 2023, retailers in France are required to take back used SLA equipment from their customers:
Sales area between 200 and 400 m² dedicated to SLA: obligation for 1:1 take-back.
Sales area > 400 m² dedicated to SLA: obligation for take-back without purchase requirement (1:0 take-back).
Distance selling with turnover of more than €100,000 from the sale of SLA: obligation for 1:1 take-back.
What are the consequences of non-compliance?
Failure to comply with the regulations can result in significant penalties. The AGEC legislation provides for fines of up to €70,000 per undeclared product.
Do you need support in fulfilling your obligations? Feel free to get in touch! Alternatively, you can fill out the enquiry form below and we will get back to you.
