What is the French AGEC law and what are its objectives?

The AGEC Law, No. 2020-105 of 10 February 2020, is France's Anti-Waste and Circular Economy Law. The official text, available through Légifrance, introduces requirements covering product design, marketing and end-of-life management across several product categories.

The legislation addresses five main areas:

• Reducing single-use plastics: progressive restrictions and measures targeting specific disposable plastic products and packaging.

• Environmental information: requirements for communicating product characteristics and waste sorting instructions.

• Waste prevention: measures restricting the destruction of unsold goods and encouraging their reuse.

• Product durability: mechanisms designed to improve access to information on repairability and product lifespan.

• Producer responsibility: strengthening collection, recovery and waste management systems for products placed on the French market.

The AGEC Law also establishes the objective of ending the placing of single-use plastic packaging on the French market by 2040 through progressive measures. This objective does not represent an immediate ban on all plastic packaging.

Certain French packaging requirements must also be considered alongside the EU Packaging and Packaging Waste Regulation (PPWR), which introduces harmonised packaging requirements across the European Union.

The AGEC Law is already in force, but individual requirements follow different implementation schedules. Businesses must therefore assess the relevant provisions and implementing decrees to determine their specific obligations.

Which companies must comply with the AGEC law in France?

The AGEC Law applies to manufacturers, importers, distributors and other economic operators whose activities fall within the scope of its provisions.

Companies established outside France may also be subject to AGEC requirements when they place products on the French market and perform activities covered by the legislation.

Applicability depends primarily on the product category, the company's role in the supply chain and the requirements established by each provision.

For example, an international clothing manufacturer selling products in France must assess the environmental information obligations applicable to textiles. A cosmetics company distributing packaged products in France must also consider the relevant packaging requirements.

Some obligations apply broadly to specific categories of operators, while others establish revenue thresholds, minimum quantities of products placed on the market or specific exemptions.

Under Article 13, environmental information requirements concern new products intended for consumers, within the product categories defined by the implementing decree. Products intended exclusively for business-to-business transactions fall outside these specific information obligations, although other AGEC provisions may still apply.

For businesses selling through distributors or e-commerce platforms, identifying the economic operator responsible for each obligation is particularly important.

Contractual arrangements may help coordinate compliance activities, but the allocation of legal responsibilities must remain consistent with the applicable legislation.

A preliminary assessment should therefore begin with a complete inventory of products placed on the French market, connecting each item to its product category, responsible economic operator and applicable regulatory requirements.

AGEC law article 13: what environmental information is required?

Article 13 of the AGEC Law regulates the disclosure of environmental qualities and characteristics for certain categories of products.

Its requirements were incorporated into Article L. 541-9-1 of the French Environmental Code and further specified through Decree No. 2022-748 of 29 April 2022.

The decree establishes which environmental characteristics must be disclosed and defines the conditions under which this information should be communicated.

For affected companies and product categories, it requires an environmental product information sheet, formally referred to in French as the fiche produit relative aux qualités et caractéristiques environnementales.

The information must be made available free of charge in digital format, in accordance with the accessibility and reuse conditions established by the decree.

Mandatory environmental disclosures vary by product category. Companies are not required to report every environmental characteristic listed in the legislation for every product sold in France.

Recycled content, recyclability and other environmental characteristics

Article 13 covers several environmental characteristics relating to product composition, manufacturing and end-of-life management.

Recycled content refers to the proportion by mass of recycled materials incorporated into a product, calculated according to the criteria established by the legislation.

For relevant product categories, reporting this information requires reliable data on material composition and origin.

Article 13 regulates the disclosure of recycled content but does not establish a universal minimum recycled-content percentage applicable to all products.

Recyclability concerns the ability to recover materials through the recycling processes recognised under the French regulatory framework.

The information must follow specific criteria and cannot be based solely on the theoretical possibility of recycling a material.

Other environmental characteristics subject to disclosure requirements, depending on the product category, include:

• Hazardous substances: information on substances identified by the legislation under the applicable conditions.

• Geographical traceability: disclosure of the countries where certain manufacturing stages take place, particularly for specified textile and footwear products.

• Plastic microfibres: information required for certain textile products containing synthetic fibres.

• Precious metals and rare earth elements: disclosures applicable to specific categories of equipment covered by the legislation.

The regulatory framework also addresses particular information concerning compostability, reuse possibilities and environmental bonuses or penalties associated with relevant EPR schemes.

Environmental disclosures must comply with the definitions and calculation criteria established under French law.

A general supplier statement may be insufficient when it does not allow the company to verify the reported information or connect it to the specific product placed on the market.

For businesses managing hundreds of product references, preparing environmental information sheets requires linking product identifiers, material composition, supplier information and supporting technical documentation.

AGEC law article 13: implementation dates and thresholds

Decree No. 2022-748 introduced environmental information requirements progressively, using thresholds based on annual turnover from the relevant products placed on the French market and the number of units marketed.

The main implementation thresholds are:

Both thresholds must be met, and they concern the products covered by the relevant provisions and placed on the French market.

The decree also establishes specific rules and exceptions for certain product categories, which must be considered when assessing applicability.

Since 2025, the final phase of the schedule has applied to operators exceeding €10 million in annual turnover from relevant products and placing at least 10,000 units on the French market each year.

These thresholds relate specifically to the environmental information obligations established by the decree. They do not provide a general exemption from the entire AGEC Law.

Once applicability has been established, companies must identify the environmental characteristics required for each product category and prepare the corresponding disclosures.

The environmental information sheet must also remain accessible for the period required by the legislation, including after the last unit of the product has been placed on the market.

What other requirements does the French AGEC law introduce?

Article 13 represents one component of the French AGEC Law. Other provisions affect packaging management, product distribution and the responsibilities of economic operators throughout the product life cycle.

Triman and Info-tri Labelling

The Triman symbol identifies products subject to the relevant separate waste collection requirements, while Info-tri provides instructions on how to sort and dispose of different materials and components.

These requirements apply to numerous product categories covered by French Extended Producer Responsibility schemes, subject to specific conditions and exemptions.

Affected companies must verify which instructions apply to their products and coordinate this information with packaging design and labelling processes.

The Triman symbol does not constitute a certification of product recyclability.

Extended Producer Responsibility (EPR)

The AGEC Law strengthened France's Extended Producer Responsibility (EPR) framework, which assigns obligations to relevant economic operators concerning the management of waste generated by products placed on the market.

Depending on the product category, companies may be required to join an approved producer responsibility organisation, pay environmental contributions and report quantities placed on the French market.

These obligations require accurate information on product categories, material composition and sales volumes.

Single-use plastics, waste prevention and product durability

The legislation introduces progressive measures to restrict certain single-use products and packaging, prevent the destruction of unsold non-food goods and improve information on the repairability and durability of selected products.

For affected businesses, these provisions may require changes to material selection, product characteristics and procedures for handling unsold inventory.

For example, a manufacturer of durable goods may need to assess whether repairability or durability index requirements apply to its products.

A distributor of non-food goods must consider the restrictions governing the disposal of unsold inventory and the applicable provisions concerning reuse, donation or recycling.

Requirements must be assessed for each product category, as restrictions, disclosure obligations, implementation dates and exemptions do not necessarily follow the same rules.

How to prepare for AGEC law compliance: data and documentation

Managing AGEC Law compliance requires a structured process connecting regulatory obligations with reliable product information.

The first step is to map the products placed on the French market.

For each product, companies should record its identifier, product category, responsible economic operator and applicable regulatory provisions.

This classification makes it possible to distinguish products subject to Article 13 from those affected by other obligations, including Triman, Info-tri and Extended Producer Responsibility.

The next step involves collecting the necessary technical information.

For Article 13 environmental information sheets, relevant data may include material composition, recycled content and specific manufacturing stages.

This information may come from internal departments, component manufacturers and external suppliers.

A structured supplier assessment system can support the collection of technical information and supporting evidence, helping companies identify missing or inconsistent data.

Each environmental data point should be linked to the relevant product, its documentary source and the date of the latest update.

This allows companies to reconstruct the origin of reported information and respond when materials, suppliers or manufacturing processes change.

Once the necessary data have been collected, responsibility for verifying and publishing environmental information sheets should be assigned to specific internal functions.

For companies managing large product portfolios, a set of operational indicators can help measure progress:

• Percentage of products classified: the proportion of product references for which applicable AGEC obligations have been identified.

• Environmental information sheet completeness: the percentage of relevant products with all required information available.

• Missing supplier data: the number of outstanding data points needed to complete compliance documentation.

• Average update time: the time required to revise an environmental information sheet following a product change.

These indicators help companies identify priorities and monitor activities before relevant deadlines.

The French Ministry for Ecological Transition's official guidance provides a reference for environmental product information requirements and the conditions governing environmental claims.

Manual data management can become difficult when a company markets hundreds of products or coordinates information across multiple facilities and suppliers.

In these cases, centralising product data and supporting documentation can reduce duplicated work and improve the traceability of compliance activities.

Metrikflow is an ESG and Compliance software platform that helps businesses collect environmental data, manage documentation and coordinate information across departments and suppliers.

These capabilities can support the preparation and organisation of data needed for AGEC-related obligations. Companies must still assess the specific French requirements and ensure that published information complies with the applicable legal provisions.

Structured product data management helps companies monitor compliance activities, identify missing information and maintain verifiable documentation supporting regulatory requirements.