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Bitumen membrane and waterproofing producer selling to France: category 1 or 2?

Bituminous waterproofing membranes, underlays, shingles and primers are category 2 construction products (family 2.g), so the producer pays Valobat, Ecomaison or Valdelia.

Last updated 6 November 2026Sources linked below
Quick answer

Bituminous waterproofing membranes, underlays, shingles and primers are category 2 construction products (family 2.g), so the producer pays Valobat, Ecomaison or Valdelia. The scope notice is explicit that bituminous mixes such as asphalt are category 1 (family 1.f) but bituminous membranes are not. On the published scales membranes cost €46.95 a tonne at Valobat, €54.00 at Ecomaison and €80.00 at Valdelia. Synthetic (PVC, TPO, EPDM) membranes are plastic products, family 2.f, with higher rates.

The rates, side by side

Eco-organismeProduct line (code)Eco-contribution excl. VATRate applies from
ValobatWaterproofing membrane and bituminous underlay (020500500)€46.95 / tonne1 Jul 2026 Valobat
ValobatBituminous sheets (020500700)€46.95 / tonne1 Jul 2026 Valobat
ValobatBitumen shingles (020100200)€46.95 / tonne1 Jul 2026 Valobat
ValobatWaterproofing membrane and synthetic underlay (020500400)€99.76 / tonne1 Jul 2026 Valobat
ValobatBituminous asphalt for waterproofing (120400200)€0.84 / tonne1 Jul 2026 Valobat
EcomaisonWaterproofing and insulation: Bituminous membranes€54.00 / tonne1 Jul 2026 Ecomaison
ValdeliaBitumen > 95%€80.00 / tonne1 Jan 2026 Valdelia
EcominéroBituminous mix€0.68 / tonne1 Aug 2026 Ecominéro

Worked example

Worked example: a roofing membrane producer sells 1,200 tonnes of bituminous membranes into France a year.

ProductEco-organismeCalculationEco-contribution a year
Bituminous membranesValobat1,200 tonnes × €46.95 Valobat€56,340
Bituminous membranesEcomaison1,200 tonnes × €54.00 Ecomaison€64,800
Bituminous membranesValdelia1,200 tonnes × €80.00 Valdelia€96,000

Valobat: €56,340. Ecomaison: €64,800. Valdelia: €96,000. Valobat's line is the lowest of the three for bituminous membranes on these scales.

Who is the producer

Under article R. 543-290 of the Environmental Code, the producer is whoever manufactures or has manufactured the product under its own name or brand for use in buildings in France, or imports it or first places it on the French market. The 2023 scope notice names three importers: a French site's client buying abroad, a contractor buying abroad to install, and a distributor buying abroad. Each of them pays “sauf si elles sont en mesure de prouver que l'exportateur a lui-même contribué”, unless they can prove the exporter already contributed. A foreign manufacturer that joins an eco-organisme itself, through a representative established in France (article L. 541-10-9-1, mandatory since 10 July 2026), takes that cost and paperwork off its French customers. Distributors increasingly ask for that proof.

How a representative saves you money here

What we need from you

  • Company name, registration and VAT numbers, and the person who signs
  • Your product list with the eco-organisme product code for each line (we map it with you) ADEME
  • Quantities placed on the French market per line, in the unit the line uses (tonne, m³, m², metre or unit), for the past year and an estimate for the coming one
  • Who your French customers are (distributors, contractors, end clients), to settle who is the producer for each flow

Price

Our fee. Construction products are quoted separately, because the work depends on the eco-organisme (Ecominéro takes monthly declarations, Valobat one a year) and on your tonnage. Plus Pro starts at €990 a year for up to 10 tonnes; above that we send a written quote. Setup is €0. Eco-contributions go to the eco-organisme at its published rate, with 0% markup. See pricing or the construction products service.

Frequently asked questions

Is mastic asphalt category 1?

Bituminous mixes are family 1.f. Valobat rates bituminous asphalt for waterproofing at €0.84 a tonne; Ecominéro bituminous mixes at €0.68. ADEME

Are EPDM or PVC membranes bitumen products?

No, they are plastic, family 2.f. Valobat's synthetic membrane line is €99.76 a tonne. ADEME

Do I declare membranes sold for bridges and roads?

Civil engineering outside buildings and their plots is not in the PMCB scope. ADEME

Razvan Toma
Written byRazvan Toma

Razvan Toma is the founder of EPR France Rep, a France-established authorised representative (mandataire) for producers with no French establishment. He has worked in waste management and recycling since 2009, running waste-separation programmes inside large B2B organisations in France for clients including Chanel, Microsoft, Decathlon, Pirelli, IKEA, Vinci, Capgemini and E.Leclerc.

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