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Adhesives, mortars, renders, sealants and paints for building: PMCB or chemicals EPR?

Mortars, renders, paints, varnishes, resins, adhesives and sealants intended for buildings are category 2 construction products (family 2.c), container included, unless they are hazardous chemical products under article L. 541-10-1 7°, which go to the chemicals stream.

Last updated 6 November 2026Sources linked below
Quick answer

Mortars, renders, paints, varnishes, resins, adhesives and sealants intended for buildings are category 2 construction products (family 2.c), container included, unless they are hazardous chemical products under article L. 541-10-1 7°, which go to the chemicals stream. Pack size matters at Valobat: its building lines cover professional packs (powders over 25 kg, paints over 25 L or 30 kg); smaller DIY packs sit in the DIY and chemicals scales. On the published scales tile adhesive powder costs €4.40 a tonne at Valobat and €29.00 at Ecomaison; paint €123.61 at Valobat and €71.00 at Ecomaison.

Construction product or chemical product?

The 2023 scope notice puts in family 2.c the mortars, renders, paints, varnishes, resins and application products, “including their container”, other than the hazardous chemical products of article L. 541-10-1 7°. Those hazardous products (many solvent-based paints, some resins and treatments) are in the chemicals stream, with EcoDDS as its main eco-organisme. Mineral mortars and renders (cement or lime based) are category 1, family 1.a. So one manufacturer can have three streams: mineral mortars (category 1), water-based adhesives and paints (category 2) and hazardous products (chemicals). We sort your range product by product with the safety data sheets. Journal officiel

The rates, side by side

Eco-organismeProduct line (code)Eco-contribution excl. VATRate applies from
ValobatAdhesive (floor, wall and tiles) powder > 25 kg (100100200)€4.40 / tonne1 Jul 2026 Valobat
ValobatAdhesive (floor, wall and tiles) paste > 25kg; DIY water-based (>5kg), solvent-based (>1kg) or reactive (>0.5kg) (100100100) ADEME€110 / tonne1 Jul 2026 Valobat
ValobatOther sealants (cartridge > 0.31 L, other types of packaging > 5 kg) (100200100)€55.00 / tonne1 Jul 2026 Valobat
ValobatPaint, wood stain and varnish, packaging > 25L or > 30kg (100300100)€123.61 / tonne1 Jul 2026 Valobat
ValobatResin and foam, packaging other than sprays> 25L or > 30 kg (100500200)€44.00 / tonne1 Jul 2026 Valobat
ValobatOrganic exterior render (paste > 25kg) (010300500)€13.20 / tonne1 Jul 2026 Valobat
ValobatMortar and organic plaster (powders > 25kg) (010300400)€5.94 / tonne1 Jul 2026 Valobat
EcomaisonPaints, renders and mortars: Glues and adhesives€29.00 / tonne1 Jul 2026 Ecomaison
EcomaisonPaints, renders and mortars: Interior or exterior paints€71.00 / tonne1 Jul 2026 Ecomaison
EcomaisonPaints, renders and mortars: Sealants, joints and PU foams€13.00 / tonne1 Jul 2026 Ecomaison
EcomaisonPaints, renders and mortars: Powder renders > 25 kg€2.00 / tonne1 Jul 2026 Ecomaison
EcomaisonPaints, renders and mortars: Paste renders > 25 kg€5.00 / tonne1 Jul 2026 Ecomaison
ValdeliaMortar, render, paint, varnish, resin, repair and installation product€280 / tonne1 Jan 2026 Valdelia

Worked example

Worked example: a building chemicals maker sells 600 tonnes of tile adhesive in 25 kg+ sacks (powder) and 150 tonnes of facade paint in 30 kg+ packs into France. ADEME

ProductEco-organismeCalculationEco-contribution a year
Tile adhesive, powderValobat600 tonnes × €4.40 Valobat€2,640
Paint, > 25 L or 30 kgValobat150 tonnes × €123.61 Valobat€18,542
Tile adhesiveEcomaison600 tonnes × €29.00 Ecomaison€17,400
PaintEcomaison150 tonnes × €71.00 Ecomaison€10,650
Tile adhesiveValdelia600 tonnes × €280 Valdelia€168,000
PaintValdelia150 tonnes × €280 Valdelia€42,000

Valobat: €21,182. Ecomaison: €28,050. Valdelia: €210,000. Powders are cheap at Valobat; paint is cheaper at Ecomaison. A mixed range may favour one contract or a split.

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

  • Sorting the range between category 1, category 2 and chemicals before you join, so nothing is declared twice or on the dearest line. Journal officiel
  • Using pack-size lines correctly: powders over 25 kg have far lower rates than pastes at Valobat. ADEME
  • Choosing the scheme: €188,818 a year apart in the example.

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

Plus the safety data sheet of each product, to sort hazardous chemicals out of the construction declaration. ADEME

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 the paint bucket declared as packaging?

For family 2.c products the container is included in the construction product declaration under the scope notice.

Is cement-based tile adhesive category 1?

The scope notice puts mineral mortars in family 1.a and adhesives in family 2.c. Ecominéro has a line for ready-to-use mortars and binders; Valobat and Ecomaison rate tile adhesives on 2.c lines. We check the product composition with you.

Are small DIY packs of paint construction products?

Paints sold to consumers in small packs are usually in the chemicals or DIY streams. Valobat's building lines start above 25 L or 30 kg.

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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