Construction products and their packaging can sit in different streams. The 2023 scope notice counts the container of family 2.c products (mortars, renders, paints, varnishes, resins, adhesives) as part of the construction product. ADEME's guide to the household/professional packaging split tells producers to check first whether their packaging belongs to the building stream, and to contact that stream if so. Packaging that does not, such as pallets, stretch film, sacks and big bags, falls under professional packaging (EPRO, operational from 1 January 2027), or under household packaging when it reaches consumers.Sources (6)
Ministère de la Transition éMinistère de la Transition écologique — Produits et matériaux de construction du secteur du bâtiment (PMCB), page mise à jour le 24 novembre 2025Journal officielJournal officiel — Avis relatif au champ d'application de la filière REP PMCB, JO du 17 juin 2023 (NOR TREP2315866V)
LégifranceLégifrance — article L. 541-10-9-1 of the Environmental Code (full text)
ADEMEADEME — household or professional packaging: how to tell
TwiiceTwiice — REP emballages professionnels, secteur Bâtiment (offre avec Valobat)EcominéroEcominéro — Emballages professionnels (EPRO)
The three cases
| Packaging | Stream | Where to declare |
|---|---|---|
| Bucket, sack or cartridge of a family 2.c product (mortar, render, paint, adhesive) | Construction products | Your PMCB eco-organisme, with the product |
| Pallets, stretch film, big bags, sacks of other products sold to professionals | Professional packaging (EPRO), from 1 Jan 2027 | An EPRO eco-organisme |
| Packaging reaching consumers (DIY store products, online orders to private buyers) ADEME | Household packaging | Citeo, Léko or Adelphe |
What the building eco-organismes offer
Valobat runs an EPRO offer for the building sector with Twiice, aimed at sacks, big bags and buckets. Ecominéro also tells its members about the EPRO stream. If your PMCB scheme offers EPRO, one contact for both is simpler; compare its rates with the other EPRO schemes first: see EPRO eco-organismes compared. Sources (2)TwiiceTwiice — REP emballages professionnels, secteur Bâtiment (offre avec Valobat)ADEMEADEME — household or professional packaging: how to tell
How a representative saves you money here
- Making sure family 2.c containers are declared once, with the product, not again as packaging. Journal officiel
- Splitting packaging between EPRO and household packaging correctly: see the EMPAP/EPRO test. ADEME
- Comparing the EPRO schemes; under 10 tonnes of packaging, Plus Pro covers PMCB and EPRO in one mandate. 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
Are wooden pallets construction products?
No. Pallets are packaging, in the professional packaging stream. ADEME
Is the sack of cement declared with the cement?
Check with your eco-organisme: ADEME's guide says to check the building stream first. Family 2.c containers are explicitly part of the product; cement is family 1.a. ADEME
When does EPRO start?
Operationally on 1 January 2027.
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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