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Is my product a construction product (PMCB) in France, and is it category 1 or 2?

Article R.

Last updated 6 November 2026Sources linked below
Quick answer

Article R. 543-289 of the Environmental Code defines construction products as products and materials, including wall, floor and ceiling coverings, intended to be permanently incorporated, installed or assembled in a building or used for its fittings on its plot, including parking, except those used only for the duration of the works. The 2023 scope notice (JO of 17 June 2023) splits them into category 1, mainly mineral products without glass, mineral wool or plaster, and category 2, all other products. The category decides which eco-organismes can take you.

Category 1: mineral products

  • 1.a Concrete and mortar: cement, aggregates, admixtures, precast and aerated concrete, mineral mortars
  • 1.b Lime
  • 1.c Stone: limestone, granite, sandstone, lava, reconstituted stone
  • 1.d Fired or raw clay: bricks, roof tiles, terracotta, flues
  • 1.e Slate
  • 1.f Bituminous mixes (asphalt), not bituminous membranes
  • 1.g Aggregates
  • 1.h Ceramics: baths, shower trays, washbasins, WCs, bidets, wall, floor and ceiling coverings
  • 1.i Other mineral products Journal officiel

Eco-organismes: Ecominéro, Valobat. ADEME

Category 2: all other products

  • 2.a Metal
  • 2.b Wood
  • 2.c Mortars, renders, paints, varnishes, resins and application products, container included, other than hazardous chemicals ADEME
  • 2.d Joinery with glass: windows, doors, verandas, curtain walls, flat glass
  • 2.e Plaster
  • 2.f Plastic: pipes, membranes, cladding, insulation boards, soft floors
  • 2.g Bitumen products: membranes, shingles, primers
  • 2.h Glass wool
  • 2.i Rock wool
  • 2.j Plant, animal and other: linoleum, carpet, wood fibre, cork, hemp, cellulose, cellular glass Journal officiel

Eco-organismes: Ecomaison, Valdelia, Valobat. ADEME

What is excluded

Pages by type of producer

Mixed products

Classify by the main material, as the scales do: lines read “over 95% metal”, “over 50% plastic”, and so on. A product mostly mineral but with glass, mineral wool or plaster is category 2. Valobat also has lines for the share of each material in composite products such as sandwich panels. Journal officiel

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 a product sold to DIY customers a construction product?

If it is meant to be permanently installed in a building, yes, whoever buys it. Some products sold to the public fall in the DIY and garden stream instead; the scope notice settles the boundary. ADEME

Is a heat pump a construction product?

No. Electrical and electronic equipment is a separate stream, and products in another stream are excluded from PMCB. ADEME

Since when does this apply?

The stream has been operational since 2023 (Valobat started on 1 May 2023), under décret n° 2021-1941 of 31 December 2021 and the cahier des charges of 10 June 2022, amended in 2023 and 2024. 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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