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Frequently asked questions : Valobat members

Regulations, services, declaration, billing, scale, management your account... Find out here all the answers to the most the most frequently asked questions of Valobat's marketers and members.

 

Questions relating to to Valobat's members and to any marketer classified by headings

The membership contract

Valobat tells you everything about the process of joining the eco-organization and the principles of your membership contract.

Services

Discover the range of services offered by Valobat to help you accelerate circularity within your organizations

The eco-contribution scale

Calculation method, purpose, eco-modulations and potential changes to the scale are explained in this section.

The declaration

Procedures, deadlines, payments, invoicing... everything you need to know about declaring your marketings.

Billing

Valobat tells you all about the billing terms and conditions resulting from the application of your membership contract

Controls & audits

Valobat details all the regulatory obligations governing the control and audit phases of your declarations.

Regulations

The origins, applications and contours of EPR in the building industry are revealed in this section.

MyValobat space

From the creation of your account to the multiple services, discover your personal space MyValobat

 

Membership Agreement

Since its approval as an eco-organization for the PMCB sector, Valobat has been offering simple and dematerialized membership solutions.

By going to the Valobat website and clicking on "Join Valobat", it only takes a few minutes to comply with the regulations.

All marketers within the meaning of the EPR for the building industry is now obliged to join an eco-organization or to apply for approval of its own individual system.

The signatory of the membership contract will receive by email a signed copy of his membership contract, via our electronic signature tool Docusign.

When your membership is registered, you will receive an email from Valobat informing you of this.

Membership in Valobat is possible at any time of the year. The membership contract will take effect on January 1st of the year of signature. However, Valobat reminds that the membership contract allows the marketer to be in conformity with its obligations under the law and invites each company to regularize its situation by contracting with Valobat as soon as possible.

Any person with the legal capacity to commit his company can sign the membership contract with Valobat, which can nevertheless be initiated by a third party.

What are the powers of a proxy?

The principal (i.e. the issuer on the market subject to the law) may entrust its agent, who accepts it, with the mission of representing it and carrying out the following operations in its name and on its behalf, with Valobat, on the basis of the provisions of article L. 541-10-1 of the Environmental Code

- declare, before the contractual date of each year, the quantities of building products and materials placed on the market by him during the previous year;

- pay the amount of the eco-contribution for which the principal is liable, before the contractual date of each year, for the quantities of the previous year;

- provide any supporting documentation necessary to manage the reporting of PMCBs.

In this context, the agent of a marketer manages all the operations of membership, declaration, invoicing, payment and/or management of control operations. The agent therefore has the same authorizations for managing the EPR PMCB as the principal. These must be defined in a contract, the mandate, based on the information given in the Valobat standard membership contract.

With the exception of the year 2022, the contract is concluded for a fixed term from January 1 of the year of enrollment to December 31 of the same year. The contract will be renewed by tacit agreement for successive periods of 12 months each, unless terminated no later than 3 months before the expiration of the current period.

Valobat is an eco-organization created by and for the building industry. In addition to its representative and proactive action on circular economy issues, Valobat develops and will continue to to develop for you services to better accompany you in your compliance, to help you in your eco-design approach and to facilitate the administrative task. Finally, Valobat which will have probably a significant market share and consequently a capacity to produce economies of scale that will contribute to a very competitive eco-tax scale.

The membership to Valobat is possible fromince October 10, 2022.

 

Services to Valobat members

Valobat offers support to each company on the status of producer subject to EPR PMCB, what products are concerned, how to sign the membership contract, how to make the declaration and then the payment. A team of EPR and PMCB experts are available to answer your questions. They are supported by a call center to answer your questions and various online tools.

Valobat is also in charge of obtaining the unique identifier for its members from ADEME and of their declaration in the SYDEREP tool.

Valobat also accompanies its members on eco-design, through training, support and tools... The animation of the members' network, a Valobat club, the organization of meetings and various events are also among the services offered by Valobat. Satisfying all your needs is our priority.

For the smallest structures, whose turnover is less than 2 M€ per year per year, Valobat offers to marketers to to choose the alternative simplified regime by applying a percentage of this turnover.

Find the products concerned by the PMCB EPR through the search engine of our online scale. 

Our call center is also at your disposal: contact us by dialing 01 80 83 60 70, price of a local call. Our consultants are available from 8:30 am to 6:00 pm, Monday to Friday.

Valobat will be present on all the channels of waste collection. Déchèprofessional or public waste collection centers, distributors, collection on site and collection for certain sorted flows on the sites of the craftsmen

Within the framework of the deployment of the territorial network, Valobat will collect the waste on all the sites/channels:
- Building sites
- Public waste collection centres
- Private waste collection centres
- Craftsmen's sites
- Distributors' sites
Valobat will be present on all the types of waste and on all the collection channels

When it is not possible to take back the flows from separate collection, article D 543-281 opens up the possibility of joint collection, for example of metals, wood and plastic, reserving it, as provided for in article R.543-290-4, for local authorities, distributors, construction companies and building sites that do not have sufficient storage space, so that they can, if necessary, reduce the number of waste flows to be separated.

The PMCB EPR Decree stipulates that the take-back must be carried out in the immediate vicinity of the point of sale. In the absence of more precise indications from the public authorities, Valobat elaborates proposals within the Valobat Distributor Working Group.

Internal PMCB waste from sales outlets can be deposited in the skips provided as part of the take-back offer. They will benefit from the same take-back conditions as the sorted flows of the customers.

Subject to ambitious objectives of reuse rate fixed by the specifications, Valobat develops devices to promote the reuse of building products.

If you have a reuse project, let's talk about it and collaborate!

Valobat provides a communication kit allowing you to promote your commitment to your stakeholders. Find it in your member area.

Article R. 543-290-2 of the Environmental Code provides that construction products or materials used for civil engineering and public works are not included in the quantities to be declared. This provision has been integratede in the standard contract. The Valobat member does not have to declare them and must provide the traceability elements justifying the exempted quantities, in particular in case of requests for supporting documents from Valobat or one of the auditing firms, in accordance with the regulatory provisions.

An EPR operates on the principle of declaring what is placed on the market. Membership of an eco-organization necessarily implies the realization of this declaration and the payment of the invoices which result from it. Concerned about the inherent management burden for its members, Valobat has worked to minimize it as much as possible by proposing solutions among which a an easy to apply scale, requiring only one annual declaration (on the Valobat has an easy to apply scale, requiring only one annual declaration (on the previous year's marketings to have a basis for invoicing) and a quarterly invoice with a regulation if necessary at the beginning of the following year, following the the final declaration.

Like all eco-organizations, Valobat will devote the majority of its budget to operational expenses (collection, sorting, treatment costs, etc.) as well as to expenses imposed by the specifications (taking charge of part of the asbestos waste, financing the reduction of illegal dumping, etc.). The other expenses will be divided between the costs of structure, awareness, communication, study and R&D. 

In response to its specifications, Valobat's intervention is based on two modalities:
- Operational intervention entrusted by Valobat to waste management professionals for collection, sorting, transport, waste preparation and/or recycling operations. The modalities are based on contracts after open tenders.
- The financial intervention is proposed to the actors collecting separate flows of PMCB waste, provided that they comply with the rules of separate collection and joint collection and that they respect a list of basic criteria, including the criteria of massification, meshing and control of traceability, which are essential for the sector to achieve its objectives. The terms and conditions are based on standard agreements and financing scales based on reference costs.
The combination of these two approaches differs between collection and treatment and according to the categories of LBCPs.

Valobat has organized itself in co-construction with the marketers based on their needs.
Valobat has a strong shareholding with important companies, which know their products and their recycling well. Several of them have already built recycling channels.
The shareholding and the market share that Valobat aims at will allow the eco-organization to make economies of scale. The eco-contribution will therefore be competitive, fair and efficient.

In application of article L541-10-13 of the Environmental Code, all marketers subject to EPR must now register with Syderep in order to receive their unique identification number (IDU). The IDU is used to facilitate the monitoring and control of compliance with the obligations incumbent upon him: for each producer on the market, there are as many IDU numbers as there are channels for which he is registered. For Valobat's members, the registration will be done directly by Valobat which will provide its members with their IDU.
The IDU is valid for 1 year and renewed every year. It must appear on your GTC (General Sales Conditions), all contractual documents and your website.

It should be noted that there are no longer any asbestos producers on the market. In accordance with article 543-290-11, Valobat will only take charge of the cost of managing asbestos waste within the scope of the public waste management service (SPGD) with an adapted scale whose precise terms will be defined with the coordinating body. The amount associated with this collection will therefore be quite low.

 

Eco-contribution scale

The eco-contribution scale is the amount eco-contribution voted by the Board of Directors of Valobat for each product and material put on the market, subject to the PMCB EPR and expressed by unit (ton, m², m3, linear meter linear, sales unit...).

Valobat is an eco-organization approved by the public authorities and has a mission of general interest. Valobat only acts within the framework of the building sector and the eco-contributions it collects are only used to carry out services for this sector. The eco-tax is calculated in such a way as to cover the end of life of products and materials in compliance with regulatory objectives, which also include study, R&D and communication costs.

The eco-tax is calculated on the basis of the waste management business plan by material. These costs will then be broken down into the volume of products put on the market (added to the transversal costs) to determine the eco-tax for each product.

The scale ofeco-taxes may change once a year to better reflect the real costs of collection, treatment and recycling. This will be especially true during the first few years of approval, as the public authorities have decided to introduce a gradual increase in the sector's power.

The Valobat's scale is freely available on its website. Valobat has also developed a simulation tool foreco-contribution simulation tool allowing marketers and their agents to estimate the amount of their future eco-contribution based on the quantities of products and materials placed on the market. This simulator is accessible online.This simulator is available online.

The specifications stipulate that the bonuses and malus will apply for the 2024 market launch.

The eco-contribution (or eco-participation depending on the EPR sector) is not a tax: it is not collected by the State, which would set the amount. It is not paid to the public authorities but is managed by an eco-organization to finance the waste management operations of a given sector. It is a collective virtuous system that makes companies that put products on the market responsible for managing their end-of-life. It is nevertheless made compulsory by law for marketers who do not wish to manage individually the collection and treatment of their products.

Although they must comply with the same requirements, the calculation assumptions and methods for the eco-contributions of each eco-organization remain the responsibility of each. It is therefore perfectly normal to end up with different scales and/or units depending on the eco-organization.

 

Statement 

The eco-contribution scale applicable for each product or material is available on the Valobat website. To make his declaration, the member of Valobat indicates the quantity of products or materials according to the proposed unit, which allows to calculate immediately the global amount of the eco-tax.

Valobat has also developed an eco-contribution simulation tool allowing marketers and their agents to estimate the amount of their future eco-contribution based on the quantities of products and materials put on the market. This simulator is available online.

Valobat provides you with an online declaration tool for your marketings. This tool has been designed with our associates and pre-members to make this declaration as easy as possible.

The placing on the market realizing a turnovers below a threshold of 2 M€ per year can access à the simplified declaration by applying a percentage of this turnover.of this turnover.

Valobat is very attached to the "fair declaration" of its members so that their contribution to the functioning of the sector is equitable between all. To help in the control of the declarations, in a respect of the principle of the right to the error, some justifications will be asked to the members. Their formalism will be proposed following the discussions that Valobat will have with the public authorities.

The eco-contribution must be paid by the membermost often directly the sender on the market of the products or materials of of the building according to the definition of the decree of December 31, 2021 or by its agent.

The eco-contribution payable in year N is based on the declaration of products put on the market in year N-1. An adjustment takes place at the beginning of year N+1, following the the declaration ofs PMCB placed on the market ins placed on the market in year N.

If you don't have many product types to declare, we recommend that you enter the different declaration lines directly, using our search engine.

If the number of lines is important or if you have set up your information system with the Valobat product codes, it is in your interest to import the standard file provided by Valobat which integrates the codification and will make the declaration automatic.

You can edit your declaration as long as it does not appear to have been processed by our teams on your personal space. If this is the case, please contact our member service.

Valobat offers you the possibility to enter your declaration in several times. Save your declaration in order to finalize it later.

The declaration of the previous year's marketings must be registered before March 31 of the current year

 

Billing

Each year, in year N, the members will make a declaration to Valobat on the real quantities put on the market the year N-1. This declaration will be used to determine the amount due for the year N-1. It will also be used to evaluate the quarterly instalments for the year N which will be adjusted upwards or downwards during the declaration for the year N+1.

The declaration on the quantities placed on the market during the year 2022 to be made at the beginning of 2023 allows for the adjustment of the level of the quarterly installments of 2023 and not to invoice the quantities of 2022 since the products and materials placed on the market in 2022 are not subject to the EPR.

On the basis of the declaration of the year N concerning the PMCB of the year N-1, Valobat will send you 4 invoices ofinstallments. Following the the declaration of the beginning of the year N+1, an adjustment (invoice or credit note) will be sent to correspond to the real marketings of year N. of the year N.
 

Control / Audit

Within the framework of its mission and the respect of equity between members, Valobat will endeavour to secure the correct declaration of its members via automatic controls in order to limit data entry errors and via regulatory audits carried out by independent firms. These firms, selected after a call for tenders, will validate that the declarations and the marketing of PMCB are coherent.

All marketers, members of Valobat are concerned by the policy of Valobat's controls, whether they are automatic, on parts or on site.

Article R541-128 4° of the Environmental Code provides that Valobat may control at least 20% of the quantities of products placed on the market by Valobat members.

The regulatory control will be carried out by an independent third-party organization accredited by the French Accreditation Committee (COFRAC) or equivalent, as an inspection body for the external control activities of the declarations of placing on the market of the contributors of the eco-organizations (COFRAC accreditation 12.7.2) The body or bodies authorized to carry out the controls will be chosen after a call for tenders.

In order to ensure the reliability of its members' declarations, in compliance with its regulatory obligations, Valobat has developed a control policy. This one will be based on a progressive approach of automated controls, controls on documents and on site controls. The automated controls aim at correcting eventual data entry errors. Documentary checks are carried out through document exchanges. On-site controls may require more time, one day, with the auditors travelling to the member's site.

The regulatory control is financed by Valobat.

In case of detection during a control of a deviation in the declaration of quantities, either upwards or downwards, a corrective declaration is made and an invoice or a credit note is issued by Valobat.

The external audit performed by the independent auditor aims at checking the consistency between the declarations and the member's marketings. The report highlights differences, over-declarations and/or under-declarations so that they can be corrected to reach the "correct declaration". In case of dispute between the auditor and the member, Valobat can of course bring its expertise which can be settled by the public authorities.

Articles R. 541-126 and 541-128 of the Environmental Code specify the provisions for the control of members. In order to ensure that the control procedures to which the members of the various approved eco-organizations of the PMCB EPR sector will be confronted do not compete with each other, Valobat will request harmonization between the various approval holders via the coordinating organization.

 

Regulations

Article R543-290 of the Environmental Code, created by the decree of December 31, 2021, specifies the notion of producer who must contribute for the PMCBs that they place on the market. This is any natural or legal person who, on a professional basis:
- either manufactures or has manufactured construction products or materials from the building sector that it makes available on the national market under its own name or brand with a view to being used by any person who carries out or has carried out by a third party construction or renovation work on the national territory;
- or imports or introduces for the first time on the national market construction products or materials from the building sector intended for use on the national territory
In the case where building products or materials from the building sector are made available on the market under the brand name of a reseller, the reseller is considered to be the producer.
Some particular cases may require detailed answers from Valobat.

Valobat has developed tools to help you find out if you are concerned by the regulation.
Find out if you are a marketer in the sense of EPR with our dedicated tool.
Find out if your products and materials fall within the scope of PMCB EPR with our online scale.
Still in doubt? Call our Customer Relations Center to clear it up!

The decree of December 31, 2021 separated the products and materials of the building into 2 large categories: mineral products and others.
- in the first, are classified in 9 families those constituted mainly in mass of minerals not containing neither glass, nor mineral wools or plaster as for example: concrete, mortar, lime, stone type limestone, granite, sandstone and lava, terra cotta or raw, slate, bituminous mixture, aggregate or ceramic.
- In the second category, we find all the other products and building materials classified in 9 families as for example:
-> those made mostly of metal, wood or plastic,
-> those based on plaster, bituminous membranes, glass wool or rock wool,
-> those of plant or, animal origin,
-> mortars, coatings, paints, varnishes, resins...
-> joinery...
Valobat has developed a tool to allow you to easily find your products subject to the regulations.

The law of February 10, 2020 establishes the principle of an EPR for construction products and materials. Manufacturers are therefore obliged to manage the end-of-life of their products, either through an individual system or by paying an eco-contribution to an approved eco-organization for the BMCP sector.
Distributors are subject to eco-contribution for private label products and/or products for which they are the first marketers in French market in importingor introducing PMCBs into France.
Membership of an eco-organization and the payment of an eco-contribution on products (mandatory voluntary contribution) is a regulatory obligation for producers on the market, unless you have an approval by the public authorities for your own individual system. As part of its mission, Valobat will inform the producers of the market of their obligation through awareness campaigns. If you are not a member of an approved eco-organization for this sector or if your individual system has not been approved by the public authorities, you are likely to receive a reminder of the law from the public authorities, followed by a formal notice to rectify the situation before receiving an administrative fine of a dissuasive amount.
As they are not placed on the market in France (including DROM COM), exported products are excluded from EPR
The AGEC law of February 2020 stipulates that PMCB are concerned by EPR. Also, to comply with it, each PMCB marketer can either join an approved eco-organization for this sector, or set up its own "individual system", by filing an approval request with the public authorities and comply with the same obligations or almost the same as those imposed on the eco-organization.
The AGEC law required that the EPR applied to PMCBs come into force on January 1, 2022. However, to be able to start operationally, an eco-organization must meet a set of specifications. The latter was published on June 10, 2022. In response, Valobat has submitted its application for approval, which will allow it to officially exercise its role as an eco-organization approved by the public authorities. In addition to its press release of November 2021 indicating that the operational start of the sector was postponed to January 1, 2023, the Ministry of Ecological Transition and Territorial Cohesion confirmed in a new press release published in June 2022 the postponement "so that the sector can be operational from the beginning of 2023".
If several eco-organizations are approved for the same sector, Article R. 541-107 of the Decree of November 27, 2020 states that the specifications may provide for the establishment of a coordinating organization to work on certain issues. For the PMCB sector, article R. 543-290-12 already provides for the missions of this coordinating body. The conditions for approval are specified in the order laying down specifications for the PMCB sector.

By law, each material must fund its own cost.

By identifying very clear boundaries between the different sectors, Valobat guarantees through its cost accounting that one product or material will not pay for another.

A marketer may choose to entrust a third party, the agent, with the operations of registration, declaration, invoicing, payments and/or management of control operations... The marketer (the principal) and the agent may sign a contract, the mandate, in which the purpose of the contract, the obligations of the agent and of the principal, and the responsibility of the agent in the exercise of its missions are specified. In its membership contract, Valobat will specify the information that must be included in the mandate.
Yes, the eco-contribution collected by Valobat is subject to VAT.

Contact the Valobat Customer Relations Center

Can't find the answers to your questions in our frequently asked questions?

Contact our Customer Relations Center now by dialing 01 80 83 60 70for the price of a local call.

Our consultants are available from 8:30 am to 6:00 pm, Monday to Friday.

You wish to send us a request by e-mail?

If your request concerns membership of the eco-organization Valobat, or any question concerning the marketers, please contact us at adherents@valobat.fr.

For any other request, contact us at contact@valobat.fr or use our contact form.