Triman logo in France
News on packaging licensing, mandatory labeling and sorting instructions
The Triman logo is probably one of the most important recycling symbols in retail. At least for dealers who ship their products to France. However, many (online) retailers are not familiar with the meaning of the Triman logo.
What is the Triman logo about? What should be considered when using the Triman logo? As always, we will answer these and other questions in our blog!
Since January 1, 2015, it has been mandatory to affix the Triman logo to recyclable products and packaging that usually end up in household waste. The legislator hopes that this will make it easier for the end consumer to see how precisely he is best able to dispose of the products. Products with a printed Triman logo therefore belong in the recycling or waste paper bin, while products without the logo can simply be disposed of with the residual waste. On the French side, sorting packaging is one of the most important contributions to a more sustainable environment. Around 89% of French citizens sort their packaging. But only 51% of them use a proven system. The legislature hopes for an even higher participation rate and an improved systematic separation through the sorting instructions, which contain the Triman logo.
The sorting instructions that were finally implemented were tested in advance by consumers and found to be good. In practice, however, it is usually not quite that simple. More on this later.
Table of contents
- Triman logo: Which packaging is affected?
- Structure of the Triman logo
- Triman logo in France: Legal requirements for product labeling requirements
- What applied to the Triman logo so far?
- How are the changes for the Triman logo from 2021?
- What will remain the same with the Triman logo in 2021?
- Why is the use of the Triman logo important for Germany?
- Update April 2021
- Update September 2021
- Triman logo: changes in 2022
- Triman-Logo: Here we help!
Triman-Logo: Which packaging is affected?
In general, all household packaging must be marked with the Triman logo. It makes no difference whether they are made of paper, cardboard, metal, plastic, aluminum, etc. Shipping cartons from the online trade, whether recyclable or not, must also bear the Triman logo.
Glass beverage bottles are an exception to this obligation. Here, the use of the Triman logo and sorting instructions is voluntary.
For electrical equipment according to WEEE, the obligation to mark with the Triman logo was dropped, since the “crossed-out dustbin” was obligatory as a substitute.
Non-compliance with these uniform labeling obligations was punishable by fines of up to €100,000 and imprisonment of up to 2 years.
Structure of the Triman logo
In order to understand the system of the Triman logo, we explain its structure in detail here:
- Of course, the Triman logo is mandatory and inextricably linked to the infoTri cartridge.
- The “hanger” and “sorting container” zones take on the colors that are characteristic of the sorting: green for glass packaging, yellow for other packaging.
- On the Triman logo, all elements that can be separated after consumption or use must be visually represented and separated by an addition symbol. The elements can be displayed either in graphic or written form.
- The designation “sorting container” (French: Bac de tri) or “tri verre” for glass packaging clearly indicates the destination of the packaging.
Guidelines: Return and Recycling in E-Commerce
Anyone who trades in products is subject to binding disposal and recycling duties, non-compliance with which can lead to considerable sanctions and warnings
The problem: many retailers are not aware of their obligations. But only someone who acts with legal certainty is safe from unplanned costs and fines.
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Triman logo in France: legal requirements for product labelling obligations plus changes for electrical equipment from 2021
Since 1st January 2015, it has been necessary to display the Triman logo on all recyclable products that are collected separately in France. The aim is to inform consumers that the product is recyclable, collected separately and subject to extended producer responsibility (EPR). However, an important change is being made in 2021, which is important for you here in Germany if you send electrical appliances to France: this is because the Triman logo also applies to products that are exported to France.
What has been valid for the Triman logo up to now?
Until now, labelling with the Triman logo has only been mandatory for products such as furniture, textiles and shoes – no matter whether or not they are electrical. For electrical equipment in accordance with WEEE, there was no obligation to label with the Triman logo as the “crossed-out wheelie bin” was mandatory here as a substitute.
Non-compliance with regard to these uniform labelling obligations was punished with fines of up to EUR 100,000 and a custodial sentence of up to 2 years.
The WEEE Directive and national legislation on electrical and electronic equipment are giving you a headache?
There is the threat of considerable warnings and fines, and even ignorance does not protect you from punishment.
Deutsche Recycling supports you with national and international recycling legislation, with services flexibly tailored to your products and regions with a focus on packaging, batteries and electrical appliances.
What changes apply to the Triman logo from 2021?
The changes for the Triman logo come into force on 1st January 2021. It is then also mandatory for all electrical equipment. From 2021, it is also no longer sufficient to display the Triman logo on your own website. This has been a practical option up to now, especially for online retailers if they were not also the manufacturer of the respective product and could not simply affix the Triman logo themselves.
This option is thus no longer available from 2021. Following the change, the Triman logo must always be displayed on the actual product or on its packaging. No specific information is currently available about future sanctions in the event that the amended provisions for the Triman logo are not observed. However, these are very likely. Nevertheless, the authorities still have some time to draw up and approve the corresponding draft legislation.
What will stay the same for the Triman logo in 2021?
The Triman logo still needs to be printed in conjunction with recycling instructions or sorting instructions. There is no further precise specification for the accompanying sorting instructions – however, it must be ensured that they are not incorrect or hamper the consumer’s understanding. You will find some examples here:
Nothing is changing in terms of the design of the Triman logo either. It must be at least 0.6 cm wide and may not be superimposed by other visual elements or be smaller than symbols printed alongside it. Coloured printing of the Triman logo is still not permitted.
You have the WEEE Directive breathing down your neck?
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It is easy to get lost in the jungle of regulations regarding the Electrical and Electronic Equipment Act/WEEE – with serious financial consequences.
Deutsche Recycling takes over the handling of all related obligations, thereby reducing the effort and costs for your company, avoiding possible penalties and warnings, and responding to the constant changes in the legal situation. Our team of experts looks forward to supporting you personally.
Why is the use of the Triman logo important?
French e-commerce is booming, which is also making it more and more attractive for online retailers. As a result, the Triman logo also increasing in relevance. Those who export a product, for which the logo is mandatory, to France must note the corresponding obligations. If you, for instance, operate an online shop, sell electrical equipment and ship it to France or intend to do so, 1st January 2021 is a crucial date for you.
Do you have any questions or need support or more information? Just get in touch with us! We will be happy to help you further.
Update April 2021
France’s highest administrative court, the Conseil d’État, has granted urgent requests for the immediate suspension of France’s new packaging labelling decree.
As part of the suspension of enforcement of the 30 November 2020 decree, the French Conseil d’État has decided to postpone the ban on placing symbols of disposal systems other than the Triman logo. The issue requires further discussion within the French government.
At this stage, the French Council of State has yet to decide whether or not to maintain the ban and penalty for the use of symbols other than the Triman logo. The final decision is expected within 6 to 18 months.
Update September 2021
Since there were more and more questions about the use of the sorting instructions, we would like to point out once again that the current regulation is not formulated clearly.
The plans currently envisage the publication of a new, standardized version of the waste separation instructions on November 30th. This includes, the transition periods to be observed: at the latest 12 months after approval, the waste separation instructions and the French Triman logo must be affixed to household packaging and affected products. This can be done in the form of a sticker.
Products that have already been produced receive a transition period of 6 months, starting with the expected cut-off date on November 30, 2021.
Basically:
The Triman logo …
- … must be printed in connection with recycling or sorting instructions
- … must not be printed in color
- … must not be overlaid by other visual elements
- … must be at least 0.6 centimeters wide
- … must not be smaller than the character printed next to it
The WEEE Directive and national legislation on electrical and electronic equipment are giving you a headache?
There is the threat of considerable warnings and fines, and even ignorance does not protect you from punishment.
Deutsche Recycling supports you with national and international recycling legislation, with services flexibly tailored to your products and regions with a focus on packaging, batteries and electrical appliances.
Triman logo: changes in 2022
The labeling requirements are now anchored in the French code, the Code de I ‘environnement, and come into force on January 1, 2022. In this case, electrical devices or their packaging must also be provided with the Triman logo. The crossed-out wheeled bin symbol must also continue to be used.
In summary, the Triman logo requirement applies in particular to all household packaging, textiles, shoes, furniture, tires and paper products – insofar as these can be recycled. From 2022, electrical devices and batteries will also be subject to the Triman logo. The area of application is therefore expanding increasingly.
What if the Triman logo cannot be applied at all?
For online shops that are not from France, it is sometimes not that easy to put the Triman logo on products or packaging. This is the case, for example, when the retailer is not a manufacturer himself and therefore has no influence at all.
An image of the Triman logo on the product page is also valid until January 2022. Alternatively, a special subpage can even be created for this purpose, which, however, should also contain the information as to which products and packaging can be recycled in addition to the Triman logo. Consequently, this notice should also be shown in French, even or especially if manufacturers or distributors come from abroad.
From 2022, a reference on the website or product page will no longer be sufficient. Depending of the size of the packaging Triman symbol and sorting guide must be printed or sticked on it.
If the packaging is less than 10 cm², the Triman / Sorting guide can be on the product instruction or leaflet
For a packaging between 10 and 20 cm², the Triman logo must be on the packaging and the sorting guide including Triman logo on product instruction or leaflet
For packaging bigger than 20 cm ², Triman and sorting guide must be printed or sticked on it.
Please note that the dematerialisation of the Triman and sorting is only possible if no other document is provided with the product.
Triman logo: This is where we help!
As a service provider in the field of environmental compliance , you can easily hand over your obligations to us. We take over your manufacturer obligations for you worldwide and in all areas (WEEE, packaging and battery). As a full-service provider, we are responsible for the labeling and information obligations, the initial registration, monthly quantity reports, contract management, invoice verification, as well as the return and disposal of the goods you have placed on the market.
It goes without saying that we assume full liability. In its work, Deutsche Recycling draws on concentrated expertise and a global waste disposal network. We operate in 12 different languages and have agents all over the world.
If you have any further questions about the Triman logo or other environmental compliance issues, please do not hesitate to contact us. We look forward to your inquiry!
