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.
The French Triman logo means that a product is recyclable, collected separately and subject to extended producer responsibility. This also applies to electrical equipment from 2021. It is then also mandatory to display the Triman logo on the product or its packaging.
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.
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.
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