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Do you trade in France?

If that's the case, please be aware that there have been some recent changes to French household packaging legislations, including the roll-out of the Triman logo and InfoTri signage.

This means that there are changes to your eco-responsibility as a UK manufacturer/exporter placing certain products on the French market, and ensure you are compliant by the 9 March 2023 deadline.

The UK Department for International Trade (DIT) has provided the information below. 

Organisations can download below the slides from the webinar on Packaging and Labelling organised by DIT France and CITEO at the end of November 2022, and access the webinar recording here: https://www.youtube.com/watch?v=mBT1-Mml_aQ&feature=youtu.be

For questions concerning the Infotri requirements for Household Packaging, you can contact one of the three eco-organisms that cover the sector:

  1. CITEO - Accueil | CITEO, 50 boulevard Haussmann 75009 Paris, contact@citeo.com,  tel: +33 (0)1 81 69 06 00
  2. ADELPHE (Part of the CITEO group) - Nous contacter | Adelphe
  3. LEKO - Home page - Leko (leko-organisme.fr) - contact@leko-organisme.fr

 

In addition, if you manufacture any products that fall under one of France’s other extended producer responsibility schemes, you may also want to contact the eco-organisms responsible for that sector for information on their infotri guidance. You can find the names of these on the following links (in French) - Filières à responsabilité élargie des producteurs | Ministères Écologie Énergie Territoires (ecologie.gouv.fr)

If you would like to receive any support from DIT and are not already in touch with us, please contact via the export support service helpline - Ask the export support team a question - GOV.UK (www.gov.uk)

Latest update (march 2023):

  • All packaging must have the triman logo from the 9th of March 2023 – there are two exceptions :
      • If the packaging has been produced before the 9th of September 2022
      • If the person responsible for packaging goods has bought or acquired the packaging before the 9th of March deadline
  • Regarding penalties
    • If you do not use the triman logo, here is the applicable law: Article L.541-9-4 of the Environment Code provides that: "Any breach of the information obligations mentioned in Articles L. 541-9-2 and L. 541-9-3 is liable to administrative fine, the amount of which may not exceed €3,000 for a natural person and €15,000 for a legal person. This fine is imposed under the conditions applied in Chapter II of Title II of Book V of the Consumer Code”.
    • If you do not register with the eco organisations: fine of 7500 euros for a legal person (article L.541-10 III of the environmental code)
  • Compliance deadlines:   
    • Packaging – March 2023
    • Textile – August 2023

Moreover, the European Commission announced that it had opened an infringement procedure against France on February 15 about the Triman logo. The Commission considers that, in the absence of harmonized rules at European level, the labelling requirements set out in the “AGEC” law undermine the principle of free movement of goods. It also invokes "counterproductive effects on the environment" and specifies that "such a measure may lead to increased material requirements for additional labelling and greater production of waste due to the larger than necessary size of the packaging. ". At this stage, there isn’t any more information on France’s reply to this procedure and the French law remains applicable. You will find attached documents from CITEO that sums up the information on the triman logo and important deadlines to have in mind.