Following our previous newsletter article published on the 23rd March 2021, please find below the latest updates regarding the French packaging regulation, as a new related decree has recently been released.
The decree of the 29th June 2021 is establishing additional regulations concerning the displaying of the Triman and the new harmonised sorting information guideline.
We are still waiting for the outcome of the French Council of State’s decision on the green dot cancelation. As usual, you will be updated on any further development.
Additional transition period for the implementation of the new sorting information
The release of the new sorting information has been further delayed. The French government is still evaluating the guidelines’s proposal from the French take-back schemes. The packaging take-back schemes believe that the guidelines will be available in November 2021.
The display of the Triman and the sorting information on every household packaging is still officially scheduled for the 1st January 2022, however the decree is mentioning a one year transition period after the release of the sorting information. In addition to the above transition period, you will benefit as well from a six-month stock clearance for all the goods produced before the implementation of the law.
For example, if the new harmonised sorting information is released in November 2021, you will have to display the Triman logo with the sorting information in November 2022. All packaging produced before November 2022 can be sold in the market until May 2023 due to the stock clearance period.
Dematerialisation of the Triman logo and the sorting information allowed in special case
As mentioned in the Anti-waste law for a circular economy (AGEC), the Triman Logo and the sorting information have to be displayed on the packaging itself.
Some exceptions were made for glass containers (fully exempted) and small size packaging. Please find below the 2 exceptions for the small size packaging:
- The dematerialisation of the sorting information is possible when the surface of the largest side of the packaged product is between ten to twenty square centimetres.
The Triman logo remains mandatory on the packaged product.
- The dematerialisation of the Triman and the sorting information are possible when the surface of the largest side of the packaged product is less than ten square centimetres and no other document is supplied with the product.
Additional point: the Triman logo and the sorting information can be added to the packaging with a sticker.
We will keep you informed on the upcoming decisions, which could further impact your obligations as a producer of packaging in France.
Should you have any queries related, please do not hesitate to approach Quentin Dequet (+49/40/750687-126) or Alina Eggert (+49/40/750687-166) via firstname.lastname@example.org.
For more information on our international compliance services related to the placing on the market of electronic equipment, batteries/accumulators and packaged products or packaging, please click here: https://www.take-e-way.com/services/international-compliance/