Following our previous article sent on the 17th September 2021, please find below the latest update regarding the French packaging regulation.
Final approval of the harmonised sorting information guidelines
On the 27th September, Citeo, the French packaging take-back scheme released their sorting guideline. This guideline explains the producers how to adjust the labelling of packaging based on the updated regulations. It contains all pictograms necessary to create individual sorting information based on your possible packaging composition.
Transition period
As explained in our previous newsletter, the sorting information will become compulsory on all packaging starting from the 9th September 2022. An extension of the deadline until the 9th March 2023 is granted to all packaging produced or imported before the 9th September 2022.
Where should the sorting information be displayed on your packaging?
It is recommended to display the sorting information on the outer packaging unit of the product (in case of sales packaging) in order to explain to the customer where to discard all the different packaging units of the product. Please be advised that the shipping packaging is not considered to be part of the packaging product and should have a distinct sorting information from the sales packaging. The reason behind is to make sure that the customer will discard both shipping and sales packaging in the recycling box, even though it might be discarded at a different time.
Citeo created three different versions of the sorting information in order to provide all producers with the required variations. The sorting information is provided free of charge to our existing customers with French packaging registration.
The French take-back schemes have decided not to release publically the harmonised sorting information guidelines on their websites. Their intention is to avoid producers using these guidelines without being registered with a take-back scheme. If foreign producers wish to adjust their packaging according to the latest guidelines, they either need to register with a take-back scheme or contact their registered importer in France in order to receive the guidelines.
Dematerialisation of the Triman logo and the sorting information allowed in special cases
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. In these cases you have the possibility to display the Triman logo and related sorting information online.
Please find below the two 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 and no other document is supplied with the product. The Triman logo remains mandatory on the packaged product.
- The dematerialisation of the Triman logo and the sorting information is 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.
Important: the Triman logo and the sorting information can be applied to the packaging by sticker!
Should you wish to register in France as a producer of WEEE, batteries, packaging, textiles or furniture, please do not hesitate to contact our Consulting Department via beratung@take-e-way.de or +49/40/750687-0.
For solutions on EU product or packaging labelling requirements and especially disposal labelling, please contact the trade-e-bility consulting team via beratung@trade-e-bility.de or +49/40/75068730-0.
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/international-compliance/
