France: Labelling obligation WEEE, lamps, batteries and PV modules
The French government has approved the sorting information guideline for electrical and electronic devices, batteries, lamps and PV modules. If you put any of these types of products on the French market, the following information is highly relevant for you.
We hereby inform you that the French government has approved the sorting information guideline for electrical and electronic devices, batteries, lamps and PV modules. If you put any of these types of products on the French market, the following information is highly relevant for you.
Please note that according to the latest news we received, the sorting information for specific equipment, among others PV modules, is supposed to be modified. This will not affect the general implementation procedures. We will keep you updated about further developments.
What is the sorting information about?
According to the decree n°2021-835 from 29th June 2021, all French take-back systems have to develop a sorting information per waste stream, which is supposed to help the consumers sort their waste correctly. The take-back systems for packaging have already released their sorting information guideline in 2021 (please see our previous articles). Recently, the take-back systems for WEEE, batteries and PV modules have as well published their sorting information guideline.
The guideline has been published in French as well as in English. Please find below seven key facts:
- The information for the consumer consists of the Triman symbol with the info-tri (sorting information), which have to be displayed together.
- Every product, which is meant to end up in households, is concerned.
- The Triman and the sorting information have to be displayed on the product or its packaging. In certain cases, it can be displayed on other documents delivered with the product or on the producer’s website.
- The crossed-out bin can replace the Triman on the packaging.
- The crossed-out bin on the product itself cannot be replaced by the Triman and still needs to be displayed on the product.
- For electrical and electronic equipment that operates with portable batteries or a lamp, only one sorting information is sufficient ("This appliance and its battery are recyclable", "This luminaire and its bulb" etc. in French). That means, you do not have to display two different sorting information but only a combined one. If the battery is not removable, the instruction “This device is recyclable” is sufficient.
- For PV panels, there is a pictogram available that can be used instead of the written version.
Time schedule for the implementation
The Triman and the sorting information must be implemented by 15th December 2022. An additional transition period is being granted until 15th June 2023 for the disposal of stocks in France. The deadline to implement the labelling that refers to the packaging elements is postponed from 9th March 2023 to 15th June 2023 for all packaging produced or imported before 9th September 2022.
What does the sorting information look like?
The sorting information consists of five elements (see illustration above). Please find the explanations of the elements below:
- The Triman symbol or the crossed-out bin.
- The country code FR.
- Description in French of the product concerned and the electrical or electronic items that are sold with the unit such as power cords, portable batteries, remote controls etc. (e.g. “This device [and its accessories and battery] are recyclable”). You can opt for a more detailed description like “This TV, its accessories, batteries and cords are recyclable”.
- The disposal options: small and large appliances have to be disposed at different locations, which is reflected by different pictograms.
- Additional information about collection points (mandatory) and repair options (optional).
Where do I have to display the sorting information?
Basically, the Triman and the sorting information have to be displayed on the product or on its packaging as long as the size allows for the application. A summary in brief:
- Packaging and document available:
Triman and sorting information have to be displayed on the product or on its packaging, as long as the size of the product allows for it. Otherwise, the Triman and the sorting information have to be displayed in the document that is delivered with the product.
- Packaging available, but no document available:
The sorting information has to be displayed on the product or on its packaging, as long as the size of the product allows for it. Otherwise, the sorting information has to be displayed on the producer’s website.
- No packaging available, no document available:
The sorting information has to be displayed on the product or on the producer’s website.
Should you have any queries related, please do not hesitate to approach Mr. Florian Spreu (+49/40/750687-159).
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: www.take-e-way.de/international-compliance/