German EPR# German Packaging Law# German Triman Mark# European EPR Compliance

From January 1, 2022 until March 9, 2023, the Triman logo will be mandatory for the packaging of products covered by Article L. 541-10 of the French Environment Act.
Beginning March 9, 2023, all household packaging must include clear, uniform labeling that indicates how the product is sorted and recycled. For specific products, the law provides additional deadlines for implementation.

All products must be labeled with a unique logo. This logo will indicate that the product should not be thrown into the household trash and that it is sortable. This is the famous Triman logo.
First, the information displayed on the package (classification labeling)
Medium of use: Packaging (or on a label affixed to the packaging), except glass beverage containers, in accordance with Article R. 541-12-21 of the French Environmental Code.
Objective: To make it easier for consumers to sort packaging in order to increase collection and develop recycling channels.
 Packaging 
In accordance with Article L. 541-9-3 of the French Environmental Code, the TRIMAN logo and information on the classification process must be affixed to all products subject to the Extended Producer Responsibility (EPR) and intended for household use.
Packages with a surface area of less than 10cm² are exempt from labeling requirements.
Packages with a surface area between 10 and 20 cm² can display Triman only.

Color Requirement
Triman signs it must be printed in black and white, while sorting recycling suggestions can be in color or black and white.

 Application Deadline
From 9 March 2023, all packaging must carry the Classification Mark.
The inventory clearance period may be extended if the following conditions apply
 - If the packaging/product was manufactured before 9 September 2022
 - If the person who packaged the product owned the packaging before 9 March 2023, it does not matter whether he filled it or not/if the manufacturer or importer sold the product before 9 March.
From January 2017, Green Dot accreditation is no longer mandatory.

 Penalty 
The DGCCRF Inspectorate imposes an administrative fine for each violation found. The penalty may not exceed €3,000 for individuals and €15,000 for legal entities, and may apply to any product that does not bear the TRIMAN label and does not provide information on the classification process.

 Packaging Information
Medium used: dematerialized (and packaged on a voluntary basis).
Purpose: To inform consumers about the environmental quality and characteristics of products that generate waste so as to enhance consumer information at the point of purchase.

 Products 
The obligation relates to new products on the French market and applies to the entire product (except for information on recyclability, which may be provided for each component of the product covered by the EPR program). The obligation does not apply to refurbished or second-hand products sold to consumers.

  Related Companies and Duration 
The obligation applies to manufacturers, importers and other distributors of products listed in Article R. 541-221 of the Environmental Code. The deadline varies according to the number of products on the French market and the turnover of the company:
Under E.C. R. 541-221, information on a hazardous substance is to be provided within six months of the substance being determined to be hazardous.
Turnover threshold: corresponds to the turnover realized in the previous financial year by the creators, importers or any other company placing products on the market, of all the products referred to in Article R. 541-221 of the French Market Environment Act.
Threshold in terms of product units placed on the market: corresponds to the cumulative total of all products placed on the French market.

  Product List  
The information referred to in Decree-Law No. 1 2022-748 (except for information related to the use of reparability indices, sustainability indices, and the use of re-enforcement resources) is made available to the public in the form of a dematerialized "Product Sheet", which can be reused, utilized, and aggregated in an automated manner, and is entitled "Product Sheet Related to Environmental Quality or Characteristics", with the name and reference number of the relevant model number. The title is "Product List Related to Environmental Quality or Characteristics" and includes the name and reference number of the relevant model number.
Product lists must be accessible free of charge at the time of purchase on a web site or web page dedicated to each relevant product model or, if this is not possible, at the smallest scale available.
Information that is no longer valid must be updated in the Product Sheet and the date of the update must be indicated.
For products placed on the market with primary or sales packaging (e.g. containers, bottles, flasks), information on the percentage of recycled materials, recyclability and the possible presence of hazardous substances in the packaging must be stated in two separate parts of the product:
environmental quality and characteristics of packaging"; and "environmental quality and characteristics of products".
Sellers/distributors are not affected by this obligation. However, retailers are encouraged to include this information on their websites in order to provide the best possible information to consumers.
The information contained in the Product Data Sheet must be provided 2 years after the last unit of the relevant product has been placed on the market.
Product Data Sheets do not need to be created for the last unit of product models released to the market before 31 March 2023.
Additional information or logos may be added to a separate part of the product list, on the product or near the product, provided that this does not cause confusion to the consumer. The accuracy of this information remains the responsibility of the manufacturer or importer.
Manufacturers have 3 months from the date of approval or publication of an order setting premiums and penalties to include in their Product Sheets information about which premiums or penalties apply to their products.

 Mandatory information 
The obligation applies to manufacturers, importers or other distributors of products listed in Article R. 541-221 of the French Environmental Code. The deadline varies depending on the number of products on the French market and the company's sales:

  Prohibited Information 
The use of "biodegradable", "respect for the environment" or any other equivalent environmental claim is prohibited. For products and packaging manufactured or imported before April 30, 2022, the ban applies as of January 1, 2023.

  Penalty 
Penalties From January 1, 2023, any non-compliance may be recorded by the DGCCRF inspector and may not exceed €3,000 for individuals and €15,000 for legal entities, and may apply to any product that does not bear the TRIMAN label and does not provide information on the classification process.
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