French labelling and packaging requirements for consumer goods

To align with upcoming EU measures focusing on the circular economy and product sustainability, France has recently introduced new environmental labelling regulations. These regulations specifically target consumer goods that contribute to waste generation, aiming to encourage companies to provide accurate information to consumers. Starting from 1st January 2023, these rules will be enforced based on a company’s turnover.

The new regulations were officially announced in the implementing decree No. 2022-748 on 29th April 2022. These regulations were subsequently added to the French Environment Code (Article L541-9-1), which became effective on 1st January 2022. As per these regulations, manufacturers and importers of products sold in France are now required to provide consumers with information regarding the environmental attributes of their products at the time of purchase. This can be done through visible markings, labels, and electronic formats.

Revised Packaging and Labelling Guidelines in France: What’s Included

The information that is required includes the percentage of recycled content, the utilisation of renewable resources, the durability of the product, its compostability, the possibility of repair and reuse, the recyclability of the product, and the presence of harmful substances.

For instance, when it comes to textiles and footwear, it is important to mention the percentage of recycled materials they could contain, as well as providing details on the traceability of the products. Also information regarding the release of plastic microfibers into the environment during washing should be disclosed.

The traceability data should encompass key details regarding the main country of origin where specific processes occur. For textiles, this includes weaving, dyeing/printing, cutting, and sewing. For footwear, it involves stitching (upper), assembly, and finishing.

Effective Date for French Packaging and Labelling Requirements

The new measures contained in the decree are applicable

• from 1 January 2023 for manufacturers or importers with an annual turnover of more than €50 million and responsible for placing at least 25,000 articles on the French market;
• from 1 January 2024 for manufacturers or importers with an annual turnover exceeding 20 million euros and are responsible for placing at least 10,000 articles on the French market.

European Union’s Guidelines: A Step Towards Sustainable Packaging

The European Union introduced the EU directive 2018/852 in 2018, marking a significant step towards stricter waste recycling targets. It aimed to ensure that by December 31, 2025, a minimum of 65% of all packaging waste would be recycled. With the target percentage increasing to 70% by December 31, 2030. The Union has prioritised transitioning to a circular economy and enhancing the recycling of packaging waste as key measures to achieve these goals.

Additional benefits include a positive impact on environmental preservation, protection, and quality, as well as contributing to the improved protection of human health and the efficient utilisation of natural resources. The EU’s long-term strategy focuses on developing products made from new recyclable and biodegradable materials. This strategy not only reduces the EU’s reliance on raw material imports but also promotes responsible waste management through reuse and recycling in the short and medium term.

However, there are still significant variations among the Member States regarding the implementation of the directive. Some countries, as mentioned in the directive itself, have yet to establish the required waste management infrastructure. Additionally, different Member States have adopted diverse approaches to transpose the directive into their national legislation.

For example, in Italy, a system known as “environmental labelling” has been introduced (you can find more information in this article on Italian environmental labelling). As a result, there is inconsistency in the provision of consumer information, which is crucial for achieving the targeted recycling objectives. It is worth noting that in certain countries, no information tools have been introduced or made obligatory.

Environmental Labelling in France

The AGEC law (Loi Anti-gaspillage pour une économie circulaire) of 10 February 2020 relating to the fight against waste and for a circular economy (Loi n. 2020-105 du 10 février 2020 relative à la lutte contre le gaspillage et à l’économie circulaire) and the decree relating to the information to be provided to consumers (Décret n° 2021-835 du 29 juin 2021 relatif à l’information des consommateurs sur la règle de tri des déchets issus des produits soumis au prince de responsabilité élargie du producteur) have introduced new objectives and regulations to foster more sustainable production and consumption in alignment with the European Directive.

Significant changes have been made to the rules governing the TRIMAN logo. The obligation to display this logo now extends to all packaging and accompanying documents, regardless of their recyclability. This requirement applies to producers, importers, or distributors introducing pre-packaged recyclable products intended for final consumers in the French market. However, certain products aimed at business-to-business (B2B) transactions and glass bottles intended for domestic use are exempt from this obligation. 

Product Labelling in Europe’s Robust Cosmetic Market

The European cosmetics market presents abundant opportunities but also challenges that demand attention to detail. Understanding the intricacies of product labelling for cosmetics in Europe is paramount for businesses seeking to thrive in this diverse market. Europe stands as a significant hub for the cosmetics industry, making it crucial for companies to grasp the nuanced regulations governing product labelling. Compliance with these standards ensures a solid foundation for success in the European cosmetics sector, which boasts a robust and discerning consumer base

Logo Placement: General Overview

The requirement to display this logo came into effect on January 1, 2022. By no later than March 9, 2023, all packaging placed on the market should bear these indications. It is important to consider the French decree, which emphasises the principle of mutual recognition (Articles 34 and 36 of the Treaty on the Functioning of the European Union). According to this decree, packaging labelled in compliance with an equivalent and binding standard is also considered compliant in another Member State, as long as its contents are compatible with the national standards (Article R541-12-20).

In practical terms, if the information for the end consumer regarding the proper disposal of primary packaging is translated into French, there should be no issues due to the principle of mutual recognition. However, as a precautionary measure, it is advisable to adhere to the French legislation and the guidelines provided by Citeo (an association responsible for recycling plastic and paper packaging, resulting from the merger of Eco-Emballages and Ecofolio).

Furthermore, the standard allows for the inclusion of tabs with the initials of individual countries on a monochromatic background to accommodate different regulations, as long as they are similar to the French standard. The “bac de tri” refers to the bin where all recyclable waste is disposed of. The logo, therefore, adopts the colour of the bin itself, which is yellow. The “bac de tri” collects not only plastic bottles but also films, jars, trays, paper, metals, and cardboard boxes starting from 2022. For glass recycling, the designated bin is the “tri verre,” which is green in colour.

Triman Logo Placement

The Triman logo is required to be placed on packaging, irrespective of its recyclability, to notify consumers that the product or packaging is subject to sorting rules.

• The logo should be in black and white on a contrasting background for visibility and legibility.
• The logo must be indelible and clearly visible when disposing of the packaging.
• The logo should not overlap with other images or text.
• No misleading indications should be present alongside the logo.

How to compose the info-tri  

There are four elements that make up the Infotri logo:

• Triman logo 
• the first yellow area with the phrase “le tri + facile” (optional)
• the packaging material which can be reported in various formats: text and pictogram; text only; pictogram only
• the collection destination: green for glass and yellow for other materials, in the format with text and pictogram, or pictogram only.

Graphics specifications

The elements can be represented horizontally, vertically or in a block. In the case of the horizontal format, the dimensions of the standard format provide for a height of 16 mm (19 mm in the case of additional optional indications, such as “Séparez les éléments avant de trier”); the reduced version, to be used only if space is limited, provides for a reading block height of 8 mm (10.8 mm if optional sentences are inserted). Below is the scheme for the standard format type:

In the case of the vertical format, the standard provides for a width of 22 mm (16 mm in the event that the indication “le tri + facile” is not reported). Note that the height of the Tri man logo is always 10 mm while the space in which to report the packing materials is a square with a width of 13 mm. In the compact version, the width of the information block reduces to 11 mm, and can be further reduced to 8 mm if the indication “le tri + facile” is not included. Below is the scheme for the standard format type.

In the block configuration, the spaces are indicated in the following figure; the heights can be reduced to 14.25 mm in the case of small packaging sizes.

Considering that the space between the margin of the white area of ​​the packaging materials and the yellow border is “x”, the space between the margin of the coloured area and the outer border of the white box must be equal to 3x (see the figure below for details). Letter spacing should never be less than 0.2 mm. Regardless of the configuration and format used, body text must always be greater than or equal to 5 pt.

The writing of the components can be done with the Helvetica Neue 77 Bold Condense font, body text greater than 5pt (see image below point 2a). The indication “Séparez les éléments avant de trier” is optional, but if it is affixed, it must comply with the envisaged provisions and have the format Helvetica Neue 67 Medium Condense Oblique.

In the case of glass packaging, there is an optional indication that can be included, which states “Laissez la capsule sur la bouteille” (Leave the cap on the bottle).

Reproduction of the Triman Logo

The Triman logo should be reproduced using the following guidelines:

• When the printing process allows it, the logo should be printed using the specific Pantone colour.
• If Pantone printing is not possible, the logo should be reproduced using the CMYK four-colour process.
• For video use, such as on websites, videos, apps, or office automation, the logo should be displayed in RGB colours.

In cases where colour printing is not technically feasible, the logo can be applied in a monochromatic colour of your choice.

Triman Logo Labelling Guidelines for Glass Packaging

For glass packaging, the Triman logo should be labelled in green or a monochromatic colour of your choice.

For packaging other than glass, the Triman logo should be labelled in yellow or a monochromatic colour of your choice.

Obviously, the good legibility of the information must be guaranteed:

Available Pictograms and Customization Rules

A variety of pictograms representing a wide range of packaging types (both food and non-food) can be found in the CITEO customer area.

However, it is also possible to create customised pictograms, following the rules outlined below:

Packaging Shape:

• Use a maximum of two lines to define the shape of the packaging.
• Utilise a thick line for the main external contours and a thin line for internal details.

Silhouette Design:

• Draw the silhouette of the packaging completely in profile or in isometric 3D.

Size Considerations:

• The design should fit within a 10 x 10 mm square.
• The entire pictogram should fit within a 13 x 13 mm square, which corresponds to the height of the standard Info tri.
• Leave a margin of 1.5 mm around the template.

Please refer to the accompanying figure for a visual representation of these specifications.

Additional Indications:

When a product is sold in countries other than France, it is mandatory to include the acronym “FR” on the packaging. This ensures clear identification of the country to which the waste disposal rules apply. Additionally, it is permissible to use a version of the label that includes pictograms only. This eliminates the need for translation, providing universal understanding of the waste disposal instructions.

Guidelines for Small Packaging

Small packaging should follow the following rules based on their surface area:

• Surface Area < 10 cm²: If no other document is provided, the entire marking can be digitised.
• Surface Area between 10 and 20 cm²: The Triman logo must be displayed on the packaging. Information on disposal can be presented on a digitised medium.

Would you like to stay updated on this topic or understand how your product can be marketed correctly in France? Are you seeking to make your product environmentally friendly while ensuring consumer and planet safety? Please let us know, and we will be glad to assist you!

We recommend you read next our in-depth article on regulatory compliance in Europe and UK.