French E-commerce Obligations: The Triman Logo
There are probably three key recycling symbols in e-commerce: the Triman Logo, the Green Dot, and the cross-out garbage can. At least for online shops shipping to France. Many sellers, however, do not seem to be aware of the Triman Logo. How does it work and what does it mean? You will get your answer in today's article.
How does the Triman Logo look like?
As of 1 January 2015, French Decree No. 2014-1577 requires the Triman Logo to be printed on recyclable products and packaging sold in France. Using this symbol will allow consumers to better understand the garbage sorting process. If the Triman Logo is not on the product, it can be disposed of in the general waste stream.
Products and packaging with the Triman Logo are meant to be disposed of separately, such as paper or recyclable plastic. It's not quite as simple as it seems.
What packaging is affected by Triman-Logo?
There is no restriction on the type of household packaging that must be marked with the Triman logo, whether it is paper, cardboard, metal, plastic, aluminum, etc. Shipping cartons from the online trade must also bear the Triman logo, whether recyclable or not. There is an exception to this rule when it comes to glass beverage bottles. Triman logo and sorting instructions are optional here.
According to WEEE, the requirement to mark electrical equipment with the Triman logo was dropped since a “crossed-out dustbin” was mandatory as an alternative. There was a maximum fine of €100,000 and a maximum sentence of 2 years for non-compliance with these uniform labeling obligations.
The structure of the Triman logo
The following is a detailed explanation of the Triman logo's structure:
Changes to the Triman logo in 2022
In January 2022, the labeling requirements are anchored in the French Code de l 'Environnement, which goes into effect on January 1, 2022. Electrical devices and their packaging must also bear the Triman logo in this case. In addition, the crossed-out wheeled bin symbol remains in use.
As a result, Triman logo requirements apply to household packaging, textiles, shoes, furniture, tires, and paper products - as long as they can be recycled. Triman's logo will be applied to electrical devices and batteries in 2022, expanding its application area.
How do you proceed if you cannot apply the Triman logo?
The Triman logo is sometimes hard to place on products or packaging for online shops outside of France. This is the case, for example, when the retailer isn't a manufacturer himself and has no influence.
Also, the Triman logo image appears on the product page until January 2022. Alternatively, a special subpage can be created for this purpose, which, however, should also contain information about which products and packaging can be recycled along with the Triman logo. Therefore, even or especially if manufacturers or distributors are located abroad, this notice should also be displayed in French.
In 2022, references to Triman symbols and sorting guides will no longer be enough on website or product pages. Depending on the packaging size, the Triman / Sorting guide must be printed or stuck on it. If the packaging is less than 10 cm2, the Triman / Sorting guide can be included in the product instructions.
In packaging between 10 and 20 cm2, the Triman logo must be on the packaging and the sorting guide must include the Triman logo. A Triman and sorting guide must be printed or attached to packaging larger than 20 cm2.
The Triman can only be dematerialized and sorted if no other documents are included.
How do you attach the logos to your products?
To make sure your product has the right Info-Tri logo and information, you should first contact the eco-organizations that your product belongs to (e.g., Ecologic for EEE products, Re_fashion for textiles, household linen and shoes). Then, follow their specific guidelines for how to attach the logo and information.
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Next, the manufacturer must determine where the logo will be placed. As a result, the Triman logo and Info-Tri information must be included on the product itself, in the packaging, or, if not, in the accompanying documents.
Manufacturers tend to prefer the last option, but there are still no guidelines on whether the display can be affixed to the packaging or product when used on a document. As the list of documents to which the information will be added has not yet been determined, it is recommended to include the information in the product's manual.
Besides the obligation to affix the Triman logo to the product, packaging, or product documentation, the Info-Tri information must also be available in electronic format. Suppose there is no other document provided with the product or packaging, and the surface of the longest side of the product or packaging is less than 10 cm2. In that case, the manufacturer may publish a logo on its website as an exception.
The examples above show that the Triman logo and Info-Tri information are indivisible in theory. The Triman logo may, however, be affixed solely to a product or packaging when it has a surface area between 10 cm2 and 20 cm2, while Info-Tri information can be provided electronically. There are also options for affixing the Triman logo and Info-Tri information using stickers.
Information for consumers
A company must also provide information about the products' environmental characteristics and packaging to consumers in accordance with the AGEC Law. As outlined in Article 13, manufacturers and importers are required to provide consumers with information about the percentage of recycled materials, durability, compostability, reparability, reusability, recyclability, and presence of hazardous substances in packaging or formulas that exceed 0.1% by mass percentage.
Those substances are listed on the candidate list of substances of very deep concern under REACH, as well as those with a comparable level of concern, including endocrine disruptors, according to Legislative Decree No. 2021/1285.
A consumer must be able to access this information electronically during the purchase process.
Claims related to the environment
The French government wants to limit greenwashing. As of April 30, 2022, the AGEC Law prohibits the use of the claims ‘biodegradable’, ‘environmentally friendly’, and any equivalent claims. Even if these restrictions are not followed, brands have until January 1, 2023, to sell the products manufactured or imported before April 29, 2022.
French authorities are likely to publish a guide in the next few months clarifying which claims meet the definition of equivalent claims and how the EU Ecolabel is used in France.
There is a dedicated section of the Library of documents for documents related to labeling requirements - you can find it here.
Be sure to check with your importer in France if you are selling cosmetic products in France.
Hope this article can be helpful for your business. If you still have more questions concerning The Triman Logo and your packaging, you are welcome to leave a message here or contact us.
I have updated the user manual on LinkedIn "document" sector to help you better understand The Triman Logo. Kindly download the file and have a look whenever you need.
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