What are the labelling obligations in France and what do I need to do?

The French government has enforced a new regulation making it mandatory to print a Triman logo (displayed below), along with sorting instructions, on recyclable products and packaging sold to consumers in France. Though the legal basis has been in place since 2015, this is only now becoming mandatory. Deadlines are outlined below.

The main reason for including this symbol is to make it easier for consumers to understand how to sort their garbage. Products and packaging with the Triman logo on them should be collected in separate waste streams, such as paper or recyclable plastics. 

Up until now, displaying the logo on the website or product page has been sufficient, however this is no longer the case. The Triman logo must now be included directly on the product and / or packaging. 

Additionally, the format of the sorting information changes depending on the recycling scheme, as well as the date it comes into force. 

Anyone who makes recyclable products available in the French market. Hence, Zalando’s partners who makes products and / or packaging available in the French market for the first time (e.g. as manufacturer or importer) are obliged to take care that products and their primary (product) packaging that are sold to the French market are equipped with the correct Triman logo along with the relevant sorting instructions. 

If you are not using ZFS, you are responsible for your secondary (shipping) packaging to carry the Triman logo and relevant sorting instructions. 

If you buy products from an upstream supplier in France, your supplier will be obliged to ensure that the product and packaging is labelled with the Triman logo plus the relevant sorting instructions.

The mandatory marking is required on all recyclable products under the Extended Producer Responsibility (EPR) umbrella which are placed on the French market. This includes the following products:

• Furniture and furnishings

• Graphic papers

• Tyres

• Clothing textiles*

• Household linens

• Shoes*

• Household packaging*

• Electrical and electronic equipment*

• Batteries and accumulators*

• Products that generate specific non-point waste

• DIY and gardening products

• Photovoltaic panels

• Sports and leisure equipment*

• Medical waste and sharp medical equipment for home care

• Medication

• Pleasure and sports boats

• Decorative textiles

• Mineral or synthetic oils

• Toys*

• Chemical products

• Tobacco products

*Product categories highlighted are those carried by Zalando.

According to the new French law, two elements must now be displayed:

i. The Triman logo:

ii. Sorting information, which means “specifying the sorting methods or deposit of waste resulting from the product on the product, its packaging, or failing this, contained in other documents supplied with the product (manual, instructions for use, etc.)”. 

The new Triman format must be accompanied by sorting information, which can be in text or symbols, or both.

Since most products are not exclusively made for the French market, the country code FR should also be included. This is to avoid confusion for customers in other countries, where different sorting rules may apply.

Please see the following examples for how the Triman logo and sorting instructions for different product categories can be displayed:

The combination of the Triman logo and sorting instructions will need to be affixed on either:

• The product (stitched label, or by direct marking i.e. printing on the product)

• The primary (product) packaging (e.g. hangtag/cardboard label, box, pouch, etc.)

• Other documents provided with the product (e.g. instructions, manual, etc.)

For certain product categories, such as shoes, it is also possible to use stickers.

Since January 2022, it has been mandatory to include the Triman logo on all household primary and secondary packaging, meaning packaging used for products that end up in private households, as well as the boxes that protect those products when being sent directly to end customers via ecommerce.

Shipping cartons from the online trade, whether recyclable or not, must also bear the Triman logo. 

By September 8, 2022, all packaging must have had the Triman logo and sorting instructions. Between September 9, 2022 and March 8, 2023, manufacturers, importers or distributors were able to sell old packaging stocks. 

Since June 15, 2023 no packaging can be sold in France without the Triman logo and sorting instructions. 

The sorting instructions are different for each type of packaging, as the symbol (parcel, glass bottle, etc.) changes and multiple symbols may also be necessary for multi-part packaging. However, all household packaging must ultimately be disposed of in the "bac de tri" (French recycling bin). 

Please find more information from the recycling system you are connected to:

• Citeo

• Leko

• Adelphe

The inclusion of the Triman logo, alongside the relevant sorting instructions where required, will be mandatory on all clothing, household linen and footwear products sold in France from February 1, 2023. The compliance period was extended to August 1, 2023 for products manufactured or imported before February 1, 2023. 

Please find further information and examples here.

The Triman logo can be attached on the primary packaging, but please note that the packaging itself needs a Triman as well. This means that you will end up with two Triman logos on primary packaging.

Since December 15, 2022, all electrical equipment and batteries must carry the Triman logo and sorting instructions. Between December 16, 2022 to June 15, 2023 an additional period for stock clearance was granted. 

Since June 16, 2023, no electrical equipment or batteries may be sold in France without the Triman logo and sorting instructions.

Please find more information at the recycling system you are connected to: 

• Ecosystem 

• Ecologic

Please check which recycling system you are registered with. The recycling systems provide the necessary information (see the links above) and are also available for further questions. 

In addition, there are also third party providers who have specialised in advising on these compliance issues. An example can be found here.

High-quality recycling can only succeed if there are waste streams that are as well sorted as possible. For the first step, it is up to the consumer to put the specific waste along the correct recycling path. This is where the sorting instructions are intended to help the consumer. France thus wants to increase its recycling rate and support the circular economy.

Yes; the process outlined above is specifically for the French market. For this reason we strongly recommend including the country abbreviation for France (FR) in the sorting instructions to avoid confusion in other markets. 

You can find this in the examples provided above.