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Significant Changes to the Signage for Packaging and Recyclable Products

Toys and Juvenile Products, EE Restricted Substances, EMC, Cereals Grains and Pulses, Dairy and Eggs, Food Additives and Ingredients, Fruit and Vegetables, Meat and Poultry, Pet Food, DIY Tools and Hardware, HG Restricted Substances, Home Furnishings and Houseware, Sports and Leisure, Stationery and Office Supplies, Personal and Protective Equipment, Footwear and Leather Products, Home Textiles, Jewelry Bags and Accessories, SL Restricted SubstancesMarch 23, 2021

As part of its anti-wastage and circular economy law (AGEC Law), the French government wishes to reform the multiple affixed logos on packaging and on products to simplify sorting habits. Primary changes include the removal of the ‘Green Dot’ (‘Le Point Vert’) and the harmonization of the ‘Triman’ and ‘Sorting Info’ (‘Info-Tri’).

Removal of ‘Green Dot’ (‘Point Vert’) Suspended 

On November 30, 2020, a ministerial ruling was published to implement a penalty for logos which “could induce a confusion regarding the sorting rule.” The Green Dot, which has been mandatory on domestic packaging since 1992, uses a graphic of two or more coiled arrows in a circle. The problem is misinterpretation. 60% of consumers wrongly assume the Green Dot indicates that packaging can be recycled when its true meaning is that the manufacturer has paid its eco-contribution to an eco-organization.

Removal of the ‘Green Dot’ (‘Point Vert’) was originally supposed to come into effect on April 1, 2021. However, food, hygiene and cosmetics associations in the France have made representations to the Council of State contending, for example, that the change will present an unjustified obstacle to the free movement of goods within the European Union (EU). The Council of State has now suspended the date of enforcement in an order published on March 15, 2021. 

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‘Triman’ Guidelines and Sorting Info

Another document is expected to be released that will harmonize and clarify signage guidelines. The aim is to standardize the display of Triman (created 2015) and to complement it with simple information regarding sorting rules. These will be based on ‘Sorting Info’ (‘Info-tri’). A customizable version of the Triman is already being used voluntary and can already be found on over half of the packaging. 

Subject to the final approval, harmonized sorting signage should become mandatory from January 1, 2022. According to the Article 17 of the AGEC Law, this should affect all packaging and/or all documents provided with the product. The decree, which is currently being written, might restrict the possibility of displaying it on other documents.

Nonetheless, the display modalities (graphic chart, implementation file) are for now on standby due to a detailed notice from the European Commission. This reconsideration led to a delay in the approval of the new sorting guidelines, which should be done within two months by the Ministers in charge of the Environment and the Consumption. In case of ministerial rejection, eco-organizations will have one extra month to share a revised proposition that considers the comments from the public authority.

Once the signage is approved, the eco-organizations will publish it on their respective websites and will inform their members. The text states: “The use of the signage and of the information will apply to the manufacturers of relevant products (…) at the latest twelve months after this date.” 

The schedule for the availability of these new guidelines is therefore reliant upon the publication of the decree and the approval of the proposals from the eco-organizations by the public authority. Nonetheless, according to Citeo, the new Sorting-Info and all the related deliverables should be available during the second half of 2021.

Manufacturers will have until January 1, 2022 to affix the Sorting-Info and Triman to their packaging. The enforcement decrees might provide a sic month time limit for stock run-out for packaging that was placed onto the market before January 1, 2022. Moreover, the draft decree details that manufacturers can substitute the French signage with regulatory signage passed by another EU Member State.

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SGS Commitment to the Circular Economy

SGS is committed to the circular economy and is closely monitoring the evolution of France’s AGEC law and developments in other consumer product regulations as a complimentary service. Through a global network of laboratories, SGS provides a wide range of services, including specific country regulations, physical/mechanical testing, analytical testing and consultancy work for technical and non-technical parameters applicable to a comprehensive range of consumer products. After all, it’s only trusted because it’s tested.

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