Producers placing packaging, batteries and products on the market in France need to be aware that whilst the Green Dot logo has lost its mandatory status, the Triman Logo hasn’t.
The Triman logo is a mandatory, unified signage for end-of-life products created from the French Decree No.2014-15733 in order to harmonise the separate collection systems within France. This symbol was introduced to provide a more readily understandable symbol for citizens and consumers in France to ensure recyclable products are separated at end of life. In other words, if the product displays the Triman logo, the product should be recycled appropriately.
There are many Producer Compliance Schemes (PCSs) and collection organisations in France for different waste streams and over time they have developed their own communication methods, including different marking systems to inform consumers and guide waste sorting. In an effort to reduce any confusion, the Triman logo was introduced to specify separate collection possibilities to consumers, whilst also highlighting the recycling efforts of product vendors.
This Triman logo is not to be confused with the Green Dot logo (pictured left), which demonstrates compliance with local packaging legislation. More information about the Green Dot, why it’s not mandatory anymore and the impacts of this change can be found here.
What are the Triman requirements?
The mandatory marking is required on all recyclable products under the Extended Producer Responsibility (ERP) umbrella which are placed on the French market. This includes the following products:
- Furniture and furnishings
- Graphic papers
- Clothing textiles
- Household linens
- Household packaging
- Electrical and electronic equipment
- Batteries and accumulators
- Products that generate specific non-point waste
Household glass packaging and products for professional use are excluded, as well as products that exhibit the crossed-out wheeled bin symbol. As it may not always be feasible for all relevant products to display the Triman logo, the marking must instead be displayed on the packaging, use instructions, the product website or any other medium that accompanied the product.
A useful handbook which contains this information, including the graphic appearance requirements, is available in English for all UK producers distance selling into France.
Complications despite good intentions
There are some complications with the existence of the Triman logo, despite its good intentions.
The Triman logo was brought in to harmonise the communication between consumers and the different collection systems, but this has not been harmonised on a European level. The Triman logo hasn’t been enforced in any other European country which means the compatibility with global trade is questionable. In a statement from 2013, before the Triman was introduced, the Industry Association wrote that they “strongly believe that the Triman measure fragments the internal market, is a barrier to trade, is more strict than necessary and is not proportionate to meet the objective being pursued”.
A report was published in April 2005 by the Federal Union of Consumers (UFC) titled Que Choisir which investigated the effectiveness of the Triman Logo four months after implementation. Their research showed that out of the obligated products tested only 20% were Triman compliant. With online shopping continuously increasing in popularity, the UFC suggested that the websites selling these products may have been displaying the Triman logo online instead, as this is in accordance with the Decree (no. 2014-1577).
Unfortunately during another survey it was revealed that 64% of products, including those from large international companies, were failing to display the symbol anywhere. The survey also showed that 81% of producers use multiple logos and that the Triman logo was often incorrectly used on items that were made up of multiple material types, leading to consumer confusion.
One of the many symbols that are likely to be seen on obligated items is the Universal Recycling Symbol (seen left) that is, along with its variants, recognised all over the world. The symbol holds a very similar meaning to the Triman logo – the object this symbol is placed on is capable of being recycled – so it’s not clear why the Triman logo is also required as it is effectively duplicating the Universal Recycling Symbol.
Above all, the Triman is expensive for obligated producers to implement - having to change the design of products and packaging to meet the requirements of only one national market - and is potentially contradicting its aim of simplifying waste sorting activities. There is also a lack of enforcement on record for any non-compliance, so now that the Green Dot is voluntary, maybe the Triman’s mandatory status could also be reviewed?
How can Ecosurety help?
We can offer consultancy to help understand your requirements in Europe, with support solutions including impact assessments, compliance strategies, regulatory monitoring, data management and distributor compliance support.
Please contact our team of specialists if you are offering goods for sale in France or other European countries by emailing email@example.com or calling 0333 4330 370.
Marketing projects specialist
Ben joined the team at the beginning of 2015 and helps drive marketing communications and projects for Ecosurety, including project managing the launch of the Ecosurety Exploration Fund and website content development.