Household Packaging and Labelling in France
WEBINAR: 28 NOVEMBER 2022
2 The Department for International Trade is
Our services are provided in over 100 markets throughout
Reduce MarketAccess Barriers RESPONSIBILITIES Attract and Retain Inward Investment Facilitate UK Exports Champion rules-based International Trading Systems DIT: Who we are We secure UK and global prosperity by promoting and financing international trade and investment; and championing free trade. OUR MISSION
a UK ministerial department formed in 2016 following the EU Referendum. It brings together foundations from the former UK Trade and Investment (UKTI).
the world.
3
Export Services UK Export Finance works to ensure no viable UK export fails for lack of finance or insurance while operating at no net cost to the taxpayer. It helps exporters access finance and insurance when there is a lack of private sector risk appetite or capacity We support the delivery of our Export Promotion strategy, ensuring that UK businesses have the tools they need to increase their exports and expand overseas. Export Support Service Getting more businesses exporting Supporting SMEs to overcome export barriers Market access Maximising legally assured terms of access for UK companies, identifying barriers and capitalising on opportunities International Trade Advisors can discuss expanding into new areas & develop an Export Action Plan Financial Support DIT Internationalisation Fund –businesses in England £ UK Export Finance
DIT
How to access this support Report trade barriers you are facing : Report a trade barrier - great.gov.uk Contact us: CommercialEnquiries.Paris@fcdo.gov.uk Adrienne SCOTT COX – Market Access Officer Stay informed: Register for our Newsflashes and Newsletter DIT France Newsletter - New Registration (great.gov.uk) Request tailored support : DIT Europe Trade Hub (qualtrics.com)
Turn the sound on of your computer Mute your microphone during the presentation Ask your questions in writing at any time, we will answer them at the end of the presentation Before starting
France: new obligations on packaging and its disposal for exporting companies
Webinar - November 28, 2022
Pauline Balaire –Regulatory Analyst Romane Colleu –
EU affairs advisor
Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
France: new obligations on packaging and its disposal for exporting companies
Citeo and the the French EPR system
What are the labelling regulatory obligations for households packaging?
How to comply to the French EPR scheme?
01 02 03
04
Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
Q&A
CITEO IS A COMPANY WITH A
30
CONSUMER
DISTRIBUTION COMPANIES TO REDUCE THE ENVIRONMENTAL IMPACT OF THEIR PACKAGING AND PAPERS BY DEVELOPING SOLUTIONS TO REDUCE, REUSE, SORT AND RECYCLE.
the collection, sorting and management of household packagings and graphic papers,
better performance
cost
reuse, recycling
and raise
sorting
Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
01. Citeo and the French EPR system
MISSION CREATED
YEARS AGO BY
GOODS AND
Role and missions of the eco-organism Organize
for a
and at the best
Conduct R&D programmes to develop ecodesign,
and improve industrial processes Inform
awareness among citizens to develop good
habits
01. Citeo and the French EPR system
Manufacturers and companies responsible for putting products on the market are required to finance or organize the management of waste for the end-of-life of their products.
In France, most companies have chosen to organize themselves collectively within the framework of ecoorganizations approved by the public authorities.
=> Citeo is a non-profit company
CITEO helps their clients to : involve them in the circular economy of their products (eco-design tools) pool and optimize processing costs related to different types of packaging and paper develop R&D and innovation programs to reduce the environmental impact of their packaging & paper
• Currently, 17 waste management channels operate according to this principle in France.
• To continue this movement, the anti-waste law for a circular economy (AGEC law) is adding new sectors to the principle of EPR (restaurants/hotel/coffeehouses, industrial waste, construction industry, construction, sanitary hygiene products, etc.)
• The majority of countries in the European Union and many other states around the world have adopted this system. Citeo
| French regulatory obligations for packaging | External diffusion
| 28/11/2022
Citeo and the French EPR system
Any company which put packaged products and/or graphic paper on the market must register to an ecoorganization like Citeo
Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion 01.
Functioning of the French EPR system
01.
Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
What are the EPR obligations for the Producers? Adopt an eco-design approach to products Support the networks of reuse Develop the recycling of waste from products Promote the extension of life of the products Provide or contribute to the prevention and management of the waste Reorganization and repair with structures of the social and solidarity economy
Obligations Objectives 01. Functioning of the French EPR system 2040 End of single-use plastic packaging 2025 20% reduction in single-use plastic packaging (of which 50% through reuse) 100% reduction in "unnecessary" single-use plastic packaging 100% recycling of single-use plastic Reduce End of certain single-use plastic products and packaging… Recycle Packaging must be recycled by 2030… Reuse 5% of reused packaging put on the market in France in 2023 and 10% in 2027… Consumer information Mandatory information on pack/off pack , Triman logo & Sorting instructions… What are the specific obligation for the producers concerning household packaging EPR? Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
01. Functioning of the French EPR system
Obligations Objectives
2040
End of single-use plastic packaging 2025
20% reduction in single-use plastic packaging (of which 50% through reuse)
100% reduction in "unnecessary" single-use plastic packaging
100% recycling of single-use plastic
Reduce
End of certain single-use plastic products and packaging… Recycle Packaging must be recycled by 2030… Reuse 5% of reused packaging put on the market in France in 2023 and 10% in 2027…
Consumer information
Mandatory information on pack/off pack , Triman logo & Sorting instructions… Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
French legislative framework for households packaging
Functionning of the French EPR system
What are the labelling regulatory obligations for households packaging?
How to comply to the French EPR scheme?
01 02 03
04
Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
Q&A
2. Labelling obligations for households packaging
Triman logo & Sorting instructions: Regulatory requirements ✓ Who is responsible for the labelling obligation ? All the producer
Producer means any person who professionally packages or has packaged his products with a view to putting them on the market, any importer whose products are marketed in packages or, if the producer or importer cannot be identified, the person responsible for first putting the products on the market.
R.543-54 du
de
I
I
I
am packaging manufacturer
am an exporter
am a distributor
Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
Article
code
l'environnement I am an importer in France I am selling products and packaging on a marketplace* I am an exporter to my corporate subsidiary in France
2. Labelling obligations for households packaging
logo & Sorting instructions: Regulatory requirements Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
Triman
2. Labelling obligations for households packaging
→ B2B packaging are not concerned however :
• If there is a doubt that your packaging might be used by consummers we recommand you to put the info-tri and sorting instruction.
Don’t forget all the responsability can be transfered by contract
Triman logo & Sorting instructions: Regulatory requirements ✓ Packaging covered by the obligation B2B / B2C?
→ Only B2C packaging are concerned
• Household packaging (B to C packaging) Am I an household packaging ?
• HORECHA packaging --> catering packaging ✓ Packaging excluded from the requirement
pickle
cosmetic
Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
• Glass beverage containers Non-beverage glass packaging (mustard or spread jars,
jars,
packaging,etc.) are covered these obligations.
2. Labelling obligations for households packaging
Triman logo & Sorting instructions:
Regulatory requirements
✓ When Triman logo and sorting instructions packaging be dematerialized ?
Small packaging
The area of the largest side is less than 10cm²
• Instruction manual : Triman and Info-tri can be affixed
• No instruction manual : Triman and Info-tri can be dematerialized
The area of the largest side is between 10cm² 20cm²
• Instructions manual : Triman is mandatory on the packaging and Info-tri can be affixed
• No instructions manual: Triman is mandatory on the packaging and Info-tri can be dematerialized
Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
Cylindrical or spherical packaging
The area of the largest side is less than 20cm² Triman and Info-tri can be dematerialized
The area of the largest side is between 20 and 40 cm²
Triman must appear on the packaging and Infotri can be dematerialized
2. Labelling obligations for households packaging
logo & Sorting instructions: Regulatory requirements ✓ Is there any penalty? • Up to 15K€/ for a company How will the penalty be applied ? Financial penalty per non-compliant product category
by public authorities - Citeo is not the authority that will enforce the fine Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
Triman
Inspection
2. Labelling obligations for households packaging
Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
Timeline for implementing the Triman logo and Sorting Instructions and deadlines for selling existing stock
2. Labelling obligations for households packaging
Timeline for implementing the Triman logo and Sorting Instruction and deadlines for selling existing stock
It is therefore possible to package and market a product without the sorting instructions marking after March 9, 2023 provided that: 1- the packaging was manufactured before September 9, 2022 ; 2- the person who packages the product has taken possession of this packaging before March 9, 2023, whether or not he has filled it à You have the right interpretation, it means that as long as you received the packaging to pack goods before March 9, 2023 then you are allowed to sell the packaging without the sorting instructions on the market.
Citeo | 28/11/2022 | French
for
| External diffusion
regulatory obligations
packaging
Labelling obligations for households packaging How does it work for product subject to several waste management channels Example for textile products 01.02.2022 01.02.2023 01.08.2023 Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
2.
Step by step for the creation of your Info-tri Step 1 Choose of colour Step 2 Design of the Info-tri Step 3 Choose of format You can choose to have the Info-tri in color or in monochrome. The only point to respect is legibility. Colour Monochrome Glass packaging Packaging excluding glass Non-glass and glass packaging Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
Step by step for the creation of your Info-tri Step 1 Choose of color Step 2 Design of the Info-tri Paso 3 Elección del formato Meaning of Triman = Separate collection exists Step 3 Choose of format 4 elements Triman 4 elements The tag with « FR » Components of the packaging Destination Text + pictogram Text only Pictogram only Bottle Bottle & cap Text + pictogram Pictogram only And / or And / or Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
Beauty cream jar (jar & lid in plastic) Beauty cream jar (jar in plastic & lid in metal) Marmelade jar (jar in glass and lid in metal) Example 2 Bottle Bottle Bottle of water Beer bottle Example 1 Step by step for the creation of your Info-tri 1 Caps 2 Lids Step 1 Choose of color Step 2 Design of the Info-tri Paso 3 Elección del formato Step 3 Choose of format Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
Step by step for the creation of your Info-tri
2 formats
size/space
proportionality
applied
reading). 1 Standard format 2 Compact format Minimum space Minimum space Step 1 Choose of color Step 2 Design of the Info-tri Paso 3 Elección del formato Step 3 Choose of format Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
There is the possibility of using
depending on
limitations. The principle of
is
(to ensure correct
The multi-country version of the Sorting Info
If you want to go further and anticipate regulatory developments in certain countries in which you export your products, you can also add the sorting rules of other countries thanks to the «multicountry» version of the Info-tri. This may be the case if you export your products to Italy, Portugal or Slovenia, which are considering making the sorting rule mandatory on packaging without imposing the format
Examples
The first block mentions the sorting rule for France. The “FR” acronym is mandatory.
The second block mentions the sorting rule for countries in which it differs. In color version, this block is always treated in black and white.
All these versions are also available in monochrome
If you want to give the sorting rule for France and other countries in which the rule is identical, you can add tabs but the “FR” should always be first. Moreover, since the benchmark colours are not necessarily the same in France and abroad, the Info-Sorting must be designed in monochrome in order not to mislead foreign consumers.
metal
Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
« Compostable »
For plastic products and packaging whose compostability can only be achieved in industrial units.
« Biodégradable » ; « environnemental friendly » or other equivalent statement
For all products and packaging.
« Do not throw away in nature »
For plastic products and packaging whose compostability can only be achieved in industrial units
Compliance with mandatory information off pack if voluntary marking
• Information on the incorporation of recycled material
• Information on recyclability
• Information on compostability
• Information on reusability
• Information on premiums and penalties
2. Environmental claim: Prohibited information- on pack
force
Come into force Come into force → January 1, 2022: compostable → April 30, 2022 Stock clearance period: until January 1, 2023 for products manufactured or imported before April 29, 2022. Article 3
the decree → January 1, 2022: “do not throw away in nature” Dates Turnover Unit of products 01/01/2023 + de 50 M Min 25 000 units 01/01/2024 + de 20 M Min 10 000 units 01/01/2025 + de 10 M Min 10 000 units Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion It does not concern the
Article R.541-223 environmental code Come into
Mandatory information - on pack Mandatory information - off pack
of
Info-tri
French labelling and mutual recognition principle
What is the mutual recognition principle?
Directive (EU) 2018/852 on packaging and packaging waste
The mutual recognition principle ensures market access for goods that are not, or are only partly subject to EU harmonisation legislation.
It guarantees that any good lawfully sold in one EU country can be sold in another.
Harmonisation :
✓ ensure better collection for recycling and reduce internal market barriers.
Draft FAQ by the French public authorities
✓ Proposed measures :
- Harmonization of sorting deposits.
- Harmonization of markings on re-use.
- Harmonization of recycled content markings.
Would an information with another pictogram directly informing the consumer about the sorting gesture can replace the Info-tri marking?
Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
French legislative framework for households packaging
01 02 03
European objectives for packaging
What are the labelling regulatory obligations for households packaging?
04
Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
How to comply to the French EPR scheme?
Q&A
How does the contract with Citeo work ?
At the beginning of each year (january / february) :
• Do the declaration of your packaging / papers for the previous year • Pay the eco-contribution
3 types of declaration are available depending on the number of packaged products you put on the french market :
Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion The Unique Identifier Number (UIN)
places ✓ Since January
2022, you
the
-> This UIN proves that you are registered with an ecoorganization for a specific EPR -> You must provide your UIN’s to your marketplaces, so that they don’t charge you with the amount of the contributions -> You must include this UIN on your general terms and conditions and on any contractual document Format of a UIN: FR245749 _ 01BJOR
FOCUS - Market
1,
have
obligation as an ecommerce seller to have a Unique Identifier Number (UIN)
The Unique Identifier Number (UIN)
Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
How do I get a UIN ? You need to register to an ecoorganisation, like CITEO CITEO will then provide you with your UIN within a few days How to register at Citeo ? https://clients.citeo.com/en/public/repchoice Packaging EPR Graphic Paper EPR Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
A few estimation costs per
0.69c€ 0.21c€ 1.21c€ 0.22c€
0.34c€ 1.62c€ 0.78c€
0.68c€ 0.34c€ 0.69c€ 0.78c€
much does the
cost ?
How
eco-contribution
product category
declaration example costs Eg. : I sell 50000 pieces of clothes to France per year The price is 50000 x 0,0050 = 250€ Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
Declaration by CSU Sector-specific
Online Guides
Detailed guides for household packaging and graphic paper can be downloaded from your customer area.
Our e-learning platform
•Two training modules.
•Dedicated webinars available in replay.
✓ A regularly updated FAQ.
Memo sheets
Our
Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
tools and services
Tools to help you with the ecodesign of your packagings
dedicated Customer Team at your service
A
A QUESTION ? NEED AN ADVICE ? Packaging or paper, our service answer you from Monday to Friday 0 808 80 00 50 Free service + cost of a call
Citeo | 28/11/2022 | French regulatory obligations for packaging | External diffusion
A REQUEST BY EMAIL ? CONTACT OUR SERVICE : CITEO@CITEO.COM
Carlos de LOS LLANOS Scientific Director
carlos.delosllanos@citeo.com Mobile : + 33 6 80 20 49 35
50 boulevard Haussmann 75009 Paris
+ 33 1 81 69 06 00 contact@citeo.com
Thank you!
Thank you !