French packaging webinar presentation

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France: new obligations on packaging and its disposal for exporting companies

Pauline

and the French EPR system

Role and missions of the eco-organism

Organize the collection, sorting and management of household packagings and graphic papers, for a better performance and at the best cost

CITEO IS A COMPANY WITH A MISSION CREATED 30 YEARS AGO

BY CONSUMER GOODS AND DISTRIBUTION

COMPANIES

TO REDUCE THE ENVIRONMENTAL IMPACT OF THEIR PACKAGING AND PAPERS BY DEVELOPING SOLUTIONS TO REDUCE, REUSE, SORT AND RECYCLE.

Conduct R&D programmes to develop ecodesign, reuse, recycling and improve industrial processes

Inform and raise awareness among citizens to develop good sorting habits

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.

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

Functioning of the French EPR system

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

Functioning of the French EPR system

What are the specific obligation for the producers concerning household packaging EPR?

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

Obligations

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…

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…

French legislative framework for households packaging

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.

Article R.543-54 du code de 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

I am packaging manufacturer

I am an exporter

I am a distributor

2. Labelling obligations for households packaging

Triman logo & Sorting instructions: Regulatory requirements

2. Labelling obligations for households packaging

Triman logo & Sorting instructions: Regulatory requirements

✓ Packaging covered by the obligation B2B / B2C?

→ B2B packaging are not concerned however :

→ Only B2C packaging are concerned

• If there is a doubt that your packaging might be used by consummers we recommand you to put the info-tri and sorting instruction.

• Household packaging (B to C packaging)

Am I an household packaging ?

• HORECHA packaging --> catering packaging

✓ Packaging excluded from the requirement

Don’t forget all the responsability can be transfered by contract

• Glass beverage containers

Non-beverage glass packaging (mustard or spread jars, pickle jars, cosmetic 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

Cylindrical or spherical 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 less than 20cm² Triman and Info-tri can be dematerialized

The area of the largest side is between 20 and 40 cm²

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

Triman must appear on the packaging and Infotri can be dematerialized

2. Labelling obligations for households packaging

Triman 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

Inspection by public authorities - Citeo is not the authority that will enforce the fine

2. Labelling obligations for households packaging

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.

2. Labelling obligations for households packaging

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

Colour

You can choose to have the Info-tri in color or in monochrome.

The only point to respect is legibility.

Monochrome

Glass packaging

Packaging excluding glass Non-glass and glass packaging

Step by step for the creation of your Info-tri

Step 1

Choose of color

Step 2

Design of the Info-tri

Meaning of Triman = Separate collection exists

Triman

4 elements

4 elements

The tag with « FR » Components of the packaging

Paso 3

Step 3

Choose of format

Elección del formato

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 Step 3

Choose of format

1 Caps

Bottle of water Beer bottle

Bottle

2 Lids

Bottle

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

Example 1

Step by step for the creation of your Info-tri

There is the possibility of using 2 formats depending on size/space limitations. The principle of proportionality is applied (to ensure correct reading).

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

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.

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

2. Environmental claim:

Prohibited information- on pack

« 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.

Article R.541-223 environmental code

Mandatory information - on pack

« 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

Mandatory information - off pack

• Information on the incorporation of recycled material

• Information on recyclability

• Information on compostability

• Information on reusability

• Information on premiums and penalties

→ 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 of the decree

Come

→ January 1, 2022: “do not throw away in nature”

It does not concern the Info-tri

French labelling and mutual recognition principle

What is the mutual recognition principle?

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.

Directive (EU) 2018/852 on packaging and packaging waste

Draft FAQ by the French public authorities

Harmonisation :

✓ ensure better collection for recycling and reduce internal market barriers.

✓ 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?

French legislative framework for households

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 :

The Unique Identifier Number (UIN)

-> 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

FOCUS - Market places

✓ Since January 1, 2022, you have the obligation as an ecommerce seller to have a Unique Identifier Number (UIN)

Format of a UIN: FR245749 _ 01BJOR

The Unique Identifier Number (UIN)

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

Our tools and services

Online Guides

Our e-learning platform

Memo sheets

Detailed guides for household packaging and graphic paper can be downloaded from your customer area.

•Two training modules.

•Dedicated webinars available in replay.

✓ A regularly updated FAQ.

Tools to help you with the ecodesign of your packagings

A dedicated Customer Team at your service​