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  • Avv. Paola Corte

Triman logo - EU Commission opens an infringement procedure for French environmental labelling rules

Infingement procedure

On February 15, 2023 the EU Commission opened an infringement procedure by sending a letter of formal notice to France (INFR(2022)4028) for its failure to address its labelling requirements concerning waste sorting instructions.


Triman logo

To be placed on the French market, household products belonging to an extended producer responsibility (EPR) scheme have to be materially labelled with the ‘Triman logo', a symbol informing that the product is the object of sorting rules, and the ‘infotri', information, specifying the methods for sorting.

The infringements

According to the press release:

  • The French authorities do not seem to have conducted a sufficient analysis of the proportionality of their policy choice as other suitable options, less restrictive of trade between Member States, are available.

  • France is also in breach of the notification obligations under the Single Market Transparency Directive (Directive (EU) 2015/1535) to the extent that the law was not notified to the Commission at a draft stage, prior to adoption. The provision of waste sorting instructions to consumers is currently not governed by harmonized EU rules. Several EU member states have adopted national rules in order to facilitate the sorting of packaging waste, including Italy.

The reasons

"National laws adopted in this field shall not create unnecessary burden internal market trade. In this context, the imposition of national-specific labelling requirements risks undermining the principle of free movement of goods and can lead to counterproductive environmental effects. Such measures can also lead to increased material needs for additional labelling and additional waste produced due to larger than necessary sizes of the packaging."

These are, in short, the same comments the Commission had made on the Italian rules for environmental labelling of packaging material, which had been notified via TRIS. The Commission had suggested that it should be possible to fulfill these labelling requirements not only by adding the information on pack, but also with other means, such as using websites and digital platforms.

What now?

France now has two months to address the concerns raised by the Commission. Otherwise, the Commission may decide to send a reasoned opinion to France.

Legal advice on environmental labelling

Studio Legale Corte is an Italian food law firm founded in 1921. We provide advice on food labelling, taking into account the case law and practice of the controlling Authorities. We have a network of experts in other EU countries and can help you manage the challenges of environmental labelling in multilingual labels.

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