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Author: Alicia Sharp
Published: 30-07-2025

Triman Logo Dispute – French EPR Labelling vs. EU Harmonisation

In 2022, France introduced a mandatory environmental labelling requirement for certain consumer products, known as the Triman logo and accompanying Info-Tri sorting instructions. This measure affects a broad range of goods placed on the French market – including packaging, textiles, electronics, and gardening tools – and aims to inform consumers how to dispose of products properly via illustrated bin-sorting symbols.

Current Situation

While the French Government views the Triman system as a necessary tool to support consumer recycling behaviours and national circular economy goals, the European Commission has taken formal legal action against it. The main contention: the Triman requirement creates a barrier to the free movement of goods across the EU.

EU Position

The European Commission has argued that enforcing national labelling requirements like Triman before EU-wide harmonisation rules come into effect (August 2028) is disproportionate and non-compliant with the internal market framework. Specifically, Brussels is working to unify packaging labelling through upcoming EU Packaging and Packaging Waste Regulation (PPWR), which will require a single, harmonised label format across all EU member states – including sorting and material composition information.

As such, France has received two infringement warnings (in February 2023 and November 2024), with the case now escalated to the Court of Justice of the European Union (CJEU).

Industry Impact

For businesses operating across EU markets, the Triman label presents ongoing compliance and operational challenges:

  • Companies must alter packaging artwork and printing logistics specifically for the French market.
  • This creates non-trivial financial and administrative burdens, especially for manufacturers with multilingual or multi-market product lines.
  • According to European, a leading packaging industry association, this has resulted in "disproportionate costs of significant scale" for EU-based companies trying to meet France's unilateral requirements.

France’s Response

A French environment ministry spokesperson confirmed that the country intends to retain the Triman logo until the EU’s harmonised labelling framework becomes enforceable in 2028. The ministry noted that France will adapt its national legislation in due course but aims to maintain higher environmental ambitions in the interim.
This dispute reflects France’s broader pattern of "gold-plating" – implementing environmental regulations that go beyond the minimum requirements set by EU directives or regulations.

Takeaway for Business

  • Companies selling into France must continue to apply the Triman logo and Info-Tri instructions on affected product categories until 2028.
  • However, there is a clear regulatory shift coming, with the EU set to introduce a single labelling standard that could reduce cross-border packaging complexity.
  • We should anticipate eventual harmonisation but must maintain current labelling compliance in France to avoid risk of enforcement or penalties.
  • If we plan to expand our EPR coverage across the EU, this dispute is a strong signal of the growing need for agile packaging compliance strategies.