France EPR Packaging Labels
This document covers all mandatory packaging labels for the French market, material recycling codes, and the upcoming EU Packaging and Packaging Waste Regulation (PPWR — Regulation EU 2025/40), which applies from August 12, 2026. It is relevant to French manufacturers, importers, e-commerce sellers, and all companies placing packaged goods on the French market.
Currently mandatory labels (in force now)
All labels in this section are legally required today for packaging placed on the French market under France’s EPR framework (Responsabilite Elargie du Producteur) and the AGEC Law (Law 2020-105).
| Label / Symbol | Description |
|
Triman logo |
Required on all packaging subject to French EPR. Signals that the item must be sorted and recycled through the national EPR system. Must appear on the product, its packaging, or the online product page. Applies to packaging, EEE, textiles, and batteries. |
|
Info-tri sorting instruction |
Consumer sorting guidance displayed alongside the Triman logo. Instructs consumers on which bin or collection point to use for each packaging component. Must be in French. Producers must also display this on online product pages. |
|
Material recycling code (e.g. PAP 20) |
Material identification codes indicate the packaging material type and enable correct sorting. PAP 20 = corrugated cardboard. Other examples: PET 1, HDPE 2, ALU 41, GL 70. See Section 2 for the full list. |
|
Crossed-out wheeled bin |
Required on all EEE products and batteries. Indicates separate collection at end of life. From August 18, 2025, must cover at least 3% of the area of the largest side on batteries (max 5 x 5 cm). |
Triman + Info-tri: where must they appear?
The Triman logo and Info-tri must be affixed, printed, or engraved on the product itself, its packaging, or — for e-commerce — on the product’s online page. They must be visible, legible, and indelible. Missing the Triman logo carries penalties of up to €15,000 per infraction with daily penalties up to €20,000.
Material recycling codes — full reference
These codes identify the packaging material and must appear on packaging to assist consumers and recyclers with correct sorting. They are usually displayed as a recycling symbol with the code number and abbreviation.
Paper and cardboard (PAP)
| Code | Material | Common uses |
 |
Corrugated cardboard | Shipping boxes, e-commerce outer packaging |
 |
Other cardboard / paperboard | Folding cartons, cereal boxes, product boxes |
 |
Paper | Bags, wrapping paper, tissue paper, leaflets |
Plastics
| Code | Material | Common uses |
 |
Polyethylene terephthalate | Drink bottles, food trays, blister packs |
 |
High-density polyethylene | Detergent bottles, milk jugs, caps |
 |
Polyvinyl chloride | Cling film, rigid packaging (restrictions apply) |
 |
Low-density polyethylene | Plastic bags, shrink wrap, squeezable bottles |
 |
Polypropylene | Yoghurt pots, bottle caps, margarine tubs |
 |
Polystyrene | Food containers, cups (recyclability concerns) |
| OTHER 7 | Other / mixed plastics | Multi-layer, composite plastics |
Glass, metals, and other materials
| Code | Material | Common uses |
 |
Clear glass | Bottles, jars |
 |
Green glass | Wine bottles, glass jars |
 |
Brown / amber glass | Beer bottles, medicine bottles |
 |
Aluminium | Cans, foil lids, aerosols |
 |
Steel | Metal tins, food cans, steel aerosols |
| C/PAP 80-84 | Paper / cardboard composite | Drink cartons (Tetra Pak-type) |
EPR registration — who must comply
France’s EPR system requires any entity that places packaged products on the French market to register with an approved Producer Responsibility Organisation (PRO) and obtain a membership number. There is no minimum volume threshold.
| Who is affected | PRO to join | Key obligation |
| French manufacturers | CITEO (main household), LEKO (alternative), Adelphe (wine/spirits) | Register, declare packaging weight and materials annually |
| EU importers | CITEO or LEKO | Same obligations as French manufacturers |
| Non-EU distance sellers / e-commerce | CITEO or LEKO (via authorised rep) | May appoint an authorised representative in France |
| Online marketplaces | Not a producer (unless own-brand) | Must verify seller compliance |
E-commerce and shipping packaging
Online sellers shipping packaged goods to French customers are considered producers, regardless of where the company is based or where goods are shipped from. Shipping boxes and e-commerce outer packaging (PAP 20) are included and must be declared. Both Triman + Info-tri labels are required on all packaging components.
PPWR — EU Packaging Regulation (August 12, 2026)
Regulation EU 2025/40 — Packaging and Packaging Waste Regulation (PPWR)
The PPWR entered into force on February 11, 2025 and applies directly in all EU countries — including France — from August 12, 2026. No national transposition is required. It replaces the former Packaging Directive (94/62/EC) and harmonises packaging rules across the EU. Products placed on the market or labelled before June 14, 2026 may generally be sold until stocks are exhausted.
What changes on August 12, 2026
| Obligation | Detail |
| Declaration of Conformity (DoC) | Every packaging type must have a signed EU Declaration of Conformity and a complete technical file. The brand owner or importer is responsible. Request documentation from your packaging supplier now — there is no grace period. |
| PFAS ban (food-contact) | Per- and polyfluoroalkyl substances (PFAS) are banned in food-contact packaging above specified concentration limits. Review food-contact materials immediately. |
| Heavy metal limits | Lead, cadmium, mercury, and hexavalent chromium restricted to 100 mg/kg total in any packaging component. Verify with your packaging manufacturer. |
| Packaging minimisation | Packaging must be designed to minimise weight and volume. Empty space is restricted. Document why current dimensions are necessary for compliance audits. |
| EPR scheme alignment | EPR fees must be modulated based on recyclability, recycled content, reusability, and presence of substances of concern. France’s CITEO/LEKO fees will be updated accordingly. |
What is coming after August 2026
| Deadline | Obligation |
| Aug 2026 | Commission must publish methodology for material composition identification (needed for 2028 pictograms) |
| Aug 2026 | Battery QR codes mandatory — all batteries must carry a QR code |
| Sep 2026 | Green claims crackdown — vague claims such as ‘eco-friendly’, ‘sustainable’, ‘planet-friendly’ prohibited unless substantiated and certified |
| 2027 | Mandatory refill options for takeaway packaging. National producer registers must be operational in each EU country. |
| Aug 2028 | Harmonised EU-wide sorting pictograms mandatory on all packaging — same symbols on packaging and public waste bins across all 27 EU countries. Replaces fragmented national labels (including, eventually, the French Triman logo). |
| Jan 2028 | Design-for-recycling delegated acts define recyclability grade thresholds |
| 2030 | All packaging must achieve minimum recyclability grades. Minimum recycled plastic content targets. Certain packaging formats restricted or banned. |
| 2035 | Proof that packaging materials are actually being recycled at scale |
Triman vs future EU harmonised label — transition plan
France is currently the only EU country to mandate a specific recycling symbol (Triman). The PPWR aims to replace all national symbols with a single harmonised EU label by 2028. Here is how the transition works:
| Period | France requirement | EU PPWR requirement |
| Now to Aug 2026 | Triman + Info-tri mandatory. Material codes mandatory. | PPWR not yet in force for labelling. Prepare DoC. |
| Aug 2026 to Aug 2028 | Triman + Info-tri still mandatory. Material codes required. | DoC, chemical limits, minimisation in force. Commission publishes harmonised pictogram specs. |
| Aug 2028 onward | Transition to harmonised EU labels (exact date TBC by French authorities). | Mandatory EU-wide sorting pictograms. Same symbols across all 27 member states. One label for the whole EU. |
Design advice for packaging artwork teams
When redesigning packaging now, allocate space for: (1) Triman + Info-tri — required today; (2) a QR code for digital product information — required by 2026-2028 depending on product type; (3) the future harmonised EU pictogram — finalised by August 2026, mandatory by August 2028. Building these elements into your next design cycle avoids costly reprints.
Full compliance timeline
| Now (2026) | Triman + Info-tri + material codes required All packaging placed on the French market must display the Triman logo and Info-tri sorting instruction (in French) alongside appropriate material recycling codes. EPR registration with CITEO or LEKO is mandatory. |
| June 14, 2026 | Sell-off deadline for pre-PPWR labelled stock Packaging placed on the market or labelled before June 14, 2026 may generally continue to be sold until stocks are exhausted under sell-off rules. |
| Aug 12, 2026 | PPWR core obligations — DoC, PFAS ban, minimisation Declaration of Conformity mandatory for every packaging type. PFAS ban in food-contact packaging. Heavy metal limits (100 mg/kg). Packaging minimisation obligations active. Commission must publish harmonised pictogram methodology. |
| Aug 18, 2026 | Battery QR codes mandatory All batteries must carry a QR code. For industrial batteries (>2 kWh) and EV batteries this links to the Digital Battery Passport from February 2027. |
| Sep 27, 2026 | Stricter green claims rules Vague environmental claims (‘eco-friendly’, ‘sustainable’, ‘planet-friendly’) prohibited unless substantiated. Eco-labels must meet defined criteria and be certified by an independent third party. |
| 2027 | Producer registers + refill rules National producer registers must be operational in each EU member state. Mandatory refill options for takeaway packaging types. |
| Aug 12, 2028 | Harmonised EU sorting pictograms mandatory Standardised EU-wide material composition pictograms replace fragmented national labels. Same symbols appear on packaging and public waste bins across all 27 EU countries. Triman to be superseded (exact French transition date TBC). |
| 2030 | All packaging must be recyclable Minimum recyclability grades enforced. Minimum recycled content targets for plastic packaging. EPR eco-fees modulated against recyclability grades. |
Penalties for non-compliance
| Infraction | Maximum penalty |
| Missing Triman logo on packaging | Up to €15,000 + €20,000 per day |
| Missing UIN on EEE products (per unit) | Up to €7,500 per unit |
| Failure to register with a PRO | Up to €100,000 |
| Missing UIN on invoices / documentation (textiles) | Up to €30,000 |
| Non-compliant packaging on market after Aug 12, 2026 | Market withdrawal + national authority fines |
| Unsubstantiated green claims (from Sep 27, 2026) | Enforcement under French consumer law |
| Incorrect material classification or underreporting | ADEME audit fines, potential contract termination by PRO |
Action checklist — what to do now
Immediate (before August 12, 2026)
- Confirm EPR registration with CITEO, LEKO, or Adelphe and obtain your membership number
- Ensure all packaging displays the Triman logo and Info-tri sorting instruction in French
- Apply correct material recycling codes (PAP 20 for corrugated boxes, PET 1, ALU 41, etc.)
- Request a Declaration of Conformity and technical file from your packaging supplier for every packaging type
- Audit food-contact packaging materials for PFAS and verify heavy metal limits with your manufacturer
- Review packaging dimensions for minimisation compliance — document justifications where necessary
- Review all environmental marketing claims — remove or substantiate vague terms before September 2026
Near-term (2026–2028 preparation)
- Allocate space for QR codes in packaging artwork — required for batteries from August 2026
- Monitor the European Commission’s harmonised pictogram specifications (expected by August 2026)
- Plan artwork redesign to incorporate EU harmonised sorting pictograms for the 2028 deadline
- If selling from outside France, appoint an authorised representative to manage EPR and PPWR obligations
- Submit annual EPR declaration to your PRO before the reporting deadline (usually Q1 each year)
