On July 17, 2025, the European Commission referred France to the Court of Justice of the European Union (CJEU).1 This move drew focus to the discrepancy between national environmental policies and single market rules, while also placing France's Triman recycling signage system, in place since 2015, under legal challenge.
This article explores the Triman signage system in France alongside the Commission's position, forthcoming EU harmonization measures, and practical compliance considerations for the industry.
Triman Signage System in France
To improve the efficiency of waste sorting and recycling, France introduced the Triman logo in December 2014 under Decree No. 2014-1577. The framework was further refined in 2021 through Decree No. 2021-835, which laid the foundation for the current recycling signage system for packaging waste. Under this system, all household products placed on the French market that fall under the Extended Producer Responsibility (EPR) scheme—with the exception of glass beverage containers—shall bear the Triman signage.
This signage is composed of the Triman logo and sorting information (Info-Tri). The logo indicates that the product and its packaging are collected separately for recycling, while the Info-Tri provides consumers with sorting instructions and identifies the appropriate collection points. The scope of application extends to a wide range of products, such as household packaging, electrical and electronic equipment, batteries and accumulators, furniture and furnishings, tyres, clothing textiles, household linens, shoes, and graphic papers.
Example of Triman Signage on a Sunscreen Lotion
(Source: ADEME, "Que faire de mes objets & déchets")
Regarding labelling requirements, the Triman logo and Info-Tri shall be displayed side by side on the product or its packaging. If this is not feasible, they can be included in other documents supplied with the product. In exceptional cases, such as when the largest side of the product or packaging is under 10 cm² and no additional documents accompany it, the logo and instructions may be presented electronically.
Additionally, the logo shall be single-colored, set against a contrasting background, and remain clearly visible, recognizable, comprehensible, and indelible, with proportions maintained. Companies under EPR obligations that fail to meet these requirements may face administrative penalties and impacts on product sales.
Commission's Position on France's Triman Signage
As France's Triman signage system, including its scope and detailed requirements, has become widely implemented, the Commission has scrutinized its impact on the single market, and raised several concerns regarding France's approach, as outlined below:
1) France's specific recycling signage requirements force legally produced and marketed goods from other member states to be adapted solely for the French market, thereby restricting the free movement of goods within the EU and constituting a measure with equivalent effect prohibited under Article 34 of the Treaty on the Functioning of the European Union (TFEU);
2) The requirements are deemed disproportionate, as France could have offered the necessary information to consumers in a manner that minimized trade restrictions between member states, especially before a unified approach across the EU was put in place;
3) France did not provide notification of the draft legislation to the Commission prior to adoption, breaching the notification obligations under Directive (EU) 2015/1535 (Single Market Transparency Directive).
To address these issues, the Commission issued a letter of formal notice in February 2023, followed by a reasoned opinion in November 2024. Given that France remained in breach of EU legislation, the Commission ultimately referred the case to the CJEU to protect the single market and ensure harmonized regulatory practices across member states.
Regulatory Trends for Waste Recycling Labels in the EU
At the EU policy level, measures are being developed to unify the regulation of recycling labels on packaging waste, supporting circular economy objectives and sustainable development. Under the EU's Regulation (EU) 2025/40 on Packaging and Packaging Waste (PPWR), all packaging will be required to carry a harmonized label indicating its material composition to facilitate consumer sorting. The corresponding implementing acts will establish the harmonized label and set out detailed specifications for labeling requirements and formats, which are expected to be adopted by August 2026. The harmonized label is anticipated to be enforced across member states by August 2028, or 24 months after the relevant implementing acts enter into force, whichever is later. This initiative will ensure that packaging products across the EU market display consistent recycling labels, reducing regulatory discrepancies between member states and improving consumer comprehension and recycling efficiency.
Until a decision is issued by the CJEU, products intended for French market shall continue to comply with the Triman recycling signage requirements, including both the Triman logo and the Info-Tri, to ensure they are legally marketable. Companies should also stay informed about the development of the EU's harmonized labelling framework, follow the upcoming harmonized label specifications, and make preparations for the transition to a unified EU label system by 2028.
