1. Why France Has Special Packaging Label Requirements
France has the most demanding recycling and packaging labeling requirements of any EU member state. Since January 1, 2022, all consumer products sold in France must display the Triman logo and Info-Tri sorting instructions on their packaging. This is not optional. It is not a "best practice." It is a legal requirement enforced by French authorities with real financial penalties.
The obligation applies to non-French sellers shipping to France — including e-commerce sellers based in the United States, the United Kingdom, or other EU countries. If your packaged consumer product reaches a French consumer, these labeling requirements apply to you.
Legal Basis
The Triman and Info-Tri requirements originate from the French Anti-Waste Law for a Circular Economy, commonly known as Loi AGEC (Loi n° 2020-105 du 10 février 2020). Loi AGEC is one of the most ambitious waste reduction laws in Europe. It introduced sweeping changes to France's Extended Producer Responsibility (EPR) framework, including mandatory on-packaging recycling information for consumers.
Enforcement is handled by the Direction générale de la concurrence, de la consommation et de la répression des fraudes (DGCCRF) — France's consumer protection and fraud enforcement authority. The DGCCRF has the power to inspect products in stores and online, issue fines, and order product withdrawals.
- The requirement covers all consumer product packaging — not just food or beverages
- Applies equally to domestic French brands and foreign sellers shipping into France
- E-commerce products shipped directly to French consumers from abroad are not exempt
- The Triman + Info-Tri obligation is separate from (and in addition to) any EU-wide packaging requirements
2. What Is the Triman Logo?
The Triman is a mandatory recycling symbol created by French law. It indicates that the product or its packaging is subject to a sorting and recycling obligation under France's EPR scheme. The symbol was originally introduced in 2015 by Décret n° 2014-1577, but Loi AGEC significantly expanded its scope and enforcement starting January 1, 2022.
Visual Design
The Triman logo is a stylized figure of a person with three curved arrows forming a recycling symbol. It is a distinctive, uniquely French mark — not to be confused with the Mobius loop, the Green Dot, or any other international recycling symbol.
Triman vs the Green Dot (Point Vert)
This is one of the most common sources of confusion. The Green Dot (Point Vert) — two interlocking arrows forming a circle — was historically displayed on packaging sold in France and across Europe. However, the Green Dot is no longer mandatory in France and does not indicate recyclability. It only indicates that the producer has paid a financial contribution to a packaging recovery scheme. Since January 1, 2022, the Green Dot has been replaced by the Triman as the primary recycling mark for the French market.
Technical Requirements
- Minimum size: 6mm in height — the Triman logo must not be smaller than this regardless of packaging size
- Must appear on the product packaging, or on the product itself if the product is subject to an EPR obligation
- Can be printed in black and white or in a single color — no color requirement
- Must be clearly visible and legible to the consumer
- The logo must be accompanied by the Info-Tri sorting instructions (they must appear together)
3. What Is Info-Tri?
Info-Tri (short for Information de Tri — sorting information) is the sorting instruction that must accompany the Triman logo on all consumer product packaging sold in France. While the Triman signals that the packaging is subject to recycling rules, Info-Tri tells the consumer exactly how to sort each component of the packaging for recycling.
Format and Content
Each packaging component must be listed individually with its sorting destination. The three main sorting destinations used in Info-Tri are:
- Bac de tri (recycling bin) — for packaging materials accepted in France's curbside recycling collection
- Ordures ménagères (general waste / household waste) — for materials not accepted in recycling
- Point de collecte (drop-off point) — for materials requiring special collection, such as glass
Example: Info-Tri for a Candle Product
Triman logo [displayed alongside]
- Pot en verre (Glass jar) → Bac de tri
- Boîte en carton (Cardboard box) → Bac de tri
- Film plastique (Plastic film) → Ordures ménagères
Example: Info-Tri for a Cosmetics Product
Triman logo [displayed alongside]
- Flacon en plastique (Plastic bottle) → Bac de tri
- Bouchon (Cap) → Bac de tri
- Étui en carton (Cardboard sleeve) → Bac de tri
- Notice papier (Paper insert) → Bac de tri
Language Requirement
Info-Tri instructions must be in French. English-only sorting instructions do not satisfy the requirement. You may include other languages alongside French, but the French text is mandatory. This is a frequent compliance failure for non-French sellers who assume that English or bilingual labeling is sufficient.
Placement
- The Triman logo and Info-Tri must appear together — they form a combined block
- They must be printed directly on the packaging or on a sticker affixed to the packaging
- For e-commerce, both the product packaging and the shipping packaging need Triman + Info-Tri
- If space is extremely limited, a URL or QR code linking to sorting instructions is permitted as a fallback — but the Triman logo itself must still appear physically on the packaging
4. CITEO Registration
CITEO is France's EPR (Extended Producer Responsibility) scheme operator for household packaging — the equivalent of Germany's dual system operators (like Der Grüne Punkt). Any producer or seller placing packaged consumer goods on the French market must register with CITEO and pay eco-contribution fees based on their packaging materials.
Who Must Register
- Any company that places packaged products on the French market — including non-French companies selling directly to French consumers
- E-commerce sellers shipping from abroad to France
- Companies importing products into France for resale
- Marketplace sellers (the seller, not the marketplace, is typically responsible unless the marketplace has assumed EPR obligations)
Registration Requirements
Registration with CITEO is mandatory before selling in France. You cannot legally place packaged products on the French market without being registered and paying your eco-contribution. The registration process is handled through CITEO's online portal.
- Eco-contribution fees are calculated based on packaging material type (plastic, cardboard, glass, metal, wood), weight, and the number of units placed on the French market
- Eco-modulation: Fees are adjusted based on the recyclability of your packaging — easily recyclable materials receive lower fees, difficult-to-recycle or non-recyclable materials receive malus surcharges
- CITEO provides the official Info-Tri generation tools and guidelines to help you create compliant sorting instructions
- Annual packaging declarations must be submitted to CITEO, reporting total packaging volumes by material type
- Website: citeo.com
Fees and Cost Structure
CITEO eco-contribution fees are generally modest for small sellers. Rates are published annually and vary by material. As a rough guide, fees typically range from a fraction of a cent to a few cents per packaging unit, depending on material type and weight. The fee schedule is available on CITEO's website, and they provide a calculator tool for estimating annual costs.
5. Which Products Must Display Triman + Info-Tri?
The short answer: all consumer products sold in France with packaging subject to EPR. The scope is deliberately broad. France's approach is that any packaging a consumer encounters should carry clear recycling instructions.
Packaging Types Covered
- Primary packaging — the immediate container of the product (jar, bottle, tube, tin, box)
- Secondary packaging — outer packaging used for display or grouping (cardboard sleeve, display box, blister pack)
- Shipping packaging — the packaging used to ship the product to the consumer (mailer, shipping box, void fill, protective wrap)
E-Commerce Implications
For e-commerce sellers, this is particularly important: both the product packaging and the shipping packaging need Triman + Info-Tri. If you ship a candle in a branded box inside a corrugated mailer with bubble wrap, each of those packaging components needs to be accounted for in the Info-Tri instructions.
Exemptions
The exemptions are narrow:
- Products consumed on-premises (e.g., restaurant or hotel use where the consumer does not take the packaging home)
- Some purely industrial or B2B products where the packaging never reaches a household consumer
- Reusable packaging in a formal deposit-return scheme (though even these may have specific labeling obligations)
If you are selling consumer goods online to French consumers, assume that no exemption applies to you. The safe approach is full compliance.
6. Penalties for Non-Compliance
Non-compliance with Triman and Info-Tri requirements carries meaningful financial penalties. France has moved beyond theoretical enforcement — the DGCCRF actively inspects both physical retail and online marketplaces.
Fine Amounts
| Violator Type | Maximum Fine | Notes |
|---|---|---|
| Individual (sole proprietor) | EUR 3,000 per product reference | Per distinct product SKU, not per unit sold |
| Company (legal entity) | EUR 15,000 per product reference | Can accumulate rapidly across a product catalog |
Enforcement Actions
- Marketplace enforcement: French authorities have begun checking products listed on Amazon.fr, Cdiscount, and other platforms. Non-compliant listings can be flagged and sellers contacted directly
- Product withdrawal: The DGCCRF can order products to be withdrawn from the French market until labeling is corrected
- Competitor-initiated complaints: Competitors can and do report non-compliant sellers to the DGCCRF. This is a common enforcement trigger, particularly in competitive product categories
- Marketplace liability: Under France's implementation of EU marketplace obligations, platforms may face their own obligations to verify seller compliance and may delist non-compliant products
The fines apply per product reference — meaning a seller with 50 non-compliant SKUs faces a potential exposure of up to EUR 750,000 for a company. While maximum fines are not always imposed, the per-reference structure means that even moderate penalties can become substantial for sellers with diverse product catalogs.
7. How to Create Compliant Labels
Creating Triman + Info-Tri compliant labels is a structured process. Follow these steps to ensure your packaging meets French requirements.
Step 1: Register with CITEO
Before anything else, register your company with CITEO through their online portal at citeo.com. You will need your company details, estimated volumes of packaging placed on the French market, and information about your packaging materials. Registration must be completed before you begin selling.
Step 2: Identify All Packaging Components
List every component of your product's packaging — primary, secondary, and shipping. For each component, identify the material type (cardboard, plastic, glass, metal, etc.) and whether it is recyclable in the French municipal recycling system.
Step 3: Use CITEO's Info-Tri Generator Tool
CITEO provides an online Info-Tri generator tool that produces the correct sorting instructions for each packaging component based on its material type. The tool outputs the proper French-language sorting destination for each component. This is the most reliable way to generate compliant Info-Tri text — do not attempt to create sorting instructions from scratch.
Step 4: Design the Triman + Info-Tri Block
- Place the Triman logo (minimum 6mm height) adjacent to the Info-Tri sorting instructions
- List each packaging component with its correct sorting destination in French
- Use clear, legible typography — the text must be readable by the consumer
- The Triman + Info-Tri block should be visually distinct from other packaging text and branding
Step 5: Place on Packaging
The Triman + Info-Tri block must appear on the physical packaging. If reprinting your existing packaging is impractical or cost-prohibitive in the short term, a sticker is an acceptable alternative. Many non-French sellers use adhesive labels as a practical solution while transitioning to reprinted packaging.
Step 6: Submit Annual Declarations to CITEO
Each year, you must submit a packaging declaration to CITEO reporting the total volume and weight of each packaging material type placed on the French market. This declaration is the basis for your annual eco-contribution fee calculation.
8. Triman vs Other EU Recycling Marks
Each EU member state has its own packaging and recycling labeling requirements. The Triman is unique to France — it does not satisfy other countries' requirements, and other countries' marks do not satisfy France's. Here is how they compare.
| Country | Requirement | Registration Body | Key Mark |
|---|---|---|---|
| France | Triman logo + Info-Tri sorting instructions | CITEO | Triman (person + 3 arrows) |
| Germany | LUCID registration + dual system contract | ZSVR (Zentrale Stelle) | LUCID number (no mandatory on-pack symbol) |
| Italy | Environmental labeling (etichettatura ambientale) | CONAI | Material codes + sorting instructions in Italian |
| EU-wide (future) | PPWR (Packaging & Packaging Waste Regulation) | TBD per member state | Harmonized EU marks (in development) |
Key Differences
- France (Triman + Info-Tri): Requires a specific visual logo (Triman) AND detailed sorting instructions in French on every consumer package
- Germany (LUCID): Requires registration in the LUCID database and a contract with a dual system operator, but does not mandate a specific on-packaging recycling symbol
- Italy (Environmental Labeling): Requires material identification codes and sorting instructions in Italian on packaging, but uses a different format than France's Info-Tri
- EU PPWR: The upcoming EU Packaging and Packaging Waste Regulation aims to harmonize packaging labeling across the EU. Once fully implemented, it may simplify multi-country compliance — but as of 2026, member-state-specific requirements like Triman still apply
The critical takeaway: compliance with Germany's LUCID system does not satisfy France's Triman requirement, and vice versa. If you sell in multiple EU countries, you need to address each country's packaging obligations individually until the EU PPWR harmonization is complete.
9. Compliance Checklist
Registration
- Register your company with CITEO before placing products on the French market
- Obtain your CITEO registration number / unique identifier (UDI)
- Set up annual packaging declaration reporting with CITEO
- Pay eco-contribution fees based on your packaging materials and volumes
Labeling
- Display the Triman logo on all consumer product packaging (minimum 6mm height)
- Include Info-Tri sorting instructions in French alongside the Triman logo
- List every packaging component with its correct sorting destination
- Use CITEO's Info-Tri generator to ensure correct sorting instructions per material
- Apply Triman + Info-Tri to primary packaging, secondary packaging, AND shipping packaging
- Use stickers if reprinting packaging is not immediately feasible
- Verify that Info-Tri text is in French (not English-only)
Ongoing
- Submit annual packaging declarations to CITEO
- Update Info-Tri when packaging materials or components change
- Monitor CITEO communications for changes to sorting rules or fee schedules
- Track the EU PPWR timeline for potential harmonization of packaging labeling
- Keep records of CITEO registration and annual declarations for at least 5 years
10. Common Mistakes
These are the errors that most frequently lead to non-compliance for sellers shipping to France. Each of them has resulted in enforcement actions or competitor complaints.
Using the Green Dot Thinking It Satisfies French Requirements
The Green Dot (Point Vert) does not satisfy France's Triman requirement. Since January 1, 2022, the Green Dot is no longer mandatory in France and does not indicate recyclability. Many sellers — particularly those who have sold in Europe for years — continue to rely on the Green Dot, assuming it covers French recycling labeling. It does not. The Triman + Info-Tri is a completely separate obligation.
English-Only Sorting Instructions
Info-Tri sorting instructions must be in French. Providing sorting instructions only in English, or in English alongside other languages but without French, is non-compliant. This is the single most common mistake for US and UK sellers shipping to France. The fix is straightforward — use CITEO's Info-Tri generator, which outputs French text by default.
Missing Info-Tri on Shipping Packaging
Many sellers apply Triman + Info-Tri to their product packaging but forget about the shipping packaging. For e-commerce orders shipped directly to French consumers, the mailer, shipping box, void fill, and protective materials are all packaging components that need to be covered by your Info-Tri instructions and declared to CITEO.
Not Registering with CITEO
Some sellers add the Triman logo to their packaging without registering with CITEO or paying eco-contributions. This is non-compliant on two fronts: you are both failing to meet your EPR financial obligations and potentially using the Triman mark without authorization. CITEO registration is mandatory before selling.
Assuming EU-Wide Compliance Covers France-Specific Rules
Compliance with EU-wide regulations (such as the EU Packaging Directive, REACH, or CLP) does not cover France's Triman + Info-Tri requirements. Similarly, compliance with Germany's VerpackG/LUCID system does not transfer to France. Each country's EPR and labeling requirements are separate national obligations. Until the EU PPWR fully harmonizes packaging labeling across member states, sellers must address each country individually.
Key Sources and References
Primary Sources
- Loi AGEC: Loi n° 2020-105 du 10 février 2020 relative à la lutte contre le gaspillage et à l'économie circulaire
- Triman Decree: Décret n° 2014-1577 (Triman signage)
- CITEO: citeo.com — Info-Tri tools and EPR registration
- DGCCRF Guidance: Direction générale de la concurrence, de la consommation et de la répression des fraudes
Additional References
- French Environmental Code: Code de l'environnement — Title IV: Déchets
- EU PPWR: EU Packaging and Packaging Waste Regulation