The EU packaging label and the French Triman: where things stand

What goes on a pack sold in France, now and later

Element	Today in France	Under PPWR
Sorting instruction	Triman and Info-tri on household packaging French Ministry of Ecologica	Harmonised EU label, from 12 August 2028 at the earliest EUR-Lex
Material composition	Not required by French EPR	Part of the harmonised label
Reusable packaging marking	Not required	QR code and label for reusable packaging
Deposit-return marking	Not applicable in France today	Harmonised label where a scheme exists
Traceability identifier	Not required by French EPR	Batch or type number and manufacturer details, since 12 August 2026 EEuropean Commission

Practical rules for print runs

• Keep the Triman and Info-tri on household packaging sold in France until the EU label applies. AAdelphe
• Add the traceability identifier now: it applies since 12 August 2026. EEuropean Commission
• Plan artwork changes for the EU label once the implementing act is published: the label applies 24 months later at the earliest. EUR-Lex
• The Commission's case against France over Triman does not suspend it. BBanque des Territoires

Triman products

Product	Triman?
Household packaging	Yes French Ministry of Ecologica
Textiles	Yes
Electronics	Yes, with the crossed-out bin ADEME
Glass bottles	Info-tri only AAdelphe
Professional packaging	No ADEME

Your first year in France

When	What	Source
Before the first French sale	Representative appointed, IDU per stream, IDUs in every marketplace ADEME	Légifrance+1
On every household pack	Triman and Info-tri	French Ministry of Ecologica
From 1 January 2027	Professional packaging scheme, if you sell to businesses	ADEME
Early the following year	Declaration of the previous year's French sales	Citeo
All year	Eco-contributions at published rates, no markup	Léko

Who is the producer

Set-up	Producer for French EPR
You sell to French customers and ship from abroad	You Légifrance
Your stock is in a French or EU warehouse, sold in your name	You
A French distributor imports and resells	The distributor
A marketplace buys and resells as retailer	The marketplace
A retailer sells your goods under its own brand	The retailer

Recycled content from 2030

EUR-Lex

Sanctions in France

Failure	Sanction	Source
Not meeting EPR duties after formal notice	Up to €1,500 (individual) or €7,500 (company) per unit or tonne concerned	Légifrance
Still not complying	Daily penalty up to €20,000	Légifrance
Register and IDU failures	Fine up to €30,000	Légifrance
No IDU on a marketplace	The platform blocks the listing or pays in your place	Ministère de l'Écologie

Who runs what in France

• Household packaging and graphic paper: Citeo, Léko and Adelphe are the approved eco-organismes. Citeo+2
• Regulation (EU) 2025/40 is the text that sets this duty. EUR-Lex
• It replaces Directive 94/62/EC from 12 August 2026, with some transitional exceptions. EUR-Lex

Short version

Keep printing the Triman and sorting instruction for France. The EU label does not apply before 12 August 2028, and the act defining it was reported as not yet adopted in late September 2026. A court case against the French rule is pending and does not suspend it. Légifrance

The timeline

Date	What	Status
9 September 2022	French Triman and sorting instruction for household packaging French Ministry of Ecologica	In force
17 July 2025	Commission refers France to the Court of Justice over Triman and Info-tri BBanque des Territoires	Pending
12 August 2026	Deadline for the Commission's act on the harmonised label, Article 12(6) EUR-Lex	Reported missed
12 August 2028, or 24 months after the act if later	Material-composition label, Article 12(1) EUR-Lex	Ahead
12 February 2029, or 30 months after the act if later	Reusable packaging marking, Article 12(2) EUR-Lex	Ahead

Is the implementing act out?

Not when last reported. Trackers checking EUR-Lex in late September 2026 found no adopted act, and one reports that the Commission registered a draft on 14 September 2026 with adoption planned for the fourth quarter: a summary. These are secondary sources. Check EUR-Lex before you commit artwork. Because the dates run from the act if later, a late act moves them.

The case against France

The Commission argues that mandatory Triman and Info-tri signage obstructs the free movement of goods and that less restrictive options exist. It sent a letter of formal notice in February 2023 and a reasoned opinion in November 2024 before referring France. BBanque des Territoires We know of no ruling yet. Until there is one, the duty stands: article L. 541-9-3 still applies. Légifrance

The two-timeline trap

• Dropping Triman early because Europe is harmonising. It is required today. Légifrance
• Printing an EU label before it exists. There is no final design to print.
• Assuming the 2028 date is fixed. It moves if the act is late.
• Green claims. Article 12(8), on labels that could mislead about sustainability or waste, is reported to apply already. Review them now.

What to do now

1. Label for France as today: the rules.
2. Use stickers where you can, so a later change does not strand printed stock.
3. Leave room on new artwork.
4. Check EUR-Lex each quarter.
5. Hold your material data per pack: the EU label will need it, and so does your declaration.