Triman France – EU opening an infringement procedure against France

EU Commission launched a proposal for regulation on packaging waste labelling

The EU is opening an infringement procedure against France due to the new Triman logos and processes that have been implemented in France recently – saying that it endangers competition and acts as a market entry barrier.

The European Commission’s key concerns regarding the Triman obligation are the following:

  • The Triman obligation risks undermining the principle of free movement of goods and can lead to counterproductive environmental effects
  • The Triman obligation can also lead to increased material needs for additional labelling and additional waste produced due to larger than necessary sizes of the packaging.
  • The EU Commission estimates that France has not conducted a sufficient analysis of the proportionality of their policy choice as other suitable options, less restrictive of trade between Member States, are available.
  • France is in breach of the notification obligations under the Single Market Transparency Directive – failure to inform the EU Commission of the Triman project before it was legally imposed.


The French Government now has two months to address these concerns. If the French Government does not prove to be convincing, the European Commission has the possibility of sending a reasoned opinion and then of seizing the Court of Justice of the European Union.

Please note that this procedure does not suspend the Triman obligation at the moment. The Triman obligation and any other regulatory obligation can only be modified and/or suspended by the publication of a by-law or a decree.

It is equally important to note that the EU Commission has launched a Proposal for a Regulation on packaging and packaging waste in November 2022 which aims (among many other points) to clear up confusion on which packaging belongs to which recycling bin within the EU by harmonising the packaging labelling. It is proposed that every piece of packaging will carry a label showing what the packaging is made of and in which waste stream it should go. Waste collection containers will carry the same labels. The same symbols will be used everywhere in the EU.

Go4Recycling will keep you updated on the French Triman and general packaging and labelling issues  – feel free to contact us anytime.