In France, there will be some relevant changes as part of the Circular Economy Act (Loi AGEC) passed in February 2020. These are now being successively implemented and you could also be affected by them if you place packaging, electrical appliances or batteries on the market in France.
From 1 April 2021, the "Green Dot" labelling will gradually disappear from all packaging in France. Packaging that still uses the "Green Dot" from then on will incur a penalty payment of 100% of the licence fee in the future. This means that the standardised disposal fee in France (depending on the material and packaging unit) will be doubled in the event of a Green Dot fee surcharge.
For packaging produced or imported before 1 April 2021, there is a transitional period of 18 months without a penalty fee (until 30/09/2022).
Packaging that is additionally placed on the market in Spain and Cyprus (where a Green Dot labelling is obligatory by law) is exempt from the penalty until 1 January 2022; thereafter, there is a transitional period of 12 months for such packaging. Once this period has elapsed, a penalty payment of 100% of the disposal fee will also be incurred for this packaging - if the "Green Dot" is still used.
In France, a legal labelling obligation with the Triman logo has already existed since 2015 for packaging and products that are collected separately and are subject to extended producer responsibility. It is expected that from 1 January 2022, in connection with the labelling with the so-called Triman logo, a uniform waste separation instruction will also be required by law.
Starting then, additional separation information must be placed on the packaging, Instruction manual or the product itself.
From 01/01/2022, these regulations will probably also apply to electrical appliances and batteries placed on the market in France.
Please note: Due to an ongoing notification procedure at EU level, there may still be changes in terms of content or timing. According to the information available to us, however, the corresponding regulation should be published by the middle of the year at the latest.
The Agency for Environment and Energy ADEME, as a government agency, has published a very detailed guide on the Triman logo with all the important information, which you can view at the following link.
Should you require additional information on this topic, our team will be happy to assist you. Please feel free to contact us for this purpose. We look forward to the exchange.