Recycling-Compliance Guide for Amazon FBA: The Triman Logo in France

Before selling on the French Amazon marketplace, you should be aware of the French Environment Code.

Like Germany – and any other EU member state for that matter (keyword: “EU Packaging Waste Directive”) – France has its own Packaging Law.

Sellers are forced by law to join a recycling scheme and pay a fee for packaging recycling.

Unlike anywhere else in the EU, France has taken it a step further: They have invented their own recycling symbol.

If you are not from France, chances are you have never heard of the Triman Logo. If you plan to sell products on Amazon.fr, it is crucial to know about it.

In this guide, we will provide you with all the information on recycling obligations in France.

What is the Triman Logo?

France has introduced its own symbol for recycling in the French Decree No. 2014-1577.

Anyone who sells recyclable products to French end-consumers from 1 January 2015 needs to mandatorily mark their products with the Triman Logo.

It may sound simple, but it is a lot more complex than that.

For instance, electronics must be marked with the “crossed-out garbage can” and therefore, may not be marked with the Triman Logo.

In general, the principle in the infographics below is mandatory.

This leaves us with the following product groups: textiles, shoes, tires, furniture, paper products, and household packaging.

These must be marked with the symbol – if they are recyclable.

Since every product on Amazon is packaged in one way or another, essentially anyone selling to France must be compliant.

What if my products cannot be marked with the Triman Logo?

It might be difficult for producers and retailers to always mark their products with this symbol, especially when selling to France from abroad.

In this case, the French law leaves another option: When the logo is not displayed on the product or its packaging directly, it is also possible to put it on one’s website.

In many cases this has proven to be the easiest solution for e-commerce.

For Amazon FBA sellers, options to edit the Amazon website are obviously limited. Thus, best practice would be to display the Triman Logo somewhere in the product description.

A short notice should ideally accompany this display on how the product and/or packaging can be recycled or what material it is made of.

Pro-tip: Since sustainability in e-commerce is now more relevant than ever, you can use this to your advantage.

Write a paragraph in your description of why your products are sustainable and recyclable and use it to SEO-optimize your product page on Amazon.

Even better if you use some extra-sustainable packaging, such as hemp-paper or 100% recycled material.

Since the Triman Logo needs to inform customers from France, it is enough to include it in your product description on Amazon.fr.

Please also make sure to write the note on recycling in French in order to be fully compliant; English-only would not be sufficient.

What are the consequences if I do not use the symbol?

The French authorities file a formal warning in case one does not follow the obligations.

On ignoring the warning, the French Environment Code stipulates financial penalties of up to 100,000 EUR or up to two years of imprisonment for non-compliance.

On top of displaying the Triman Logo, Amazon sellers must make sure that their products and packaging are rightfully licensed with a French recycling scheme.

There are different recycling schemes for the product groups mentioned above: textiles/shoes, tires, furniture, paper products and packaging.

As of July 2020, the French Ministry for Ecological and Inclusive Transition is also currently debating to reform the country’s waste recycling laws for online sales.

Thus, obligations for Amazon sellers may soon become even stricter.

Are there similar recycling-compliance regulations to be aware of in other EU countries?

Yes. For instance, in Spain, it is mandatory by law to print the well-known Green Dot Logo on any product packaging for consumer products.

In general, anyone selling on Amazon in Europe (Amazon.fr, Amazon.de, Amazon.es, Amazon.nl, Amazon.it, Amazon.co.uk) should be aware of the EU packaging waste legislation, as sellers are required to pay recycling fees for their packaging in most countries.

Since each country has incorporated the EU packaging waste directive in their own national law differently, researching one’s obligations in Europe can be expensive and tiresome.

Because there are so many different guidelines and these guidelines can be difficult to understand, it is best to hire a professional consulting agency for recycling compliance to ensure that you comply with the guidelines.

The digital compliance consulting service of ecosistant is a quick and easy way to determine what to do in each country and to always stay up to date with e-commerce recycling-compliance.

ecosistant

ecosistant

ecosistant is a Berlin-based consulting agency for recycling compliance. It specializes in packaging and product compliance, CSR, circular economy, and other topics related to sustainability in e-commerce.

Toby Fischer, MBA

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