10 July 2015
Triman Mark User’s Handbook Published to Assist Manufacturers Placing Consumer Products on the French Market
Suppliers who place a recyclable product that is subjected to extended producer responsibility on the French market are required, as of 1 January 2015, to affix a common mark onto their products, or else onto the packaging, instructions, or any other medium (including paperless). This is the case, unless the product is exempted. The mark is intended to inform the consumer about the recyclability of the product.
The French authority, ADEME (Agence de l'Environnement et de la Maîtrise de l'Energie) has published a “user’s handbook”, setting out detailed guidelines which will help Hong Kong companies familiarise themselves with the new Triman mark Decree, as well as the practicalities relating to affixing the mark on products that fall within its scope. Some useful examples, concerning e.g. clothing and shoes, are also provided.
The Triman mark is a visual illustration to indicate to users that the product (including packaging) is subject to a specific sorting instruction for recycling. The mark is to be affixed on all recyclable products that fall under a specific sorting instruction, and those that are covered by Extended Producer Responsibility, but excluding electrical and electronic equipment, batteries and accumulators, and other specific waste products. These categories are subject to other specific signage rules under European regulations.
The Triman mark may appear in any colour, but must be a single colour on a contrasting background, so as to be visible, legible, clearly comprehensible, and indelible. The supplier must avoid affixing it onto areas that are not visible to the consumer at the time of the sorting. Other affixing requirements include the following:
- The mark must in no way be separated, blocked or hidden by other signs or images. In the case of smaller products, the mark must not be reduced to less than 0.6x0.6cm.
- The mark cannot be barred or crossed out.
- It cannot in any way be a part of indications (e.g. images or signs) that contradict the mark or would be likely to confuse the consumer at the time of waste-sorting.
Hong Kong manufacturers should be aware that the Triman mark is not mandatory for household glass containers. To fall within the scope of the Triman mark, a product (or product packaging) must meet the five following criteria:
1. The product must be subject to Extended Producer Responsibility (EPR). The list of EPR sectors are as follows:
- Furnishing items (household and professional)
- Graphic papers (household and assimilated)
- Textiles, linen and footwear (household)
- Household packaging
2. The product must not already be subject to specific waste markings (e.g. crossed-through waste bins). The following product chains are subject to specific marking rules:
- Electrical and electronic equipment
- Batteries and accumulators
- Household chemicals generating specific waste that could be harmful to the user’s health or the environment
3. The product must be intended for a household destination:
- The Triman mark must inform the consumer that certain products are part of a separate sorting. The concept of ‘consumer’, defined in Article 3 of the Act No. 2014-344 relating to consumption, excludes professionals. The products destined to professionals therefore have no requirement for the affixing of the Triman mark.
- However, Hong Kong traders will appreciate that, in product design, it can be difficult to distinguish household products from those intended for professional use. If the product is recyclable and is covered by sorting and separate collection, the supplier can affix the Triman mark regardless of the nature of the future user.
4. The product must be recyclable:
- This is defined as any product that can effectively, given the present techno-economics, be recycled as defined in Article L. 541-1-1 of the Environmental Code. The process for the preparation of reusing products is included in the process for recycling.
5. The product must be subject to a sorting instruction:
- This is defined as the invitation made to the consumer which would allow him to dispose of the product by means of a separate collection. By separate collection is meant a collection where a waste stream is kept separately by its type and nature so as to facilitate a specific treatment.
If the product meets all five of the abovementioned criteria, the Triman mark must be affixed.
The guidelines recommend that the mark be displayed directly on the product, to ensure that the information is available to the consumer at all times, and especially when the item is discarded. For example, the marking may be displayed directly onto the collar of a t-shirt, on the care instructions label, or on the sole of a shoe.
In the absence of the Triman mark appearing directly on the product, the supplier can place the mark on the product’s packaging, a package-insert, or in a paperless format. For example, the marking may be displayed on a shoe box, on a piece of clothing’s washing instructions, or on a producer’s website.
If only the packaging of the product is to be recycled, or if there are several packaging components, only some of which are recyclable, the Triman mark must be affixed to the recyclable components and not to the others. For example, when a recyclable cardboard packaging has been placed inside a plastic packaging that cannot be recycled, the Triman mark may only be affixed to the cardboard.
To sum up, in the French Environment Code (Article L.541-10-5) amended by the Law of 2 January 2014, authorising the government to simplify corporate activity, it is stated that as of 1 January 2015 all companies (including, therefore, Hong Kong companies) manufacturing recyclable products that are covered by an Extended Producer Responsibility chain and are placed on the French market are obliged to display the marking, to inform the user that the product is recyclable. Thus, the use of the Triman mark is not voluntary but, for products falling within its scope, it is a mandatory requirement.
Please click the following to read (in English) the User's Handbook on the Triman mark.