French packaging labelling - July 2022 updates
by Jennifer Brook at 09:26 in Environmental, Packaging
The French producer responsibility organization for packaging, CITEO, released specific and thorough labelling guidance for their members at the end of last year, to help producers follow the less-detailed requirements of the law.
What is French packaging labelling?
As explained in a previous Lorax EPI blog from last year, the French law requires producers to include component pictograms (or the name of the separable packaging component), sorting instructions and the Triman symbol on their packaging. CITEO provides template labels for their members that producers can use to meet these requirements.
Since last year, some producers have run into other problems when trying to label their packaging. CITEO has spoken with the government, and secured feedback for producers, in the form of new guidance released through Article 2 of Decree 2022-975, published in July 2022.
Deadlines for using up old stock
One of the points in the new decree outlines when producers are allowed to market old stock that has old packaging labels. Originally, producers had to be compliant with the new packaging labels by 9 September 2022, and old stock had to be used up by 9 March 2023.
The new guidance provides further clarification that the stock depletion rule also applies to empty packaging that was manufactured or imported prior to being used for product filling.
The Ministry has confirmed the interpretation that empty packaging manufactured before 9 September 2022 or placed on the French market before 9 March 2023, can still be used to package products after the 9 March 2023 deadline, until the depletion of stocks. This rule applies to all packaging, whether manufactured in France or abroad.
Decree 2022-975 also clarifies other aspects of the packaging labelling system.
For example, producers were finding it difficult to place the Triman symbol onto smaller packaging, so there are new size restrictions, specifically for cylindrical or spherical packaging. There is also further direction around how your labels should look if you have many different packaging elements.
If you would like to find out more details regarding the implementation of the new French labelling system, and how it may affect your business, contact us at Lorax EPI today, and speak with one of our experienced consultants.