What’s new?
On 16 July 2025, the European Commission referred France to the Court of Justice of the European Union (CJEU) for failing to address incompatibilities in its national waste sorting labelling requirements. This escalation is the final stage of infringement proceedings that began with a formal notice letter in February 2023, followed by a reasoned opinion in November 2024.
Under French legislation stemming from the AGEC Law of 10 February 2020, all household products subject to Extended Producer Responsibility (EPR) schemes, including cosmetic products, must display the ‘Triman’ logo and ‘infotri’ sorting instructions, regardless of where they were originally manufactured. The Triman logo indicates that a product is subject to sorting rules, while the infotri label specifies appropriate disposal and recycling methods.
The Commission argues that these France-specific labelling requirements constitute a barrier to the EU Single Market, forcing manufacturers to create packaging variations exclusively for the French market and violating fundamental EU principles of free movement of goods.
What now?
Despite the infringement proceedings, French market surveillance authorities continue monitoring and enforcing Triman logo compliance. Companies selling cosmetic products in France must maintain current labelling requirements until further legal resolution.
CJEU proceedings typically take 18-24 months to reach a final judgment. If the Court rules against France, the country would be required to amend or repeal the conflicting national legislation.
Regardless of the infringement proceedings on course, from August 2028, harmonised EU-wide packaging labelling is expected to become mandatory under the Packaging and Packaging Waste Regulation, superseding national systems like France’s Triman requirements.
