December 16, 2013
A press release from the Joint Industry Association has outlined the concerns of 21 trade associations regarding the Triman legislation in France – a common set of symbols on recyclable products marketed in France aiming to simplify waste sorting activities and increase France’s recycling rate.
The measure was drafted by the French environment ministry and given approval from the European Commission in October 2012 “on the basis that the measure did not present any obstacles to the internal market”.
However, concerns have been raised by countries exporting within the EU Single Market that the proposed measure would become a barrier to trade, as packaging would have to be made specifically for the French market; with the measure also claimed to be very expensive to implement in proportion to its objectives and “more strict than necessary”.
As a result, the Joint Industry Association has called for the French Government to abandon the current initiative or make it voluntary; the EU authorities to review the compatibility of the Triman legislation with global trade and internal market rules; and, in case France adopts the current draft decree, has asked the Commission to launch an infringement procedure against France.
The Triman legislation would require recyclable products and packaging to display the ‘Triman’ logo, which would have to be affixed next to existing environmental logos. The logo would also have to be displayed on secondary recyclable packaging, with an alternative being to display wording and/or pictograms on the primary packaging to inform consumers that secondary packaging inside is also recyclable, although this must be translated into French.
These rules exclude products placed on the market prior to 1 January 2015. Furthermore, e-waste, batteries and accumulators covered by relevant European legislation, such as WEEE are exempt, but all packaging covered by producer responsibility legislation will be subject to the Triman obligation. It has been argued by the Joint Industry Association that this would confuse consumers rather than providing guidance.
Also exempt are products where it is “technically not possible” to display the logo; situations where costs are disproportionate; and products that have a similar label to comply with the legislation of another Member State.
The Joint Industry Association argued that the Triman measure will have a number of negative impacts on businesses, including administrative burdens and costs for relabeling or repackaging products; estimating that it would cost the printing industry €0.25 ($0.34) per sticker, or €8 million ($11 million) overall in the printer cartridge industry.
It was also noted that, while French authorities have said that current recycling fees will be reduced to balance the new costs, no concrete measures have been seen to suggest that this is the case; with the Joint Industry Association stating that “to our knowledge, the French authorities have not conducted any impact assessment of the costs associated with this measure”.
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