EPR unique identifier, Triman logo and Info-tri in France: what an online shop must do

Are you a “producer” under EPR rules?

The French Environmental Code (Code de l'environnement, abbreviated “C. env.”) defines as a producer any person who develops, manufactures, handles, processes, sells or imports products that generate waste. C. env. L. 541-10 Among the schemes that most concern online shops: C. env. L. 541-10-1

• Household packaging and paper; the ministry's FAQ on the Triman also mentions an online seller's shipping boxes.
• Electrical and electronic equipment and batteries.
• New clothing textiles, footwear and household linen intended for private individuals.
• Furniture items and textile decoration items.
• Toys, sports and leisure goods, DIY and garden items.

For packaging, the producer is now defined by EU Regulation 2025/40: a manufacturer, importer or distributor that makes packaging available for the first time, “regardless of the selling technique used, including by means of distance contracts”. C. env. R. 543-43 · Reg. (EU) 2025/40, Art. 3

The EPR unique identifier: where to display it

Producers register with ADEME, which issues them a unique identifier and publishes the list of registered producers. C. env. L. 541-10-13 · R. 131-26-1 If you are a member of an éco-organisme (the organisation that runs an EPR scheme on behalf of producers), your annual data reporting can go through it. The identifier takes the form FR123456_01ABCD.

C. env. R. 541-173 · L. 541-10-10 · Law No. 2004-575, Art. 19

Example wording: “Identifiants uniques REP attribués par l'ADEME: FR123456_01ABCD (emballages ménagers); FR123456_02EFGH (textiles d'habillement, chaussures et linge de maison).” (In English: “EPR unique identifiers issued by ADEME: [identifier] (household packaging); [identifier] (clothing textiles, footwear and household linen).”) Replace these fictitious numbers with your own.

Lost your identifier, or want to check a supplier's? The free EPR unique identifier lookup tool searches ADEME's public register using a SIREN number (the French company registration number) or a company name.

On marketplaces. A platform that facilitates distance sales of products subject to EPR must contribute in place of the seller, unless it holds supporting evidence; holding a unique identifier counts as proof that the seller complies. C. env. L. 541-10-9

The Triman logo and Info-tri

Every product intended for households and subject to an EPR scheme, except glass beverage packaging, bears a marking indicating that it is subject to sorting rules: this is the Triman. It is accompanied by information on how to sort it, detailed item by item when the instructions differ. C. env. L. 541-9-3 This information is drawn up by the scheme's éco-organisme and published on its website. C. env. R. 541-12-18 For household packaging and paper, Citeo (the éco-organisme for these products) distributes it under the name Info-tri, with a guide and graphic files to download.

• Where. On the product, its packaging or, failing that, the documents supplied with the product. For household packaging, on the packaging itself, possibly by means of a sticker. The Triman is placed right next to the sorting information. C. env. L. 541-9-3 · R. 541-12-21
• Small products. If the area of the largest side of the product or its packaging is less than 10 cm² and no document accompanies the product, both can be provided in digital form only; between 10 and 20 cm², only the sorting information can be. These thresholds rise to 20 and 40 cm² for cylindrical or spherical products. C. env. R. 541-12-21
• Parcels. An online seller can put on its boxes a single piece of sorting information covering the box and the packing materials, according to the ministry's FAQ.
• QR code. According to the same FAQ, a QR code cannot replace the sorting information, which must directly state the sorting instruction.

For household packaging, the ministry's FAQ gives an entry into force of 09/09/2022, with the sell-off period for existing stock ending on 09/03/2023: the obligation is fully applicable.

What is coming with the EU Packaging Regulation

Regulation (EU) 2025/40 provides for a harmonised label on packaging materials. It becomes mandatory on 12/08/2028, or 24 months after the entry into force of the implementing act that will define it if that date is later. It also covers e-commerce packaging, and its information will have to be made available to buyers before the purchase online. Reg. (EU) 2025/40, Art. 12(1) By 12/02/2027 at the latest, packaging subject to an extended producer responsibility scheme may be identified in all Member States where that scheme applies solely by a symbol placed in a QR code or by another open, standardised digital marking. Reg. (EU) 2025/40, Art. 12(9) The French Environmental Code already allows the Triman to be replaced by a mandatory common European marking. C. env. R. 541-12-20

Penalties

• Unique identifier missing from the mandatory information, failure to register or incorrect data: administrative fine of up to €30,000, imposed by the minister responsible for the environment. C. env. L. 541-9-5
• Triman or sorting information missing: up to €3,000 for an individual and €15,000 for a legal entity. C. env. L. 541-9-4 According to the ministry's FAQ, the DGCCRF (the French consumer protection authority) carries out the checks and the fine can apply per product concerned.

Your action list

1. List the EPR schemes that cover your products and your packaging, parcels included.
2. Check your registration and your identifiers in ADEME's register.
3. Add each identifier, with its scheme, to your terms and conditions and your legal notice.
4. Collect your suppliers' identifiers so you can answer buyers' requests.
5. Check that the Triman and Info-tri appear on your packaging, shipping boxes included, and on the products you manufacture or import.
6. Download your éco-organisme's files rather than redrawing the logo.
7. For a specific case (imports, selling from abroad, white label), have your analysis validated by a lawyer or your éco-organisme.