Environmental Label Information

Our home is burning and after a record-breaking summer, climate change is at the heart of global concerns. To cope with climate change, European and national policies are evolving, becoming more stringent, and introducing new requirements, for example about the environmental label information & recycling obligations.

The EU Legal framerwork is wide and includes: the waste framework Directive, the packaging & packaging waste Directive (94/62/EC), the Decision (97/129/EC) and national laws.

EU context: one Directive, different implementations

In 1994, the EU has implemented a directive on packaging and packaging waste.

The main reasons were to manage the increasing quantities of packaging waste (which generate environmental problems) and facilitate the functioning of the internal market (since each EU member state had adopted different rules in this regard).

Since then, the EU has amended its laws on packaging several times. These revisions included: measures for plastic carrier bags, additional waste prevention and reuse obligations for EU members, the Extended Producer Responsibility schemes.

EPR or Extended Producer Responsibility…What is it?

Appeared in the early 1980s in a few member states, the Extended Producer Responsibility (EPR) is an environmental policy approach in which a producer’s (manufacturers and importers) responsibility for a product is extended to the post-consumer stage of a product’s life cycle.

Since then, it has continuously spread around the EU (and abroad). These rules are transversal and affect all types of packaging (electronics, food but also cosmetics). In practice, EPR implies that producers take over the responsibility for collecting or taking back used goods and for sorting and treating for their eventual recycling. Such a responsibility may be either financial or organisational. EPR is to be considered as a major instrument in support of the implementation of the European Waste Hierarchy, and therefore for the increase of, by priority: prevention, re-use and recycling.

Along with other key economic instruments, EPR can encourage a change in behaviour of all actors involved in the product value chain: product-makers, retailers, consumers-citizens, local authorities, public and private waste management operators, recyclers, and social economy actors.

2024: Deadline for EU member states

The latest amendment to the Directive 94/62/EC includes updated measures to:

  • Prevent the production of packaging waste
  • Promote the reuse, recycling and other forms of recovering of packaging waste, instead of its final disposal

Among other rules, by end of 2024, EU countries should ensure that producer responsibility schemes (EPR policy) are established for all packaging. Because it’s a Directive each country transposed it in a different way in its national legislation. Therefore, the application of this directive can be very different in each country, from almost no obligations to very prescriptive requirements.

But to date, only France, Germany and Italy made it compulsory for marketplaces to check if sellers are EPR compliant. Penalties for non compliance have gotten stricter in recent years.

We will give you the examples of France and Germany below.

Germany: The “Verpackungsgesetz” law

Here is an overview of the recent amendments/updates to the “Verpackungsgesetz” law:

  • From 1st July 2022 all type of packaging must be registered for the German market. This means that every producer who places a product on the German market for the first time will have to register on the “Lucid Packaging” website (the online platform of the Zentrale Stelle Verpackungsregister (Central Agency Packaging Register)). The producer will have to provide details about the packaging types and brand names. For producers who have previously already registered, they can add details on the existing registration.
  • Electronic Marketplaces are required to check if their business partners placing packaging filled with goods on the German market are registered in the LUCID Packaging Register. The Zentrale Stelle Verpackungsregister (Central Agency Packaging Register) provides a digital register excerpt for this purpose.

France: The “Agec” Law

Among the multiple measures, here are the main actions that will impact the labelling of cosmetic products:

  • Obligation to display the Info-Tri sorting instructions from 1st January 2022 (whether the packaging is recyclable or not). Household packaging must bear the Info-Tri, i.e.: the Triman Logo and sorting instructions to inform the consumer on how to sort of the packaging in a correct way. The info-tri is now the standard marking, easily recognized by consumers. The Info-Tri is not linked to the recyclability of packaging, and you must follow specific labelling rules as set out in the guidance prepared by the eco-organization CITEO.

Regarding the deadlines:

producers had until 9 September 2022 to affix it to all household packaging. There is the possibility of marketing products without the Info-Tri after 9 March 2023 if the packagings have been manufactured before 9 September 2022 and sold to the marketer/subcontractor before 9 March 2023 (filled or not). As an example, here is the amount of the penalty for non-compliance: 3,000 € for a natural person, 15,000 € for a legal person.

  • Removal of any other signs that may confuse consumers regarding the sorting rules from January 1 st, 2022. Article 62 of the AGEC law states that a financial penalty should be imposed for any marking or sign that can be confusing in regards to the sorting rules or the waste amount of the product.

The Ministerial Order (Arrêté du 30 Novembre 2020) on signs and markings that can bring a confusion on sorting rules has been published on December 24th2020 and it lays down that any sign representing 2 or more coiled arrows in a circle are confusing, with the exception of:

  1. The Triman logo
  2. Logos associated with the product brand or the distributing company
  3. Regulated signs from the Member states that inform the consumer that the product is recyclable or bears sorting instructions

The Green Dot is therefore affected by this national provision. However, the financial penalty was suspended and there is no date for the postponement of this penalty on green dot at this time. A final decision on this is expected in the course of 2022.

How Biorius can help?

BIORIUS launches its new service that provides information regarding the manufacturers’ Extended Producer Responsibility (EPR) and the new labelling obligations, which are applicable if you manufacture or import packaging on specific markets (like France or Germany for instance).

As a client, you can choose among any EU member state plus UK, Switzerland, and Norway. We can also recommend the countries where the regulation requires a specific labelling and/or set-up new requirements.

Feel free to contact us for further information about our recycling obligations assistance.

Hanna Gharbi

Business Development Representative



  • Frédéric Lebreux

    Dr. Frédéric Lebreux is Biorius's Chief Executive Officer and has worked in the cosmetic industry for more than 13 years. He is regularly invited as a speaker or Professor to cosmetic events.