Selling clothing, footwear, or textiles in France? It’s not too late to get compliant and avoid costly fines
Triman is a mandatory labelling system related to the end-of-life treatment of consumer and professional products. In February 2022, this was extended to cover clothing, textiles and footwear. The labelling must conform to the highly specific requirements set out by the French Ministry of Ecological Transition, and non-compliance is punishable by a fine.
If you’re a fashion or lifestyle brand manufacturing goods in France or importing them into the country, you may have already heard about the Triman labelling requirements. And if not, you need to get informed and get compliant, because the final deadline for all your stock to meet the regulations is fast approaching.
It is crucial for many brands to understand and adapt to all the complexities of the Triman labelling requirements for clothing, textiles and footwear. And while they require changes to their operations, there are many ways to stay ahead of the compliance curve and avoid costly fines. But what is it actually about?
Introduction to the Triman labelling system in France
Triman is a labelling framework for consumer and professional products in France. It relates to the end-of-life treatment of these products and comes under the umbrella of the French Anti-waste law for a circular economy, otherwise known as AGEC.
The new labelling requirements came into force in early 2022 and cover a wide variety of clothing, household textiles and footwear. The requirements are valid for all items manufactured in or imported into France and cover all types of selling platforms. This includes e-commerce, factory outlets, self-employed sellers and second-hand marketplaces.
Under the AGEC law, you are considered a producer (or ‘marketer’) if you manufacture, import, assemble or otherwise ‘introduce into the national market’ products in the categories of clothing, household linen and shoes. If you are one of the following types of party, you come under this legislation:
- A manufacturer or instructing party selling articles (manufactured in France or abroad) in France under your brand name
- An importer (wholesaler or retailer) of national or international brands
- A distributor of your own brand or directly imported products (multi-brand retailer)
So, even if you are a Dutch fashion label importing clothes into France, French law requires you to adhere to the Triman labelling regulations if you are also selling the clothes. The eventual responsibility always rests with the party who delivers the products to market (known as the ‘metteur en marché’).
For instance, a wholesaler operating in France who imported non-labelled clothes into the country would be responsible for adding the correct Triman labelling before selling these goods. This is the case for all other categories of applicable products.
For importers: customs officers will not check for the presence of a Triman label on imported clothing, footwear or textiles. Checks will be carried out by governmental organisations such as the Direction départementale de la protection des populations (DDPP) and the Direction générale de la concurrence, de la consommation et de la répression des frauds (DGCCRF).
The information that accompanies the Triman logo on the label is known as the ‘info-tri’ (‘sorting information’). It is mandatory in all but exceptional cases to include both the logo and the sorting information. This gives consumers clarity on exactly where they should put their used goods so they can be effectively reused or recycled – paving the way towards a circular economy for clothing.
What are Producer Responsibility Organisations?
Before you can start operating as a vendor of clothing, footwear or home textiles on the French market, you will need to register with a producer responsibility organisation (PRO). These organisations accompany the circular transition for various product categories. Currently, the only PRO for clothing, footwear and textiles is ReFashion.
As a fashion or lifestyle brand in France, you must pay eco-contributions to ReFashion to comply with France’s extended producer responsibility (EPR) legislation. Your company pays for each garment that you put on the market, effectively subsidising its reuse or recycling. This is designed to reduce the amount of clothing that gets sent to landfill.
Once your company has registered with the PRO, you can apply to register with ADEME (the French Agency for the Ecological Transition) to receive a unique ID number (“Identifiant Unique”, or UIN). This is a legal requirement for any person or organisation selling clothing, footwear or textiles in France.
Note: almost all brands will need to register with two PROs – one to cover their clothing products and one for the packaging it comes in. If you have an e-commerce operation, it is advisable to discuss with your logistics provider whether you also need to register with a PRO for the packaging in which your products are delivered. Your provider may already be registered with the appropriate PRO for their packaging.
When will a brand be required to comply with Triman labelling regulations for clothing?
In theory, the Triman regulations came into force on 1 February 2023. All products created in France or imported into France after this date must have a Triman + info-tri label attached to them. However, brands have been given a six-month grace period. This means any clothing created or imported before 1 February 2023 may be sold without a Triman label until 1 August 2023.
After 1 August 2023, all textile and footwear products on sale in the French market (and created in France for export) must be labelled correctly. Any product sold without the appropriate Triman label will incur a per-violation fine of EUR 3,000 for natural persons and EUR 15,000 for legal persons (i.e., companies). Don’t get caught out!
Which clothing products need to carry a Triman label in France?
The Triman labelling requirements cover a wide variety of clothing, textile products and footwear. The below table outlines the types of products that are included in the requirements, and which are exempt. However, it should be noted that many ‘exempt’ items are covered by a separate EPR stream, meaning they also need to be labelled.
Most clothing, including socks, underwear, trousers, scarves, t-shirts, gilets and coats.
All-leather goods, natural fur items and purely decorative costume items such as fairy wings or masks (please note that there is a separate EPR stream for toys and games).
Most shoes, including sandals, slippers, boat shoes, baby shoes and trainers.
Protective footwear (ISO 20345-compliant) and specialised sports equipment shoes, including ski boots, cycling shoes and ice skates (these items fall under the Sport & Leisure EPR stream).
Most home textiles, including bed linen, tablecloths, bath towels and dressing gowns.
Carpets, cushions, headboards, oilcloths, venetian blinds, furniture coverings and room dividers (these items are covered by the Furniture EPR stream).
Note: accessories such as umbrellas are not currently included under the Triman labelling regulations. A full range of clothing items covered by the Triman labelling regulations is available for download here.
What does the Triman label for clothing look like?
The exact design of the Triman logo and the accompanying sorting information has been approved by the French Ministry of Ecological Transition. It is important to respect the exact design guidelines and dimensions of all label elements. The Triman logo and the sorting information pictograms are available for download license-free for ReFashion members.
Please note, the use of the Triman graphical assets is only free to use for companies and persons registered with the Producer responsibility organisation relevant to the EPR stream in question (ReFashion for clothing, footwear and textiles, Citéo for packaging and paper and Ecomaison – formerly Eco-mobilier – for furniture). Discover the ReFashion guidelines.
What needs to be included on the Triman label for clothing?
The Triman label must always (apart from in exceptional cases) consist of two main elements. These are the small human figure with four arrows (the Triman logo), and the sorting information (the ‘info-tri’). Below are several examples of how the full Triman label (logo + info-tri) may appear on the product and its packaging.
How big should Triman labels for clothing, footwear, and fabrics be?
Each label must contain the Triman logo, the initials ‘FR’, the sorting information symbols, and the URL address. The label must measure a minimum of 2.7 cm wide for the horizontal version, or 2.7 cm tall for the vertical version. The minimum height (for the horizontal version) is 1 cm or 0.6 cm in the case of technical difficulties.
Please note, the proportions of the graphical elements must always be respected, and it is not possible to separate the elements of the label – it must always appear as one unit. The small human figure with the arrows does not constitute a Triman label.
How the Triman label must be attached to clothing and footwear?
The Triman label may be sewn directly onto products, as with care instruction labels. Alternatively, the label may be printed or embossed directly onto the product or its packaging. If it is impractical to attach or print a label directly, you are advised to print the Triman label on attached elements such as hang tags. Alternatively, you may print the Triman label on any accompanying documentation, such as a usage instructions booklet. It is also possible to use a Triman sticker, for example in the case of shoes.
Note 1: if you use the hang tag or the booklet option, you must print two Triman logos on the tag/booklet: one to cover the item of clothing/footwear/textiles and one to cover the card tag/paper booklet. This is because the tag/booklet will become part of a waste stream managed by Citéo (paper and packaging), while the clothing will be covered by ReFashion.
Note 2: if a product – e.g., a gift set – contains different product categories, separate Triman labels need to be visible on the individual products or the packaging. This is to cover the disposal requirements of each separate product category (e.g., clothing and household goods).
Which variations of Triman labelling for clothing are acceptable?
Modification of the approved design specifications is not permitted. However, there are sufficient labelling options within the approved designs to reflect a wide range of possible situations. For instance, there are several different options for sorting information (‘info-tri’) icons, allowing you to customise the label to your product’s specifications.
Note: if your brand sells shoes, clothing and home textiles, it is acceptable to add the ‘t-shirt, folded towel and shoe’ option to all your products, no matter what they are:
It is also possible to indicate that your company operates an in-store collection service for used clothing by adding the ‘in-store collection’ icon, as below:
What are the additional labelling requirements for Triman?
Most clothing, footwear and household textiles come in packaging, and this packaging needs to carry its own Triman label – separate from the label referring to the clothing itself. Take the example of a pair of shoes in a cardboard box. The shoes would need to have the below label printed on them or attached to them, either sewn on or using a sticker:
Meanwhile, the cardboard box itself must carry a Triman label from Citéo, the producer responsibility organisation that oversees the management of packaging waste.
The two different Triman labels, one from ReFashion and one from Citéo, cannot be combined into one label. This is because they relate to different EPR streams.
Are there any exceptions to the Triman labelling requirements for clothing?
If the surface area of a product will not accommodate a Triman label, a (semi-) digital Triman label may be used. If the largest surface of the product measures less than 10 cm2, and there is no supporting documentation included, the Triman label in its entirety may be made available online. For ease of access, a QR code or similar is recommended.
If the largest surface area of the product measures between 10 cm2 and 20 cm2, and it comes with no supporting documentation, the Triman logo (the human figure with the four arrows) must be attached to the product, but the full label (the Triman logo + the sorting information) must be made available online, accessible e.g., via a QR code.
What happens if I do not manage to sell off all non-compliant stock by 1 August 2023?
All stock present on the French market not carrying the Triman logo will be considered a violation of French law. Brands that have not managed to sell off all non-labelled stock or attach labels to existing stock by the cut-off date of 1 August 2023 may attach the correct labels directly to products in the form of stickers.
How can Bleckmann help you achieve Triman compliance for clothing?
With the final deadline for Triman compliance fast approaching, it’s understandable to be concerned about how your brand will cope with the updated regulations. Many will be worried about the cost and logistical complexity of re-labelling all their existing stock, and monitoring compliance across their entire supply chain.
So, why not get in contact with a Bleckmann team today and see how we can help you achieve compliance with minimal disruption to your business operations?
For more detail on the French Triman labelling regulations for clothing, footwear and household textiles, please see the guidelines available on the ReFashion website: https://refashion.fr/pro/en/sorting-info-textile-sector-validated