A cosmetic can be fully compliant with EU cosmetic law and still be rejected by a French retailer. The usual reason is a packaging obligation rather than a cosmetic one: Triman and Info-Tri labelling, the French sorting mark that no other EU member state requires and that brands consistently discover only when a listing is refused.
This guide explains what the marking is, what it has to show, where it goes, and why “we already have the Triman logo” is usually not enough.
Key takeaways
- The Triman logo plus Info-Tri sorting instructions are mandatory for products and packaging placed on the French market.
- The legal basis is the AGEC law and Article R.541-12-17 of the French Environmental Code.
- The logo alone is not compliant — it must be accompanied by component-by-component sorting instructions.
- It is a packaging obligation, which is why cosmetic brands miss it: it sits outside Regulation (EC) No 1223/2009.
- It applies to distance selling into France, so online-only brands are not exempt.
- Marking is separate from your EPR registration with an eco-organisme such as CITEO.
What the AGEC law requires
France’s loi anti-gaspillage pour une économie circulaire — the AGEC law — reformed how sorting information must appear on consumer products. Under Article R.541-12-17 of the Environmental Code, products and their packaging placed on the French market must carry the Triman logo together with sorting instructions telling the consumer what to do with each element of the packaging.
The Triman logo itself is the familiar figure with three arrows, signalling that the item is subject to sorting rules. On its own it conveys very little, which is why the reform pairs it with Info-Tri: a small block that breaks the packaging into its components and assigns each to a waste stream.
Why cosmetic brands miss it
Cosmetic compliance work is organised around Regulation (EC) No 1223/2009 — safety assessment, notification, labelling under Article 19. Triman appears nowhere in it. It is environmental and packaging law, administered separately, and it applies to cosmetics simply because cosmetics come in packaging.
The result is predictable. A brand completes its CPSR, notifies on the CPNP, appoints a Responsible Person, prints its artwork — and is then told by a French retailer or marketplace that the pack cannot be listed. Our country guide on cosmetic compliance in France covers the wider ANSM and market-surveillance picture this sits inside.
Component by component
The core of Info-Tri is that packaging is not one thing. A single cosmetic unit can easily have four or five separately disposable components, each going to a different stream. A generic mark that lumps them together does not satisfy the requirement.
| Component | Typical material | Sorting consideration |
|---|---|---|
| Bottle or jar | PET, PP, glass | Usually recyclable; stream depends on material |
| Cap or closure | PP, HDPE | Often a different material from the body; may need separating |
| Pump or dispenser | Mixed plastic and metal spring | Frequently non-recyclable due to mixed materials |
| Outer carton | Cardboard | Paper stream; watch for laminates and foiling |
| Leaflet or insert | Paper | Paper stream |
| Shrink film or sleeve | PVC, PET | Usually removed and discarded separately |
Placement, size and the small-packaging route
The marking has to be visible and legible to the consumer, which in practice means a defined minimum size and a sensible position on the pack. Hiding it under a fold, printing it in a colour with too little contrast, or shrinking it until the sorting text is unreadable all undermine compliance even where the elements are technically present.
For genuinely small packaging there is a dematerialised route — the information can be provided outside the pack itself, subject to conditions. This is a real provision, not a general escape hatch: it exists for items where the marking physically cannot fit, and using it for a pack that could carry the mark is not compliant.
Where it fits with the rest of your label
If you are opening the artwork to add a French sorting mark, it is the cheapest moment to verify everything else on the pack. The mandatory symbols on cosmetic labels — period after opening, the open-jar mark, the hourglass, the hand-and-book reference mark — all have their own rules, as does the ingredient declaration.
Practical sequencing: get the INCI list prepared, run a full Cosmetic Label Review, and add the France Triman & Info-Tri marking in the same artwork cycle. One print run instead of three.
Bringing it all together
Triman and Info-Tri are a small, bounded piece of work with an outsized consequence: without them, French retailers and marketplaces can simply decline to list you, no matter how complete your cosmetic dossier is.
Identify every packaging component, assign each its sorting stream, lay the marking out to the prescribed form, and design it into the artwork at a legible size from the start. And if France is not one of your markets, you do not need any of this — which is worth confirming before anyone sells you the service.
Frequently asked questions
Is the Triman logo enough on its own?
No. Since the AGEC reform the logo must be accompanied by Info-Tri sorting instructions covering each packaging component. A pack showing only the three-arrow figure, with no component-level sorting guidance, is not compliant.
Do I need Triman if I only sell online into France?
Yes. The obligation attaches to placing the product on the French market, and that includes distance selling. Marketplaces increasingly check for the marking before permitting a listing, so online-only brands tend to encounter it sooner rather than later.
Do other EU countries require the same mark?
No. Triman and Info-Tri are specific to France. Other member states have their own extended producer responsibility regimes, but none requires this particular on-pack sorting mark, which is exactly why it gets overlooked in EU-wide artwork.
Does this register me with CITEO?
No. Registering with an eco-organisme, obtaining your unique identifier and paying eco-contributions is a separate extended producer responsibility obligation. Marking guidance prepares what goes on your pack; it does not enrol you in a scheme.
My packaging is too small for the full marking. What are my options?
There is a dematerialised route for packaging that genuinely cannot carry the marking, subject to conditions on how the information is otherwise made available. Whether you qualify depends on the actual dimensions and available print area, so it needs assessing rather than assuming.
I have already printed my packaging. What now?
The AGEC requirements have been phased in with sell-through periods for stock already produced, so existing inventory is not automatically unsellable. Your position depends on when the packaging was produced, which is worth establishing before you decide whether to reprint or sell through.
