France - Country Commercial Guide
Labeling/Marking Requirements

Overview of the different labeling and marking requirements, including any restrictive advertising or labeling practices and where to get more information.

Last published date: 2019-10-13

The use of French is compulsory in all designations, offers, presentations, user manuals, and terms of service for a product or service. In addition, all invoices and receipts must also be in French. The objective of this measure is to provide information, consumer protection, and enable the individual to buy and use a product or service while having  complete knowledge of the product’s nature and warranty.

The Act of August 4, 1994 and its implementing regulations have established that the use of French language is a fundamental element of the heritage of France. The purpose of the law is the protection of the French language; the obligations apply without the need to distinguish whether the buyer is an individual or a professional.

These requirements are part of the French Code of Consumption which can be accessed at:  French Code of Consumption. A partial list of French language requirements relevant to U.S. businesses operating in France includes:

The use of French is compulsory in trade relations and labor relations, without, however, prohibiting the use of recognized foreign words or phrases.

Contracts which are parts of legal entities under public or private persons performing a public service are written in French regardless of their purpose and form.

Job offers in the press, labor contracts, and other documents relating to social relations within the company are required to be written in French.

Labeling of food, a decree of 1 August 2002 complement Article R. 112-8 indicating that the labeling may be contained in one or more other languages, in addition to French.

Whenever mentions, ads, and inscriptions are supplemented by one or more translations, the French presentation should be as legible, audible, or intelligible as the presentation of foreign languages.

All labeling must be easily understandable, written in French with no abbreviations other than those prescribed by the regulations or international conventions. They must be listed in a conspicuous place and so as to be visible, clearly legible and indelible. They should in no way be hidden, obscured or interrupted by other written or pictorial content.

Relevant regulations

Act No. 94-665 of 4 August 1994 on the use of the French language.

Decree No. 95-240 of 3 March 1995 taken for the implementation of Law No. 94-665 of 4 August 1994 on the use of French. Circular of 19 March 1996 concerning the application of Law No. 94-665 of 4 August 1994 on the use of French.

In regards to textile labeling, the Court of Cassation, in a ruling dated November 14, 2000, agreed that the information labels displaying pictograms, where warnings were essential for the consumer, must be written in French. However, in an attempt to not obstruct the free movement of goods, specific products can be accompanied by statements in a foreign language not translated into French as long as the drawings, symbols, pictograms, or statements are of equivalent or complementary subject and are not likely to mislead the consumer. The specific products included are items that have inscriptions, are printed or woven, in a foreign language, contain words and phrases entered in the current language, or resulted from international conventions (i.e. off / on, made in …, copyright, etc.) which are used alongside other means of consumer information, such as symbols or icons.

Summary

There is a broad array of EU legislation pertaining to the marking, labeling and packaging of products, with neither an “umbrella” law covering all goods nor any central directory containing information on marking, labeling and packaging requirements. This overview is meant to provide the reader with a general introduction to the multitude of marking, labeling and packaging requirements or marketing tools to be found in the EU.

Introduction

The first step in researching the marking, labeling and packaging legislation that might apply to a product entering the EU is to draw a distinction between what is mandatory and what is voluntary.  Decisions related to mandatory marking, labeling and/or packaging requirements may sometimes be left to individual Member States.  Furthermore, voluntary marks and/or labels are used as marketing tools in some EU Member States.  This report is focused primarily on the mandatory marks and labels seen most often on consumer products and packaging, which are typically related to public safety, health and/or environmental concerns.  It also includes a brief overview of a few mandatory packaging requirements, as well as more common voluntary marks and/or labels used in EU markets.

It is also important to distinguish between marks and labels.  A mark is a symbol and/or pictogram that appears on a product or its respective packaging.  These range in scope from signs of danger to indications of methods of proper recycling and disposal.  The intention of such marks is to provide market surveillance authorities, importers, distributors and end-users with information concerning safety, health, energy efficiency and/or environmental issues relating to a product.  Labels, on the other hand, appear in the form of written text or numerical statements, which may be required but are not necessarily universally recognizable.  Labels typically indicate more specific information about a product, such as measurements, or an indication of materials that may be found in the product (such as in textiles or batteries).

Mandatory Marks & Label

  • Textiles
  • Cosmetics
  • Dangerous Substances
  • Explosive Atmosphere
  • Electrical & Electronic Equipment
  • Household Appliances    
  • Pricing
  • Footwear
  • Units of Measurement
  • Automotive
  • Tire labeling
  • Maritime
  • Materials in Contact with Food
  • Noise Emissions
  • Wood packaging
  • Energy Efficiency
  • Recycling- Separate Collection

  Voluntary Marks and Labels

  • Cup/Fork Symbol (material in contact with food)
  • Eco-Label
  • Green Dot
  • Energy Star
  • ‘e’ Mark

Recycling Marks

Voluntary and mandatory marks and labels apply to all Member States of the EU, countries in the European Economic Area, European Free Trade Association, as well as candidate countries seeking membership to the EU.

CE MARKING

The CE is the most widely used and recognized marking required by the EU.  Found in all “New Approach” legislation with a few exceptions, the CE marking demonstrates that a product meets all essential requirements (typically related to safety, health, energy efficiency and/or environmental concerns).   CE marking is required for the following products/product families:

  • Cableway installations
  • Civil explosives
  • Construction products
  • Electrical/electronic products
  • Electromagnetic compatibility
  • Low voltage
  • Restriction of Hazardous Substances
  • Energy efficiency
  • Equipment and protective systems in potentially explosive atmospheres (ATEX)
  • Gas appliances
  • Hot water boilers
  • Lifts
  • Machinery
  • Medical devices (3)
  • Non-automatic weighing instruments
  • Personal protective equipment
  • Pressure equipment
  • Radio equipment
  • Recreational crafts
  • Refrigeration appliances
  • Simple pressure vessels
  • Toys

For each “New Approach” law there is a separate list of references to harmonized European standards, the use of which provides the manufacturer with the ‘presumption of conformity’ with essential requirements.  While other non-EU standards may be used to demonstrate a product’s compliance with the applicable directive(s), the manufacturer will have to provide detailed information regarding the compliance process.  An array of standardized safety warning symbols/pictograms may also be applicable to each of the above product categories.

In 2008, the EU adopted a package of measures known as the New Legislative Framework (NLF) which provides a regulatory ‘toolbox’ for new and revised EU product safety legislation. The framework is designed to improve market surveillance, more clearly define the responsibilities of manufacturers, importers and distributors, and clarify the meaning of CE marking across a wide range of product groups.  In February 2014, to align product harmonization legislation with the provisions of the NLF (most notably Decision 768/2008), the European Union adopted an “Alignment Package” consisting of eight revised CE marking directives. These newly aligned directives are in force since 2016.

Note:  The EU is currently finalizing new legislation that will impact CE marking for medical devices.  The new regulations have transition period with the new measures coming into force in 2020 for medical devices and 2022 for in-vitro medical devices.

For more information:

CE Marketing

Harmonized Standards

New Legislative Framework

CE Marking Laws Applicable

THE WASTE ELECTRICAL AND ELECTRONIC EQUIPMENT DIRECTIVE (WEEE)     

THE WASTE ELECTRICAL AND ELECTRONIC EQUIPMENT DIRECTIVE (WEEE) LOGO
WEEE Logo

This directive is designed to tackle the rapidly increasing waste stream of electrical equipment into landfills and waste incineration facilities. The directive increases recycling of electrical and electronic equipment, limiting the total quantity of waste going to final disposal.  This directive affects the following product categories:

  • Large and small household appliances
  • Consumer equipment
  • Lighting equipment
  • IT and Telecommunications equipment
  • Electrical and Electronic Tools
  • Toys and Sports equipment
  • Medical Devices
  • Monitoring and control equipment
  • Automatic dispensers

The symbol shown above must be displayed on all products that fall under this directive and indicates that the product is not to be discarded with normal household waste.  It is a required mark on batteries.  In instances where this symbol cannot be displayed on the equipment itself, it should be included on the packaging.

For more information:

Directive 2012/19/EU

   

Energy Labeling Logo
Energy Labeling Logo

Directive 2010/30/EU on “labeling and standard product information of the consumption of energy and other resources by energy-related products” sets a framework for the adoption of product-specific directives for the proper energy efficiency labeling for each concerned product.   With the adoption of Regulation 2017/136 on energy labeling, which entered into force on August 1, 2017, the original directive 2010/30/EU was repealed; labeling categories were simplified; and the scope was extended.

Suppliers are to supply, free of charge, labels or product fiches containing information about consumption of electric or other energy sources to their dealers. Dealers then must display labels in a visible and legible way and make the fiche available in product brochures or other literature.

For more information:

Clearer Energy Labelling

Energy Consumption

DEVICES FOR USE IN POTENTIALLY EXPLOSIVE ATMOSPHERE (ATEX)

EXPLOSIVE ATMOSPHERE (EX) Mark
EXPLOSIVE ATMOSPHERE (EX) Mark

In addition to applying a CE marking for products falling under the ATEX Directive (2014/34/EC), it is also necessary to display the Ex mark. The Ex mark is a specific marking designed for explosion protection.  Located next to the ‘Ex’ mark will be a symbol designating the product group or category as specified in the directive.

The revised ATEX Directive (2014/34/EC) was adopted in February 2014 as part of the New Legislative Framework alignment package.  It replaced the existing directive and became applicable on April 20, 2016.

For more information:  Mechanical EngineeringDirective 2014/34/EU

NOISE EMISSION OF OUTDOOR EQUIPMENT
NOISE EMISSION OF OUTDOOR EQUIPMENT

Machines used outdoors are subject to CE marking requirements.  Noise emission levels are covered separately.  The sample mandatory label shown above specifies noise emission levels.

For more information:

Noise Emissions

steering wheel mark - MARITIME LOGO
STEERING WHEEL MARK - MARITIME LOGO

Shown above is the equivalent of a CE marking, but for marine equipment.  It applies to equipment for use on board any new EU ship, wherever the ship is situated at the time of construction. In addition, the mark also applies to equipment placed on board existing EU ships, whether for the first time or to replace equipment already carried on board. This regulation does not apply to equipment already on board on the date on which the directive entered into force in 1997.  The directive applies to the following equipment categories:

  • Life-saving appliances
  • Marine pollution prevention
  • Fire protection
  • Navigation equipment
  • Radio-communication equipment

A revised Marine Equipment Directive (2014/90/EC) was adopted in July 2014 and is applicable since September 18, 2016.

For more information:

Directive 2014/90/EC

TEXTILES

Textile products must be labeled or marked whenever they are put on the market for production or commercial purposes. The names, descriptions and details of a textile’s fiber content must be indicated on products available to consumers. With the exception of trademarks or the name of the undertaking, information other than that required by the directive must be listed separately. Member States may require that their national language be used on the labeling and marking required by the directive.

For more information:

Textiles Legislation

Footwear Mark
Footwear Mark

Labels must convey information relating to the upper, the lining and insole sock, and the outer-sole of the footwear article. The information must be conveyed by means of approved pictograms or textual information, as defined by the directive.

The label must be legible, firmly secured and accessible. The manufacturer or the authorized agent established in the Community is responsible for supplying the label and for the accuracy of the information contained therein. Only the information provided for in the directive needs to be supplied.  There are no restrictions preventing additional information from being included on the label.

For more information:

Footwear

COSMETICS

Containers and/or packaging (in certain cases) must bear, in identifiable, easily legible and visible characters, the following:

  • The name, trade name and address, or registered office, of the manufacturer or person responsible for marketing the cosmetic product within the Community
  • The nominal contents at the time of packaging (by weight or volume)
  • The date of minimum durability indicated by “Best before end”, for products with a minimum durability of less than 30 months. In this case the following must figure on the packaging:
Hour-Glass-Symbol
Hour-Glass-Symbol for Cosmetics
  • The period after opening during which the product can be used without harm to the consumer, for products with a minimum durability of less than 30 months (indicated by a symbol representing an open cream jar, as shown below):
Open Cream Symbol
Open Cream Jar Symbol
  • Particular precautions for use
  • The batch number or product reference, for identification
  • The product’s function

If it is impossible for practical reasons to print on the packaging all the conditions of use and particular `warnings, an enclosed leaflet, label or tape has to be provided. In this case, the following symbol will then have to be on the packaging:

Enclosed Leaflet Symbol
Enclosed Leaflet Symbol

The Member States are to draw up procedures for providing the information set out above in the case of cosmetic products that have not been pre-packaged. The product function and list of ingredients also have to appear on the container or packaging. Member States may stipulate that the information on the label is provided in their national or official language(s).

About the labeling of nanomaterials present in cosmetics:

The Cosmetics regulation indicates that from July 2013 “all ingredients present in the form of nanomaterials shall be clearly indicated in the list of ingredients” and that “the names of such ingredients shall be followed by the word ‘nano’ in brackets.”

For more information:

Regulation 1223/2009

Market Research Report on “EU Cosmetics Legislation”

DANGEROUS SUBSTANCES

Regulation on the Classification, Labeling and Packaging of Chemicals
 

Dangerous Substances Symbols
Dangerous Substances Symbols

  The labeling of dangerous substances must indicate the following:

  • The name of the substance
  • The origin of the substance (the name and address of the manufacturer or distributor)
  • The danger symbol and an indication of danger involved in the use of the substance
  • A reference to the special risks arising from such dangers.

The dimensions of the label must not be less than a standard A8 sheet (52 x 74mm), and each symbol must cover at least one-tenth of the label’s surface area.  Member States may require their national language(s) to be used in the labeling of dangerous substances.  Where the packaging is too small, the labeling may be affixed in some other manner.  The packaging of products considered dangerous which are neither explosive nor toxic may go unlabeled if the product contains such small quantities of dangerous substances that there is no danger to users.

Symbols must be employed if the substance can be defined as any one of the following (as shown above):  explosive, oxidizer, flammable, harmful, toxic irritant, corrosive, or harmful to environment.  Containers of hazardous substances should include, in addition to the appropriate symbols, a raised triangle to alert the vision-impaired to their contents. Note that this directive has undergone numerous amendments relating, amongst other things, to the marking and labeling of additional substances.  Accordingly, it is advisable to consult all literature.

Regulation 1272/2008 implements the classification, labeling and packaging requirements for chemicals based on the Worldwide United Nation’s Globally Harmonized System (UN GHS).

For more information:  Regulation 1272/2008/EC on the classification, labeling and packaging

Legal Metrology and Metric Units of Measurement

This legislation specifies permissible ranges of nominal quantities, container capacities and the weights or volumes of prepackaged products.  Manufacturers are advised to take note that all labels require metric units, although dual labeling is also acceptable.

For more information:   Legal Metrology

PRICE DISPLAY

The directive requires an indication of the selling price, and price per unit of measurement, on all products offered to consumers. The aim is to improve the information available to the consumer and to facilitate price comparison. This information must be unambiguous, clearly legible and easily identifiable. If advertising mentions the item’s selling price, it must also indicate its unit price. For products sold in bulk, the unit price is the only item whose indication on the label is mandatory. National authorities may provide alternatives for products sold by small retail business operations.

For more information:

Directive 98/6/EC on the indication of the prices of products offered to consumers.

AUTOMOTIVE

Automotive e4 label
e4 Label

As specified under the various directives relating to automobiles.  The number shown in the rectangle on the label indicates the particular Member State in which the approval process was conducted.  A “base approval number” must also be provided adjacent to this certification.  This four-digit number will correspond to the directive and type of device in question.  The country-number correlation is as follows (this is not an exhaustive list):

1

Germany

6

Belgium

18

Denmark

2

France

9

Spain

21

Portugal

3

Italy

11

UK

23

Greece

4

Netherlands

13

Luxembourg

24

Ireland

For more information:

All existing directives on motor vehicles, in chronological order, available online at:

Existing Motor Vehicles Directives

PHOTOMETRY

e4 circle mark for vehicle lights
e4 Circle Symbol for Vehicle Lights

A similar marking is an ‘E’ surrounded by a circle, which applies to the testing of headlight lamps, brake light lamps and turning signal lamps of all vehicles seeking EU market entry. These include consumer vehicles, low-volume production trucks, light and heavy goods vehicles, trailers, motorcycles, cranes, agriculture and forestry tractors, and special-purpose and off-road vehicles.

For more information:

Automotive Legislation

TIRE LABELING

Tire Label Mark
Tire Label Mark

Tire label legislation requires that tire manufacturers declare fuel efficiency, wet grip and external rolling noise performance of C1, C2 and C3 tires (i.e. tires mainly fitted on passenger cars, light and heavy-duty vehicles).

The objective of the regulation is better information for the consumer and a contribution to a more energy efficient transport policy.

For more information:  Energy Topics ; Directive 1222/2009/EC; Directive 288/2011/EC

PACKAGING MATERIAL

The EU Packaging and Packaging Waste Directive harmonized member state legislation regarding packaging material composition and the management of packaging waste. The composition of packaging material is addressed in a series of EU-wide standards. For the management of packaging waste through recycling collection targets and recycling systems, Member States have adopted voluntary markings for products mentioned in the following pages.

For more information:  Directive 94/62/EC

Wood Packaging Mark
Wood Packaging Mark

WOOD PACKAGING

Like the United States, the EU has adopted legislation to ensure pest control in wood packaging.  The marking used for regulated materials is based on the International Plant Protection Convention compliance symbol shown above.

For more information:  Requirements for wood packaging and dunnage

VOLUNTARY MARKS AND LABELS

MATERIALS IN CONTACT WITH FOOD MARK (WINE GLASS AND FORK)
WINE GLASS AND FORK MARK

Manufacturers of containers, plates, cups, and other material that is intended to come into contact with food are required to check the compliance of their product with EU chemical safety requirements. Using the symbol shown above shows compliance with these requirements.  It is mandatory to comply with the legislation, but the use of the symbol is voluntary.

For more information:  Legislation on Food Contact Materials

THE e-MARK

 

eMark metrological "passport" to facilitate the free movement of prepackaged goods
The e-Mark

The e-mark, shown above, acts as a metrological “passport” to facilitate the free movement of prepackaged goods.  It guarantees that certain liquids and other substances have been packed by weight or volume in accordance with the directives.  While compliance is not mandatory, free movement throughout the EU is guaranteed for prepackaged products that do comply with the provisions of the directive.

Containers with an e-mark also bear an indication of the weight or volume of the product, known as its “nominal” weight or volume. The packer (or importer, if the container is produced outside the EU) is responsible for ensuring that the containers meet the directive’s requirements.

For more information:  Prepackaging

THE ECO-LABEL

 

the eco label logo (flower with an e)
Eco Label Mark

The European Eco-label enables European consumers, including public and private purchasers, to easily identify officially approved green products across the European Union, Norway, Liechtenstein and Iceland.  Introduced in 1992, the label communicates to the customer that the marked products meet specific eco-friendly criteria that have been developed to apply to everyday consumer goods and services.

The symbol may apply to the following 27 product and services groups:

All-purpose cleaners and cleaners for sanitary facilities

Household cleaning products

Textile products

Bed mattresses

Laundry detergents

Tissue paper

Campsite Services

Light bulbs

Tourist accommodation service

Copying and graphic paper

Lubricants

Vacuum cleaners

Detergents for dishwashers

Paints and varnishes

Washing machines

Dishwashers

Personal computers

Wooden coverings

Footwear

Printed paper products

Wooden furniture

Furniture

Refrigerators

 

Growing media and Soil improvers

Soaps, shampoos and hair conditioners

 

Hand dishwashing detergents

Soil improvers

 

Hard floor coverings

Televisions

 

Heat pumps

Textile coverings

 

Manufacturers should be aware that similar eco-friendly markings are often used nationally, such as the Nordic Swaan or the German Blue Angel shown below.

 

Nordic Swan or the German Blue Angel
Nordic Swan or the German Blue Angel Markings

The Eco-label program has recently been expanded to cover fish and fishery products.  This means that eco-labeled products have been produced in accordance with specific environmental standards.

Private Eco labels have been developed by the seafood industry to “influence the purchasing decision of consumers and the procurement policies of retailers selling seafood products, in order to reward producers involved in responsible fishing and aquaculture practices leading towards sustainable use of natural resources.”

There are multiple eco-label schemes, and logos, developed by a variety of operators and according to different characteristics. This confusing situation has led to a need for harmonization and coherence. In response, the UN Food and Agriculture Organization (FAO) has developed a “Guideline for the Eco-Labeling of Fish and Fishery Products from Marine Capture Fisheries.”

The U.S. government has decided not to engage in the development of such marketing tool. Instead, NOAA Fisheries has developed a comprehensive website where stakeholders, including consumers, can find facts about a specific species of fish and related fisheries. Consumers can then make their own purchasing choice: Fish

The European Commission is currently preparing, at the request of the European Parliament and the Council, a feasibility report on options for a Union-wide eco-label scheme for fishery and aquaculture products. Some EU Member States have already created their own National eco label.

For more information:  European Eco-Label websiteEco-labels for Fisheries and aqua products

RECYCLING

Chasing Arrows Recycling Symbol
Chasing Arrows Recycling Symbol

The “mobius loop” (sometimes known as the “chasing arrows”), based on an international standard, (sometimes known as the “chasing arrows”), may be found on products throughout Europe. This symbol is meant to help consumers identify and participate in recycling initiatives for product packaging and materials.  As well as being used on printed packaging, the chasing arrows symbol is sometimes featured in the molds of glass, metal, paper, or plastic products. Various kinds of loops indicate whether the product is recyclable, recycled or contains recycled material.

For more information: https://ec.europa.eu/environment/waste/target_review.htm

Plastics

Plastic Mark Symbol (PET and number)
Plastic Mark Symbol (PET and number)

The symbol above is an example of how a plastic’s type may be indicated on a product. As part of the EU voluntary identification system for plastics, the following marks are used for the most common types of plastics (Decision 97/129/EC):

EU Number

Abbreviated Description

Full Plastic Description 

1

PET

Polyethylene Terephthalate

2

HDPE

High Density Polyethylene

3

PVC

Poly Vinyl Chloride

4

LDPE

Low Density Polyethylene

5

PP

Polypropylene

6

PS

Polystyrene

Glass

Recyclable Glass Symbol
Recyclable Glass Symbol

There are no EU-wide symbols used to designate the recyclable nature of glass.  However, it is certainly encouraged on the national level with an array of symbols.  The one shown above is just one small sample of the total existing to show recyclability.

GREEN DOT

Green Dot Symbol
Green Dot Symbol

The Green Dot system is a scheme in which participating organizations coordinate the collection, sorting and recovery of used packaging.  This system is administered according to national packaging laws (adhered to by packaging manufacturers, fillers, retailers and importers), and it should be noted that all participating national systems operate independently. The umbrella organization, PRO-Europe, is responsible for managing the Green Dot labeling system in Europe.  More than 460 billion pieces of packaging marked with the Green Dot, shown above, are distributed worldwide. Interested applicants should contact one of the national administering authorities:  Pro Europe