Decided: the Green Dot in France.

helmut.minor • 12. Juli 2023

Rise again?

The French Circular Economy Law of February 10, 2020 (Art. 62) introduced a new provision in the Environment Code (L541-10-3) on which basis any markings that may cause confusion to consumers regarding the sorting rules would be subject to penalties. The Ministerial Order of November 30, 2020 targeted the Green Dot logo as such a cause of confusion. As a consequence the Green Dot, went under the menace of a potential prohibition.

In a recent decision, however, this menace was taken away by the responsible French authority Conseil d’Etat (CE). The CE concluded that even though the French authorities notified the European Commission about this decision, the communication in fact did not enable the Commission to fully assess the effects of the regulation. Therefore the communication did not suffice to meet the notification obligation of Art. 5 of Directive (EU) 2015/1535 upon the procedure for the provision of information in the field of technical regulations and of rules on Information.

This means that the Green may still be used in France. However, with regard to the extensive introduction of the Triman sorting rule label in France and in the light of the Proposal for a Regulation on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC (Packaging Regulation) which already mentions the confusing character of the Green Dot logo in its recitals (see recital 49), the fate of this logo appears to be foreseeable.

The CE decision may not mark a rise but the ultimate downfall of the Green Dot.

Source:

https://www.conseil-etat.fr/fr/arianeweb/CE/decision/2023-06-30/449872

https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52022PC0677

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