Key Takeaways:
When US indie beauty brands start planning an expansion into Europe, many assume that complying with the EU Cosmetics Regulation will be the hardest part. You find a Responsible Person, prepare your Product Information File, adjust your artwork and upload everything into the Cosmetic Products Notification Portal (CPNP), and you’re done. Except… not quite.
There is one country that consistently surprises even the most prepared founders: France.
As a French marketer now working for a clean indie beauty brand in Los Angeles, I spend a significant amount of time navigating packaging regulations on both sides of the Atlantic. And here’s the truth: sustainability legislation in Europe is accelerating fast, and most indie brands underestimate how deeply this affects packaging, timelines, and launch strategy.
Where We’re Currently at… in Europe
To understand what this means for a brand preparing to launch in Europe today, let’s start with the basics. Any cosmetic brand sold in the EU must:
In addition to these EU requirements, since Brexit, brands planning to sell in the UK must also appoint a UK Responsible Person. Most of the regulatory heavy lifting—such as preparing safety dossiers, ensuring correct labeling and managing registrations—is typically handled jointly by your manufacturing partner and your EU/UK regulatory firm. While the list of obligations can sound intimidating, founders should know they are not expected to manage all of it alone. A good RP will guide the process, flag risks early, and make sure your packaging is compliant before it reaches production.
Good Manufacturing Practices, ingredient restrictions, and clear labeling apply across all 27 EU countries. But the moment a brand intends to sell in France, a second layer of obligations appears.
…and in France
France introduced the Anti-Waste for a Circular Economy Law (Loi AGEC) in 2020, and it has become one of the most ambitious environmental laws in the world. We’re talking:
The new sorting system—composed of the Triman symbol and the Info-Tri instructions— must now appear on all household products sold in France, including cosmetics.
And this is where indie brands really feel the pain: this requirement applies to France only.
It’s not like appointing an EU Responsible Person that automatically covers the whole block. This is one country requiring one specific graphic, on both primary and secondary packaging wherever applicable.
If you’re unfamiliar with what the Triman label looks like, here is the symbol that now appears across French packaging. You’ve likely already seen it—not just on cosmetics, but also on food, household products, and even apparel hang tags. Its rapid expansion across categories is exactly why American brands are suddenly noticing it everywhere and wondering why France requires a dedicated graphic when no other EU country does.
Because the Info-Tri system has strict rules about icons, positioning, disassembly instructions, and layout, you can’t just add a recycling logo and call it a day. If you already printed packaging, discovering this requirement later can become a very expensive surprise.
The idea of having one EU-wide box is simply no longer realistic for brands that want to be present in France.
Why Is France So Strict?
There are clear reasons for France’s approach. The country consumes several million tons of packaging waste each year, with sorting efficiency still far below national targets. The government wants to:
Beauty plays an important cultural and economic role in France, and the country sees strict packaging regulation as a way to reinforce leadership in responsible product development.
That’s why the Triman logo accompanied by the Info-Tri sorting instructions became mandatory for household packaging in France, with new packaging placed on the market from September 2022 required to carry the new signage, and a sell-through deadline of March 9, 2023, for older packs.
For brands exporting to other European markets where sorting labels are being discussed but not yet fully defined, Citeo also offers a pictogram-only “export” version of the French label. It requires no translation and can be adapted with country tabs, helping brands anticipate upcoming changes without redesigning their packaging for every market.
Is It Meant to Stay?
Now here’s the twist: even France’s system will not remain unchanged.
In parallel to the AGEC law, the EU adopted a new Packaging and Packaging Waste Regulation (PPWR) in 2024, which will gradually replace the existing packaging directive and reshape packaging rules across the entire Union.
Its goal includes:
One of the most significant changes is the creation of a single, EU-wide labeling system, intended to eliminate the patchwork of national rules that exists today. Once this framework is implemented, national schemes such as France’s Info-Tri will need to evolve or adapt to fit within the EU’s unified approach.
For US founders planning ahead, France is less an outlier and more a preview of where the rest of Europe is headed.
Although the PPWR clearly intends to harmonize packaging labels, the technical specifications of this new EU label have not yet been published. Brands still don’t know what the final pictograms will look like, where they must appear, or how they will coexist with digital identifiers, such as QR codes, that provide additional information on material composition, sorting, and environmental performance.
The European Commission is expected to publish the detailed technical specifications for these EU-wide labels by the end of 2026, via implementing acts. From August 2028, packaging placed on the EU market will need to carry harmonized pictogram-based labels, giving brands roughly a two-year window to update their artwork once the final designs are known.
This doesn’t mean brands should postpone their European launch, but it does mean indie founders need to plan for packaging updates, consider MOQs carefully, and build enough flexibility into their designs to adapt once the new EU-wide system becomes official.
What This Means for Indie Brands
For very small brands entering France in low volumes, an over-label can sometimes be the most realistic short-term solution. It’s not ideal from a sustainability or aesthetic standpoint, but many emerging brands choose this route to avoid the cost and stress of reprinting full packaging runs. As volumes grow—or once the EU publishes its unified labeling rules—transitioning to fully integrated artwork becomes the best long-term strategy.
For indie brands entering Europe, understanding this regulatory landscape early can prevent costly delays, avoid last-minute relabeling, and support stronger long-term planning. France may feel like the most complicated part of the puzzle today, but in many ways it is simply revealing what the rest of Europe is preparing to require. Building packaging that is compliant, future-proof, and ready for long-term growth is no longer optional; it is a strategic investment in international readiness.
Ultimately, whether a brand chooses fully revised packaging or a temporary over-label, the key is to plan early and avoid discovering French requirements at the artwork stage. The brands that succeed in Europe are the ones who anticipate regulatory shifts rather than react to them—especially now that the EU is preparing one of the biggest harmonization efforts in its history.