Forthcoming environmental labelling in France: ongoing public consultation to determine methodology and format

The aim behind such scheme is to help companies measure, calculate and communicate the environmental footprint of their products on the basis of reliable, verifiable and comparable information and enable consumers to be informed about the environmental impact of the products they decide to purchase.

Legal context in Europe

In 2013, the European Commission adopted a recommendation to the Member States to use common European methods, known as PEF (Product Environmental Footprint), a multi-criteria method used to measure a product's environmental performance based on the life cycle analysis, a reference method for measuring the environmental impact of a product by considering its entire life cycle.  

The PEF proposes 16 impact indicators covering human health issues, impacts on natural resources and impacts on ecosystems. To make these results easy to understand for consumers, the PEF method has developed the PEF score which is presented in points and gives an overview of the environmental footprint of a product throughout its life cycle. 

Today, there is no regulatory obligation at European level and the PEF method is applied on a voluntary basis.

Legal context in France

Introduced by the "Anti-waste for a circular economy" (AGEC) law of 10 February 2020 the voluntary environmental and social display system was eventually made mandatory by the “Climate and Resilience Law” adopted on 22 August 2021 (Law no. 2021-1104).

In France, however, regulations are becoming increasingly stringent, particularly for priority sectors such as the textile and food sectors.
The list of categories of goods and services for which this obligation will be made mandatory will be set by decree. The decree will also define, for each category of goods and services concerned, the methodology to be used and the display methods adopted.

Environmental labelling will be a measurement that aggregates all the dimensions of the environmental impact generated by a product, taking into account as laid down by Article L. 541-9-11 of the French environment code:

• Greenhouse gas emissions 
  
• Damage to biodiversity
  
• Consumption of water and other natural resources 
  
• The effects of environmental pollution 
  

Just like a price (in euros), a nutritional value (in kcal), the environmental cost quantifies the impact of each product. The higher the score, the greater the environmental cost of the product. 

French methodology of calculation of the environmental footprint

For the time being, France has taken the lead in terms of regulation, but it is foreseeable that other European countries will follow in the years to come. 

Experimentations have been led to determine the methods of calculation and of display to be used for the textile industry. Hence, the French government and the Agency for Ecological Transition (ADEME) are developing their own methodology, which differs in a number of ways from the PEF methodology (although both are based on life cycle analysis). The French authorities are seeking to move closer to the PEF method while adapting it to the situation of French companies and the requirements of French law. The French methodology should therefore include the main principles recommended by the European Commission, while introducing certain adjustments.

The environmental labelling system is made up of several tools for calculating the environmental cost of products and ensuring that the results are comparable. For instance, The ADEME issued general documentation for the environmental impact assessment of clothing products. The government has also published the Ecobalyse platform, an online calculator for estimating the environmental impact of textile and food products (as these categories of products will be the first concerned). The current version of the tool will be upgraded in the coming months to take account of the latest methodological developments. 

These methodologies and tools are not mandatory yet but constitute useful guidelines regarding the requirements that are likely to be put in place: 

• For example, it is provided that for the textile sector, an additional criterion will be taken into consideration: the durability of clothing. The environmental cost will be modulated by a durability coefficient, a high durability coefficient (1.5), for clothing from "ultra-fast fashion" while more eco responsible brands will have a low durability coefficient (0.5). This coefficient will then modulate the environmental cost of a garment downwards for the most virtuous brands and upwards for garments from fast fashion brands.
  
  
• Raw materials are also to be taken into account for the clothing sector as they represent a major impact for the textile industry (20 to 50% of the environmental cost of clothing).
  
  
• The impact of microfibres must also be factored into the environmental cost of a garment. The more persistent a fibre is and/or releases a large quantity of microfibres, the greater its impact. Microfibres are emitted into different compartments (water, air, soil) throughout the life cycle of a garment (dye baths, machine washing, end of life, etc.).

Timeline regarding the entry into force of this new obligation for the textile sector

To this date, environmental footprint display is not mandatory in France.

The textile environmental labelling scheme entered the final public consultation phase on 3 April 2024 after which the French Authorities will take final decisions (on the methods and format) and draw the implementing text of the decree making environmental labelling mandatory. 

According to the authorities, the aim is to roll out official environmental labelling in the textile sector by the end of 2024, on a voluntary basis. And according to the timeline provided by the ADEME, it should not become mandatory before 1 January 2025.