France

Status of the current legislative process

No draft implementation has been published yet. 

The French authorities indicated that this Directive will be transposed in the next Law containing various provisions adapting French law to European Union law ("DDADUE").

Link to the draft (if available) 

N/A - no draft Act has been introduced to date

Does the implementation go beyond EmpCo requirements? 

Yes, French existing legal framework before 2025  partially goes beyond what will be prohibited by EmpCo: 

• Law n°2020-105 of 10 February 2020 for the fight against waste and for a circular economy ( “AGEC law”) prohibiting the use green claims such as "biodegradable" and "environmentally friendly" or any other equivalent term on product and packaging. 
• Law n° 2021-1104 of 22 August 2021 on combating climate change and strengthening resilience to its effects (the “Climate and Resilience Law”)  
  
  • prohibiting as a principle  the “advertising for the marketing or promotion of fossil fuels, 
  • regulating the use of carbon neutral claims requiring that advertisers, that use wording indicating that the product or service is carbon-neutral or has no negative impact on the climate in advertising, provide specific evidence of carbon neutrality. 

Are there any comments from relevant authorities on the interpretation or enforcement of the national implementation?  

Yes

On 30 September 2025, the French authorities published a note on the website of the French Authority for Competition, Consumer Affairs and Fraud Control  (“DGCCRF”) concerning the impacts of the upcoming transposition Directive 2024/825 on Empowering Consumers ("EmpCo Directive") into French law.

In particular, French authorities have addressed key transposition issues in the aforementioned note related to these topics:

• On Sustainability labels: under the Directive, sustainability labels must meet stricter requirements. Consequently, internal labels and non-verified labels that do not employ a third party to verify compliance with specifications will be prohibited.
• On Generic environmental claims: The absolute prohibition of generic claims (such as "biodegradable", "environmentally friendly" and equivalent terms) on products and packaging (only) will need to be reviewed. Indeed, the EmpCo Directive extends this prohibition EU-wide across all media (not solely products or packaging) and allows such claims where it can be demonstrated excellent environmental performance through EU Ecolabel or Type I eco-labels, specifying supporting criteria. As a result, French authorities confirmed Article L.541-9-1 requires amendment to ensure consistency with the EU Directive. 
• On GHG offsets impact claims: the EmpCo Directive added to Annex I of the Unfair Commercial Practices Directive 2005/29/EC (the 'blacklist' listing misleading practices prohibited in all circumstances) an absolute prohibition on environmental claims asserting neutral, reduced or positive GHG impact based on offset mechanisms. Consequently, French authorities acknowledged the national transposition of this prohibition will lead to the abrogation of the rules provided by Article 12 of the Climate & Resilience Law currently regulating carbon neutral claim (see above). 

Will the national implementation be applied in a Business-To-Business (B2B) context? 

N/A

Is there a green claims guide/guidance in your country? 

Yes

Green Claims Guidelines has been adopted in France, by the National Consumer Council (CNC) and the French economic regulation and consumer protection authority (DGCCRF - General Directorate for Competition, Consumer Affairs and Fraud Control) on 20 March 2023. The guidelines are available here (in French only): https://www.economie.gouv.fr/files/2023-05/Guide_allegat_environ_fr_2012.pdf?v=1685025927 

The first part covers the definition of environmental claims, environmental information and labels, and the legal framework for claims whereas the second part covers details and clarifications concerning the various existing environmental claims and claims relating to companies.  

These guidelines also contain two appendices, summarizing (i) the mandatory dematerialized system to provide information on the environmental qualities and characteristics of products and packaging and (ii) methods to establish a fair environmental claim. 

What are the sanctions and penalties?  

The new EU requirements will be implemented within the provisions prohibiting misleading commercial practices. Non-compliant environmental claims will therefore be sanctioned under the same legal framework and penalties (i.e. sanctioned by two years’ imprisonment and a €300 000 fine, a turnover-based fine, or a fine up to 80% of the expenses incurred in carrying out the advertising or practice constituting the offence, as well as by complementary sanctions).

Does the national implementation answer the following questions:  

(1) whether sustainability labels can take the form of text; 
(2) whether generic environmental claims can be used or are they banned unless you have recognised excellent environmental performance; 
(3) whether GHG impact claims based on GHG offsets are banned only if offsets are the sole basis, or even if offsets and GHG reductions are combined.

N/A