Environmental Scoring: When Will Mandatory Deployment Hit Fashion Articles in France?

Definition of environmental labelling and eco-score

Before delving into the process of implementing environmental labelling and the associated methodology, it is important to understand what it entails.

Environmental labelling is a system that informs consumers about the environmental impacts of a product throughout its lifecycle.

It takes the form of a score (e.g., a scale from A to E or 1 to 100), which can be supplemented by sub-scores for specific impacts. The score is calculated using a transparent and established methodology based on life cycle assessments (LCAs). For more information, you can refer to our dedicated article on the methodology of environmental labelling.

It allows consumers to position a product on a quantified scale of environmental performance, compare it to other products within the same category, and make informed purchasing decisions.

It also serves as an effective communication tool for brands to highlight their eco-design efforts, as they can rely on the criteria during the product development phase.

It should not be confused with the mandatory product information sheet regarding environmental qualities and characteristics, as required by Article 13 of the AGEC law. This sheet presents certain qualitative characteristics of the product (e.g., country of manufacture, presence of hazardous substances), but not an environmental impact calculation.

Timeline of environmental labelling in France

With the AGEC and Climat et Résilience (Climate and Resilience) laws, environmental labelling is currently taking shape in France. However, this follows a long process that began with the Grenelle Environmental Roundtable in 2007. Let's review the key dates and milestones for this score, which have paved the way for its implementation on textile products, where it will soon be mandatory.

1. 2007-2013: The Grenelle Environmental Roundtable lays the foundations for environmental labelling.

The Grenelle 1 and Grenelle 2 laws of 2009 and 2010 were enacted to fulfill the commitments made during the Grenelle Environmental Roundtable in 2007. They introduced the principle of informing consumers about the environmental impacts of the products they consume, including greenhouse gas emissions.

This period marked the beginning of a consultation process led by AFNOR (French Standardization Association) and ADEME (Environment and Energy Management Agency) to determine sector-specific relevant indicators, best practices, and overarching impact assessment methodologies. In particular, the "GT5" working group was responsible for developing a technical framework for environmental labelling in the clothing sector.

An initial experimentation phase took place between 2011 and 2012, during which voluntary brands from various sectors tested environmental labelling with consumers. A report was subsequently submitted to Parliament.

The report confirmed the interest in environmental labelling based on life cycle assessments (LCAs) but highlighted methodological and technical difficulties, as well as potentially significant implementation costs. Common methodologies for each sector had to be developed, but in the meantime, work on product impact databases (such as ADEME's IMPACTS database, which was replaced by the Empreinte database) needed to continue.

This marked the beginning of a phase where the environmental labelling approach was guided by the recommendations of sector-specific working groups but remained flexible and voluntary.

2. 2015: The Energy Transition Law seeks to limit greenwashing.

As more companies began using environmental claims to characterize their products, measures to combat greenwashing were introduced in French law. Article 90 of the Loi de Transition Énergétique pour une Croissance Verte (LTECV, Energy Transition Law for Green Growth) requires producers and distributors to substantiate any environmental claims with relevant data on the overall environmental performance of the product.

The objective is to prevent brands from misleading consumers by making their products appear more environmentally friendly than they actually are, and to differentiate sincere eco-design efforts from false claims.

The LTECV provided a boost to the environmental labelling project as a useful tool for companies to ensure compliance. A well-constructed environmental score enables them to evaluate the environmental performance of their products based on a relevant methodology and communicate that performance reliably.

3. 2017-2020: Environmental labelling is pre-deployed in five pilot sectors.

In 2017, a new experimentation phase began to consolidate the technical framework developed by ADEME. Environmental scores were pre-deployed in five pilot sectors:

• Apparel
• Food
• Hospitality
• Furniture
• Electronics

The aim was to test impact calculation tools and reference frameworks, assess their usefulness in guiding eco-design efforts, and evaluate their effectiveness in communicating product performance to consumers.

In the fashion sector, companies like Decathlon and Okaïdi deployed environmental scores on their products and submitted reports to ADEME.

During this period, two additional texts further advanced environmental labelling in France:

• One of the 50 measures outlined in the Feuille de Route Économie Circulaire, (FREC, Circular Economy Roadmap) published in early 2018 focuses on the voluntary deployment of environmental labelling, initially in the five pilot sectors and subsequently in other sectors.
• The CESE (Economic, Social, and Environmental Council) published an opinion in March 2019, inviting the government to adopt a proactive policy on environmental labelling to follow up on the FREC (Circular Economy Roadmap). The opinion included 20 recommendations, notably suggesting legislation for a unified mandatory environmental labelling system that is clear and readable for consumers, with two levels (a single score and the possibility to access detailed information).

4. Since 2020: The AGEC and Climat et Résilience (Climate and Resilience) laws establish mandatory environmental scoring

With the aim of transforming all sectors of the French economy, the AGEC (Anti-gaspillage pour une Économie Circulaire, Anti-Waste for a Circular Economy) law was enacted in February 2020. One of its goals to reduce resource consumption and waste generation is to provide better consumer information.

Article 15 of the AGEC law introduces a voluntary framework for environmental labelling, which will subsequently become mandatory, with a priority focus on the fashion sector. The article stipulates an 18-month experimentation phase to evaluate different environmental labelling methodologies (calculation methodology and display modalities) in order to determine the system for each sector.

This article was later repealed with the publication of the Climate and Resilience law in August 2021. It was replaced by Article 2 of this law, which clarifies and strengthens the provisions for environmental labelling.

Here are the four key elements to remember from Article 2 of the Climate and Resilience law:

• Environmental labelling will be made mandatory through a decree that establishes the methodology and display requirements for each product category, following an experimentation phase. This will be prioritized for apparel articles.
• The labelling should be available to consumers at the time of purchase.
• It should provide clear and reliable information on the product's impact throughout its lifecycle, specifically addressing greenhouse gas emissions.
• Relevant indicators specific to each product category, including greenhouse gas emissions, biodiversity, and water and natural resource consumption, should be considered.

In line with the AGEC and Climate and Resilience laws, the ADEME has launched a new phase of experimentation for environmental labelling on clothing. The process involves three major steps:

• ADEME's call for projects known as "XTex" until November 2021, allowing various stakeholders to propose alternative methods to ADEME's technical framework.
• Experimentation with the selected methods from February to September 2022.
• Evaluation of the XTex experimentation results and submission of a report to Parliament in 2023.

Based on the findings of this report, a methodology will be developed. The goal was to validate a definitive version of environmental scoring for clothing by the end of 2023, accompanied by the publication of a decree specifying the mandatory display requirements.

It is worth noting that on the 18th of March 2023, the Secretary of State for Ecology, Bérangère Couillard, communicated the post-XTex experimentation work orientations.

During a meeting with textile companies, federations, NGOs, consumer associations, she identified eight impact criteria that are being further investigated to be considered in the environmental score calculation. Learn more in our article dedicated to the environmental scoring methodology.

The implementation timeline that has been then communicated is the following:

• 2024: voluntary display of the eco-score on fashion articles
• 2025: start of the mandatory display

As of December 2023, the implementation decree has not yet been published, and the timeline is likely to be postponed.

Toward European Environmental Labelling

With the Climate and Resilience law and the XTex experimentation, France is entering the final stretch of mandatory environmental labelling, which is expected to start in 2025 for fashion articles, after a voluntary phase in 2024.

Taking inspiration from the French approach, the European Commission has been working since 2013 to establish a common European methodology based on the Product Environmental Footprint (PEF) framework.

Thus, the communication modalities for environmental information are expected to be harmonized at the European level. We will provide an update on this harmonization in an upcoming article.