The French Eco-score framework has just taken a significant step forward. On November 28th, the Minister of Ecological Transition launched a public consultation on two key regulatory texts, signaling progress toward its long-awaited implementation. This marks an important moment for fashion and textile brands preparing to navigate upcoming environmental labeling requirements.
The French Eco-score, part of the 2021 Climate and Resilience Law, is a methodology for assessing and communicating the environmental impacts of products. It builds on life cycle assessment and evaluates indicators like carbon emissions, water consumption, and biodiversity impact. For an overview of the law and its initial implications, check out our previous blog.
Now, with the framework progressing, here are the key updates we have so far:
The public consultation, running from November 28 to December 19, 2024, focuses on two regulatory texts that define the parameters of the French Eco-score.
Draft Decree: specifies the methodology for calculating environmental impacts and rules for communication. Brands that are voluntarily communicating aggregated environmental product scores must adhere to the Eco-score methodology. Scores calculated using other methods must be consistent with the Eco-score. The decree applies to clothing textiles (new or remanufactured) put on sale on the national market.
Draft Order: Details the product categories, calculation methods, and labeling requirements. This one specifies the logo and various ways to communicate the environmental impacts. The Draft Order also establishes exclusion rules for certain products. For instance, items where more than 20% of the total mass consists of non-textile materials or those made from materials not included in the Ecobalyse database can be excluded if no suitable proxy is suggested by the methodology.
Once the consultation concludes, the proposal will be reviewed by the European Commission, with implementation expected in spring 2025.
The French government plans to notify the European Commission in January 2025, following feedback from the consultation.
The Eco-score and PEFCR (Product Environmental Footprint Category Rules) are being aligned to converge. This is a medium-term goal to make compliance easier for brands across France and the EU.
By April 2025, the PEF A&F (Product Environmental Footprint for Apparel and Footwear) is planned to be finalized. This will allow brands to calculate and communicate both the Eco-score and the PEF Score.
The Ecodesign for Sustainable Products Regulation (ESPR), an EU initiative, will eventually add new requirements for sectors like textiles. However, these specific rules (called secondary acts) are still being developed and will take time.
Currently, there is no official timeline for textiles, and the PEFCR for Apparel and Footwear is still in the recommendation phase, meaning it’s not legally binding yet. With the French Eco-score framework, the goal of the French government is to fill certain gaps in the PEFCR by covering additional categories such as micro-plastics, biodiversity loss, and more regionalization.
It’s important to note that calculating and displaying the French Eco-score remains voluntary. Brands can already use the Eco-score voluntarily, but compliance with specific obligations (outlined in the decree and the order) will only become mandatory once the law is published.
If a brand wishes to communicate the environmental impact of its products, it must:
However, if the brand is already calculating another aggregated environmental score (an aggregated score being one that combines several impact metrics into a single value), such as the PEF score, then:
(If scores are not aggregated (e.g., product carbon footprint, % recycled content), there is no obligation to display the Eco-score)
A centralized portal will require brands to upload their scores, calculation parameters, and related data, with bulk import options available. Other required information includes the calculation date and the legal nature of the entity responsible for performing it. When brands calculate their French Eco-score, they will be obliged to share it on this portal.
Starting one year after the launch of the Eco-score, third parties (e.g. distributors or apps) will be allowed to calculate scores for the brands using publicly available parameters. Third parties rely on default parameters for missing data, which are conservative and result in higher (less favorable) Eco-scores. This happens because third parties lack access to optional, detailed product data, such as specific material choices or production processes, which only brands can provide.
However, scores calculated by brands take priority and override third-party scores (with a maximum delay of one month). Brands can include nuanced details and optional parameters that reflect a more accurate environmental performance of their products, leading to more accurate and favorable scores.
The Eco-score consultation and expected 2025 launch provide an opportunity for brands to prepare now. Here is a timeline to keep in mind:
The Eco-score framework allows for updates to ensure accuracy and reflect improved data:
This structured approach ensures that the Eco-score reflects the most accurate and current information over time.
As the Eco-score framework progresses, new details are emerging about how brands can calculate and communicate their scores effectively. Here are the quick facts we know so far:
Year-Round Validity: Parameters used in the modeling must remain valid year-round, including during sales periods.
Trims Modeling: Updates to better model trims and other smaller components are planned for future methodology iterations.
Product Life Cycle Assessment: Our platform delivers comprehensive life cycle assessments (LCAs) tailored to the most recent Eco-score and EU PEF standards. We automatically calculate the Eco-score for each product, encompassing all 16 environmental indicators required for compliance.
Data Consolidation and Cleaning: Carbonfact consolidates diverse datasets from any source or format, making data management simple and efficient. Missing or incomplete data? Our AI, trained on extensive primary datasets, fills gaps by automatically estimating details such as component weights, dtex values, and process-level steps.
Hotspot Analysis: Carbonfact identifies emission hotspots in your supply chain, helping you focus on areas with the greatest potential for impact reduction. We provide a targeted list of data points to gather from your suppliers, saving your team weeks of time and ensuring a more complete and precise Eco-score.
Proactive Compliance and Reporting: Our platform tracks methodology updates and ensures your scores remain compliant as regulations evolve. Carbonfact generates ready-to-submit reports for the French declaration portal and other regulatory requirements.
The next update (Version 2.7) of the French Eco-score framework will address product range definitions and other refinements. It is scheduled for release shortly, providing more detailed guidance for brands.
We will keep you updated!