Deciphering the final decree on textile environmental cost labelling

Yesterday, the French Ministry of Ecological Transition announced the launch of a public consultation on the decree for the environmental labelling of textiles.

At a time when more and more consumers are looking to buy environmentally-friendly products, environmental labelling is becoming a crucial tool. By providing clear, standardized information on the environmental impact of textile products, the government hopes to increase transparency and encourage consumers to make more sustainable choices.

A decree focusing on "environmental cost

The main principles

This decree introduces a key measure: the "environmental cost" of textile products, expressed in impact points. This cost reflects the overall environmental impact of a product (manufacturing, raw materials, transport, etc.) and is intended to guide consumers in their choices.

The aim is to enable consumers to compare products in a transparent way, and to integrate environmental impact into their purchasing decisions.

Key definitions

This decree introduces precise concepts for the environmental display of textile products:

• Remanufacturing: making a new product from existing items, as opposed to simply repairing them.
• Placing on the market: concerns only new products, excluding second-hand.
• Producer: brands responsible for designing and marketing their products under their own name.
• Importer: includes marketplaces like Amazon or Shein that sell products to the French market.
• Product reference: each variant (composition, color, texture) is considered as a unique reference, requiring separate calculations for each variation.
• Digital portal: a tool developed by the French government to centralize and publish the environmental costs of products.

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Products concerned by environmental cost labelling

The decree applies :

• Clothing textiles intended for consumers (new or remanufactured, but not second-hand or professional garments).
• Products placed on the national market for the first time.

The product categories considered are at least the following: Boxer / briefs, boxer shorts, socks, shirts, jeans, skirts / dresses, swimwear, coats / jackets, pants / shorts, sweaters, t-shirts / polo shirts.

Exclusions :

• Textile clothing products in which more than 20% of the mass consists of materials other than textile fibres
• Textile clothing products for which more than 20% of the mass is made up of materials whose contribution to the calculation of the environmental cost is not modelled in the methodological note.
• Products with electronic components (e.g. connected clothing).

The announced timetable for the introduction of environmental costs

Here is a summary of the timetable for adoption and implementation of the decree:

1. Until December 19, 2024: Final national consultation
2. January 2025: notification to the European Commission, which has three months to approve the decree.
3. April 2025 - April 2026: test phase
   1. Only brands will be able to calculate and register their environmental costs on the public portal.
   2. No third party may publish a score without their agreement.
4. From April 2026 : widespread deployment
   1. If a brand hasn't published its environmental cost, any player can calculate and register it.

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Environmental labelling obligations

Transparent communication

Today, there is no obligation to communicate the environmental impact of a textile product. However, once a brand decides to do so, it must comply with certain rules.

The main obligations of brands are as follows:

1. Calculate the environmental cost using the Ecobalyse reference methodology.
2. Submit this environmental cost on a public declaration portal that will soon be available.
3. Use the official visual provided by the authorities to communicate this environmental cost.
4. If the communication is dematerialized, a link must be provided to the information used to calculate the environmental cost.

In addition, if a brand communicates another environmental score, such as the PEF (Product Environmental Footprint) score, it must also display the environmental cost calculated according to the decree's methodology. These two scores must be presented in equal measure, without one being emphasized to the detriment of the other.

The declaration portal: a key issue for brands

The decree provides for the creation of a public declaration portal. This portal will play a crucial role, as it will store and make public all data relating to the environmental costs of products.

Why is this portal important for brands?

• Each textile product can have only one environmental cost registered on the portal.
• Brands therefore have priority in calculating and filing their own environmental costs. If a brand fails to do so, other players, such as associations or rating applications (for example, along the lines of Yuka for the Nutriscore), will be able to do it for them.
• By filing the environmental cost, brands can also update it every three months if changes are made, such as a change of supplier or product improvement.

This portal will thus become a public database serving as a reference for the environmental costs of each textile product. From 2026, any player will be able to calculate and communicate this cost, even if the brand has not taken the initiative.

The official visual and display methods

To standardize communication, an official visual will be used to present the environmental cost. Unlike a scale of letters (A-B-C-D-E), this visual proposes an overall score representing the product's environmental cost.

The government's aim is to make it easy for consumers to compare the environmental impact of different garments. For example, a t-shirt might have an impact of 400 points, while a heavier coat might have an impact of 1,000 points. The aim is for each consumer to be able to take a global view and set an "environmental budget" when buying clothes.

In terms of display rules :

• If the score is displayed on the shelf (for example, next to the price), it must be the same size as the price font.
• On a physical label, it must be visible and legible, and must not be hidden.
• When displayed online, a link must be added to redirect to the calculation details and parameters used.

For the time being, there is no obligation to communicate environmental costs. However, in 2027, convergence at European level will lead to a general obligation to communicate, in conjunction with work on the Digital Product Passport and the PEF (Product Environmental Footprint).

How can brands prepare for this?

The decree offers brands a transition period to prepare for these new rules. This period is a real opportunity to put in place effective processes for data collection, eco-design and communication.

For effective preparation :

• Brands need to start collecting the data they need to assess the environmental impact of their products, such as material composition and production sites.
• Work on traceability is essential, as the mandatory information to be communicated is that already required by other regulations, such as the AGEC law.

The Waro solution is there to support brands in this transition, whether in terms of impact reduction strategy, regulatory compliance, or the integration of the tools needed to calculate and file environmental costs on the portal.

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