FAQ on the decree to display the environmental cost of textiles

The French Ministry of Ecological Transition recently announced the launch of a public consultation concerning the release of a decree on the environmental display of textile products.

This announcement raised many questions about the content of the decree: obligations, products concerned, declaration portal, durability, communication, level 2 criteria, and much more.

Check out our comprehensive FAQ, with over 50 answers to the most frequently asked questions.

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Decree obligations

Is it compulsory to communicate the environmental cost of your products?

No, it's a voluntary display. Brands are not obliged to communicate it. However, if a communication is made on an aggregated impact score, it must respect the obligations of the decree and its orders.

Are all brands affected, or are there volume/sales thresholds?

Given the absence of any regulatory obligation, all brands, whatever their volume or sales, can choose to communicate the environmental cost of their products.

Once a brand undertakes to communicate this data, it is subject to the obligations set out in the decree.

Is it possible to communicate another impact score?

If another aggregated environmental impact score is communicated, then the environmental cost must be communicated and the rules for its use must be respected.

The other aggregate score must not be confusing or inconsistent with the environmental cost.

If a producer submits his environmental cost to the portal in the 1st year, can a third party use it directly, or will it have to wait until the end of the test year before a third party can use it?

Yes, once data has been deposited on the portal, it becomes public (environmental cost and associated data) and can be used immediately, even during the first year.

Is it compulsory to place a calculated environmental cost on the portal if it is only used internally?

No. Deposit on the portal is only required if the environmental cost is publicly disclosed.

In the event of an inspection, what proof will be required to justify the data entered for the calculation?

An instruction from the DGCCRF will later specify the evidence to be provided to justify the data used during an inspection.

What is the deadline for complying with the decree in terms of communication if you already have an environmental communication in progress?

Apart from the test year, no specific deadline has been set. However, the decree will not be signed for several months, which gives us plenty of time to prepare.

How do you manage the dual role of producer and distributor?

For products for which you are a distributor, you have to wait unless your partner agrees, so that he can make his own calculations.

Can a third party calculate and communicate another score (e.g. PEF score) during the 1st year?

Yes. During the first year, the decree does not bind third parties.

Is the third party obliged to have specific information to make the calculation and communicate?

Yes, the purely mandatory parameters for calculating environmental costs are already public (composition, weight, 3 stages of the AGEC law). Default values are available for non-mandatory parameters to facilitate calculations.

Does Ecobalyse have to be used to calculate environmental costs?

No, Ecobalyse is the reference calculation engine, but it's not mandatory.

It is also possible to use the methodological guide to carry out your calculation using another calculation engine.

Which product categories are affected or likely to be affected?

The products concerned include :

• Boxer/Slip
• Socks
• Shirts
• Jeans
• Skirts/Robes
• Swimwear
• Coats/Vests
• Trousers/Shorts
• Sweaters
• T-shirts/Polos

What are the exclusion rules?

The following products are excluded:

1. Second-hand products.
2. Products in which more than 20% of the mass is composed of materials other than textile fibres
3. 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 included in the methodological notice (i.e. is not present in the list of Ecobalyse materials).
4. Products incorporating electronic components.

Is there a material definition (fiber, leather, etc.)?

Textile fibers include cotton, viscose, polyester, wool, etc. Leather is not a textile fiber according to the decree's methodology.

Does this apply to lingerie?

Yes, lingerie products are concerned if they meet the criteria for textile fiber composition (at least 80% of the product's total mass). More work needs to be done to model typical bra accessories.

Are accessories (e.g. belts, scrunchies, pouches, bags, totebags, etc.) excluded from the scope?

Accessories are excluded from the scope of the decree. This scope is defined for clothing textiles only, under certain conditions.

Does this apply to PPE (workwear)?

PPE is not concerned, unless it can be purchased directly by end consumers.

Does the decree apply to footwear?

Footwear is not included in the categories covered by the decree, as it is not composed mainly of textile fibers. Only clothing textiles are included.

Are sport-specific textiles (e.g. kimonos) affected?

If the product consists of more than 80% textile fibers and is intended for the end consumer, then it is included in the scope of products covered by the decree.

A product is excluded if its material cannot be modeled using the Ecobalyse? methodology.

Exactly. An update to take better account of missing materials is planned for early 2025. Proxies will be defined to measure the environmental cost of products containing currently missing materials.

Portal

What data must be uploaded to the portal?

Here are the data to be deposited:

• environmental cost calculated in terms of impact points

• a list of the parameters used to perform the calculation, including any specific data used and the justification for these data
• information identifying the product references concerned
• the date on which the reference was placed on the market
• the date on which the environmental cost is calculated
• the legal status of the person making the calculation
• the corresponding version of the methodology used

Does the declaration portal already exist?

No, it is currently under development. Its commissioning is scheduled for Q1 2025, so that it can be used as soon as possible.

What happens if a third party has already filed an environmental claim on my products?

During the 1st year, only brands can calculate and register the environmental costs of their products.

After this 1st year, the brand retains priority for calculating the environmental cost of its products. If a third party does so before a brand, when the brand in turn calculates and submits its environmental cost, the cost submitted by the third party is "crushed" by that of the brand.

Will solutions like Waro be able to deposit environmental costs and associated data on the portal on behalf of their customers?

The declaration portal is designed to facilitate large-scale deployment of environmental costing. It is planned to enable batch filing for both trademarks and the solutions that accompany them.

Are all the data deposited on the portal public, or just the environmental cost?

All data submitted is public: the environmental cost and the data used to calculate it.

Do I need to submit supporting proof of the data used for the calculation on the portal?

No. Level 1 is declarative, no proof is required. Only the data used to calculate the environmental cost must be filed.

Is there a verification system on the portal?

Not directly on the portal. It's the DGCCRF which, when it checks an environmental cost, will retrieve the data deposited on the portal to check, using the Ecobalyse tool, whether the environmental cost has been correctly calculated.

They will also be able to request evidence to justify the data used.

Data and parameters

What data is needed to calculate environmental costs?

Mandatory product-specific parameters:

• product category
• the weight of the finished product
• the nature and percentage of materials making up the product, where these materials represent at least 2% of the total mass of the product and 5% of the total impact of the modeled product
• geographical origin of the weaving/knitting stage
• geographical origin of the finishing or printing stage
• geographical origin of the production stage

Optional parameters for which default values are available :

• whether or not the product is remanufactured
• the number of references in the market segment
• reference price
• company size and repair services offered
• whether or not the geographical traceability of production stages is apparent
• geographical origin of raw materials
• geographical origin of the spinning stage
• if applicable, the type of printing applied to the garment
• if necessary, the application of a fabric-washing process
• the proportion of air transport (post-packaging)
• a list of accessories integrated into the sales unit, including buttons, zips, underwiring, etc.

What are the determining factors that justify 2 different versions of a product being 2 different products?

Each product with a different color or material composition is a different reference.

How do you manage multisourcing (the same reference may be produced by 2 different suppliers, with different geographical origins for materials and manufacturing stages)?

The same rule applies as for displaying traceability under the AGEC law: "When, for a given model, the geographical origin of the stages is different according to the units of the product, the producer or importer indicates the country where the most units in number are produced".

Which reference size should I choose if the one proposed is not part of my range (e.g. I only want "extra size")?

When none of the sizes offered for sale corresponds to the reference size of the decree, choose a size representative of the different sizes offered for the reference in question.

The weight of the finished product is mandatory. What about the weight of each part (e.g. top, lining)?

The weight and composition of each part of the product must be supplied (e.g. main fabric 200g 90% cotton / 10% polyester and lining 100g 100% cotton).

Information is not required for parts representing less than 2% of the product's mass or less than 5% of the product's impact.

Does the product's weight include components such as the hanger?

The mass of the product includes only the final product, without the hanger or elements not integrated into the product, such as packaging.

Durability

Does environmental cost take sustainability into account?

Yes, sustainability is an integral part of the Ecobalyse methodology. There are two aspects that define sustainability:

• Physical (product resistance): currently set at a coefficient of 1 pending completion of the PEFCR project.
• Extrinsic: Emotional sustainability is well taken into account with 3 parameters (range width, encouraging repair and displaying traceability).

Is the repair incentive criterion based solely on the existence of a Refashion-labeled repair service? No more "price" data?

No, the repair incentive criterion breaks down into 2 sub-criteria:

• The difference between the price of the reference and its repair cost.
• The existence of a repair service offered by the brand (this 2nd sub-criterion is not taken into account for very small businesses). The repair service must be certified by Refashion as part of the "Repair Bonus".

How do I define my range width? Exclude outlets? Period exclusion (e.g. sales period)

The range width is defined for the reference segment under study. It must correspond to the number of color references present on the reference sales channel.

The value entered can be observed at any time by the DGCCRF on the reference sales channel, so it must correspond to a maximum of one year.

The range width does not include large size, maternity and handicap references.

Only references corresponding to clothing textiles should be counted. Shoes or bags, for example, should not be counted. References corresponding to clothing textiles but which may not be covered by the regulatory framework (e.g. a cashmere sweater) must be counted.

How do I define my reference sales channel?

The reference sales channel is the brand's website. If there are no online sales on the brand's site (or if the site is an artificial sales channel), a sales channel must be chosen from among the main ones.

Communication

For label communication, should the display be on detachable, disposable labels or on textile labels sewn into the garment?

There's nothing compulsory: the physical display can be made on the element of your choice.

If we communicate a score other than environmental cost (e.g. PEF), are we subject to the requirements of the decree?

Yes, when communicating another environmental score (e.g. PEF), the environmental cost must also be displayed and all associated requirements must be met:

• Submit environmental costs on the reporting portal
• Use the official visual
• If the communication is online, a link must be provided to access the information used for the calculation.
• Environmental cost display must be as large as the "private" score

On the other hand, the communication requirements for your "private" score are specific to you.

Is it just a physical display, not a digitized one?

Both formats are possible. If the display is digital, a link to the data used for the calculation (those deposited on the portal) must be provided.

Can the environmental cost be displayed via a QR code?

Yes, this is permitted and can be integrated into a digital signage strategy.

If we communicate physically, should we also communicate digitally and vice versa?

Not necessarily, it is possible to :

• not to communicate
• communicate only in physics
• communicate exclusively in digital
• communicating physically and digitally

Can the environmental cost be displayed with a click, or does it have to be visible directly?

Each brand is free to display the environmental cost wherever it wishes.

It just needs to be accessible at the time of purchase. If another aggregate score is provided, then the environmental cost should be displayed next to it, and in the same size.

Can we add additional information next to the display to make it easier to understand?

Yes, that's right, it's recommended to help consumers understand and correctly use the environmental cost.

Are average values available by product category?

Example values are provided on Ecobalyse in the "Explorer" tab: https://ecobalyse.beta.gouv.fr/#/explore/textile

Level 2

Is level 2 display authorized?

Level 2 is authorized by the decree. However, in order to communicate information relating to level 2, a methodological note for this level 2 must be drawn up. For the moment, the decree only contains the methodological note for level 1.

It cannot be used until the corresponding methodological manual has been finalized and validated. Work is in progress on the level 2 instructions.

Are we limited to level 1 while awaiting the level 2 manual?

Yes, brands must limit their communication of environmental costs to Ecobalyse level 1, pending finalization of the instructions for level 2.

Other

Where can I find the methodology guide?

Ecobalyse documentation: https: //fabrique-numerique.gitbook.io/ecobalyse

When will the decrees concerning the declaration portal, consistency with other scores and the graphic charter be issued?

Early 2025.

Do you have any further questions on this subject?

Don't hesitate to contact us: https: //www.waro.io/contact

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