What is the French Ecoscore?

The French Ecoscore is an environmental cost index displayed on products or services, whether on shelves or online within the French market. It is calculated over the entire life cycle of a product according to a validated reference system. The Ecoscore provides a simple benchmark for consumers, helping them make informed purchasing decisions by comparing products based on their environmental impact.

The objective of the Ecoscore

The Ecoscore aims to provide reliable, easily understandable information to consumers about the environmental impact of goods throughout their life cycle. It considers factors such as:

• Greenhouse gas emissions
• Damage to biodiversity
• Water and natural resource consumption
• Environmental externalities (e.g., pollution)

This system encourages manufacturers and distributors to adopt eco-design practices by providing transparency about the environmental footprint of their products.

Public Consultation on Ecoscore: Key Regulatory Texts

A recent public consultation, held from November 28 to December 19, 2024, addressed two significant regulatory texts that outline the French Ecoscore framework:

1. Draft Decree: This text defines the methodology for calculating environmental impacts and establishes communication guidelines. Brands that choose to voluntarily display aggregated environmental product scores must comply with the Ecoscore methodology.
2. Draft Order: This order specifies the product categories, calculation methods, and labeling requirements. It outlines the official logo and various communication formats while also establishing exclusion criteria for certain items. 

Following the consultation, the regulatory proposal will be submitted to the European Commission for review, with implementation anticipated in spring 2025.

Why and How Brands Should Calculate the Ecoscore

Brands selling clothing in the French market will be required to label their products with an environmental cost score calculated using the approved methodology.

The regulatory texts introduce the following obligations:

• Scope Definition: Specifies the products covered and the parameters for calculating the environmental cost.
• Methodology Compliance: Brands must follow the prescribed methodology when communicating environmental scores.
• Consistency: Environmental cost communication must be consistent with the calculated score.
• Signage Use: Brands must use the official Ecoscore logo when communicating the environmental cost.

How does the French Ecoscore align with EU regulations?

The French government plans to notify the European Commission in January 2025. The Ecoscore and the EU's Product Environmental Footprint Category Rules (PEFCR) are being aligned to simplify compliance for brands across France and the EU.

• By April 2025, the finalized PEFCR for Apparel and Footwear will enable brands to calculate both the Ecoscore and PEF scores.
• The EU's Ecodesign for Sustainable Products Regulation (ESPR) will introduce new requirements for textiles, but these are still in development.

Implementation Timeline for Environmental Labeling

• End of Public Consultation: December 2024
• Notification to the European Commission: January 2025
• Voluntary Display: April 2025 to April 2026
  
  • Brands can calculate and submit their environmental costs on the public portal.
  • Third parties cannot publish scores without brand consent.
• General Deployment: From April 2026
  
  • Third parties (e.g., distributors or apps) can calculate and submit environmental scores if brands haven't published their own.

Ecoscore Framework and Methodology Overview

The French Ecoscore is based on the PEF methodology for Apparel and Footwear, considering the entire life cycle of textile products, from raw materials to manufacturing, use, and end-of-life.

As the Ecoscore framework develops, additional insights have emerged to help brands calculate and communicate their scores more effectively. Below are key takeaways:

• Labeling Options: Brands can display environmental impacts per mass (e.g., points per kilogram) alongside the overall product score.
• Product Range Definitions: Product ranges will be categorized by segment (e.g., men, women, children, plus size) for more precise calculations.
• Repair Services: To be included in Ecoscore calculations, repair services must be recognized by Refashion, the French textile eco-organization.
• Traceability: Brands must ensure traceability details are visible on their website homepage and in-store product tags.
• Year-Round Validity: The parameters used in the modeling must remain consistent throughout the year, including during sales periods.
• Trims Modeling: Future updates will improve the modeling of trims and smaller components to enhance accuracy.

Articles in details

• Article 1: Specifies exclusions, such as single-use textiles, items with over 20% non-textile materials, or electronic components. 
• Article 2: Defines the calculation methodology, detailed in an official guideline. 
• Article 3: Establishes the environmental cost calculation unit as the sale unit (1 bundle = 1 sale unit).
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• Article 4: Specifies that the environmental cost is calculated for each product type, with a theoretical usage duration assigned to each. For products with multiple textile components, costs are calculated separately for each part and summed. Non-textile accessories are modeled as defined in Article 7.
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• Article 5: Details lifecycle impact modeling using the 16 environmental impact categories of PEF Methodology. 
• Article 6: Introduces the non-physical durability coefficient. It is calculated using a formula that combines the below three criteria and their respective weights. This coefficient ranges from 0.67 (minimum) to 1.45 (maximum) and is based on three weighted criteria.
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  The three weighed criteria are:
  - Range diversity (40% weight): The maximum number of product variations offered by a brand within a market segment.
  - Repair incentives (40% weight): The ratio of average repair cost to reference price and whether a repair service is offered.
  - Traceability display (20% weight): Whether the geographical production stages are clearly indicated.
  

• Article 7: Lists mandatory parameters for the environmental cost calculation. They must be based on specific product data, as detailed in the official methodological guidelines: Product category, Weight, Material composition (materials representing at least 2% of total mass and 5% of total impact), and Location (Yarn production, fabric manufacturing, dyeing/printing/finishing and assembly)
• Article 8: Allows additional parameters in the calculation, as defined in the methodological guidelines. Default values can be used if specific data is unavailable, with potential third-party verification.
• Article 9: Requires a standardized environmental labeling graphic for display on both physical and digital platforms.

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Additional Considerations

• Export Outside Europe: The PEFCR assumes clothing is disposed of locally. However, many garments are exported outside Europe and end up in countries with inadequate waste management systems. The French Ecoscore supplements end-of-life impact calculations to account for this.
• Microplastics: Synthetic clothing contributes significantly to microplastic pollution. The Ecoscore accounts for these impacts based on the fiber type, penalizing synthetic materials.
• Non-Physical Durability: The Ecoscore considers factors like repairability and traceability, which influence a garment's longevity and, consequently, its environmental cost.

Voluntary Use of the Ecoscore

While the French Ecoscore is not yet mandatory, brands can voluntarily calculate their scores using the Ecobalyse methodology and an online calculator. Any entity calculating a product's environmental cost must make the following information publicly available:

1. The calculated environmental cost in impact points
2. Parameters and data used for the calculation
3. Product references and market launch dates
4. Date of calculation and the entity responsible for it

Declaration Portal Requirements

A centralized portal will require brands to upload their Ecoscore data, including calculation parameters and other details. Bulk import options will be available to simplify the process. Once brands calculate their scores, they must share them on this portal

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