The French Eco-score is now officially termed "Environmental Cost," aligning with the Climate and Resilience Law. This rebranding underscores the focus on quantifying the environmental impact of textile products.

What is the French Eco-score?

The French Eco-score 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 Eco-score

The Eco-score 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 Eco-score: Key Regulatory Texts & timing

A recent public consultation, held from November 28 to December 19, 2024, addressed two significant regulatory texts that outline the French Eco-score 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 Eco-score 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.

European Commission Notification: The draft decree and order were notified to the European Commission, with the standstill period ending on May 14, 2025.

Voluntary Phase: Expected to commence in the second half of 2025, allowing brands to adapt to the new requirements.

Mandatory Compliance: From April 2026 labeling compulsory for textile products sold in France. If Brands, by this date, not have published the Environmental Cost, third parties will be allowed to calculate and publish it.

Why and How Brands Should Calculate the Eco-score

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 Eco-score logo when communicating the environmental cost.

How does the French Eco-score align with EU regulations?

The French government plans to notify the European Commission in January 2025. The Eco-score 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 Eco-score and PEF scores.
• The EU's Ecodesign for Sustainable Products Regulation (ESPR) will introduce new requirements for textiles, but these are still in development.

Aligning the Ecoscore with EU PEFCR Standards

In recent months, the French environmental labeling methodology has begun aligning more closely with the EU’s Product Environmental Footprint (PEF) approach. However, key methodological differences still exist, leading to noticeable discrepancies in scores generated by each system—potentially causing confusion for consumers. To address this, the French Eco-score and the EU’s PEF Category Rules (PEFCR) are being progressively harmonized, with the goal of creating a unified framework that simplifies compliance for brands operating in both France and the wider EU.

It’s important to note that the PEFCR for Apparel and Footwear is currently only at the recommendation stage and is not yet legally binding.

Following public consultation, the French government intends to notify the European Commission of its methodology in January 2025. The Commission will have three months to evaluate the proposal. By April 2025, the final version of the Apparel and Footwear PEF is expected to be published. This will enable brands to consistently calculate and communicate both the Eco-score and the PEF score going forward.

French Ecoscore vs EU PEFCR: Key Differences in Methodology

The French Eco-score methodology addresses several of the known limitations of the EU Product Environmental Footprint Category Rules (PEFCR) for Apparel and Footwear. While PEFCR provides a standardized approach to environmental impact assessment, it currently overlooks critical factors such as durability, microfiber pollution, and biodiversity loss. Additionally, it tends to underestimate the environmental impact of synthetic materials like polyester, inadvertently favoring fast fashion.

To offer a more comprehensive and corrective perspective, the French Eco-score introduces several innovations:

• Assessment of Commercial Practices
  Beyond product-level data, the French approach includes an “extrinsic sustainability coefficient” that evaluates brand behavior. This coefficient consists of three parameters:
  • Range breadth – assessing how extensive the product offering is
  • Repair incentives – evaluating whether the brand encourages product repair
  • Traceability transparency – measuring the visibility of supply chain information
  While not an exhaustive definition of fast fashion, these indicators target the most relevant aspects of unsustainable practices.
• Recognition of Synthetic Fiber Impacts
  The methodology explicitly accounts for microfiber pollution from polyester and other synthetic fibers—an impact area currently unaddressed by the EU PEFCR.
• Support for Organic and Local Materials
  The Eco-score gives higher weight to the ecotoxicity criterion in LCA and includes updated inventory data (e.g., for wool), thereby recognizing the environmental benefits of organic and locally sourced materials.
• Inclusion of Emotional Durability
  Although physical durability is not yet incorporated, the methodology does factor in emotional durability, acknowledging the role of long-term consumer attachment in reducing environmental impact.
• Expanded Scope and Data Depth
  Key differences also emerge in the databases and impact categories used. The French database offers greater granularity and introduces two additional impact indicators:
  • Export outside the EU
  • Microfiber emissions

These enhancements make the French Eco-score more tailored to the realities of the fashion industry—especially in addressing fast fashion and synthetic fiber use—while aiming for more meaningful consumer-facing transparency.

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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.

Eco-score Framework and Methodology Overview

The French Eco-score 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 Eco-score 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 Eco-score 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. The labeling requirements apply to all producers, importers, and distributors placing textile products on the French market, irrespective of company size or origin. This broad applicability emphasizes the importance for all fashion entities to align with the new regulations.

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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 Eco-score supplements end-of-life impact calculations to account for this.
• Microplastics: Synthetic clothing contributes significantly to microplastic pollution. The Eco-score accounts for these impacts based on the fiber type, penalizing synthetic materials.
• Non-Physical Durability: The Eco-score considers factors like repairability and traceability, which influence a garment's longevity and, consequently, its environmental cost.

Voluntary Use of the Eco-score

While the French Eco-score 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 Eco-score 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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