Developments labelling obligations environmental characteristics France: Environmental law: What we know now

We hope to get more clarity from our French counterparts in September. Modint has decided to share this information to keep members updated on the developments, also because this is covered in international media. We are monitoring these developments closely and are working with other European counterparts to supply you with practical information. We have heard rumours that some obligations might be challenged on a EU level, since questions have been raised on the French national law possibly violating the EU single market principle, which calls for harmonised rules. We can not confirm this at this moment, which basically means that we do not know if and how this French law will be put in place.

Update 16/09/2022: Below information is still valid at this moment. Input from France is expected around October 10th.

Below the requirements as they have been laid out by the French law:

Environmental labelling requirements will come into force progressively by 2023 and 2025, according to established scheduling, considering their turnover and the number of units.

Products concerned: Furniture items as well as upholstered seat or bedding products, textile decorative items, new clothing textile products, shoes or household linen intended for private individual, new textile products for the home, excluding those which are furnishing elements or intended to protect or decorate items of furniture;

• From 1 January 2023, for producers, importers and any other marketers who report an annual turnover of at least 50 million euros for the products they have placed on the national market, and who place at least 25,000 units of these products on the national market annually. However, the obligations are not applicable to products for which the last unit will have been placed on the market between January 1 and March 31, 2023.
• From 1 January 2024, for producers, importers and any other marketers who report an annual turnover of at least 20 million euros of products that they have placed on the national market, and who are responsible annually for placing at least 10,000 units of these products on the national market.
• From January 1, 2025, for producers, importers and any other marketer who report a turnover greater than 10 million euros of products, that they have placed on the national market, and who are responsible annually for placing at least 10,000 units of these products on the national market.

France will require companies to make below information available to the consumer. Information must, at least, be digitally available at the time of purchase.

Environmental qualities and characteristics of products

• The amount of recycled material incorporated
• Recyclability: information on the use of renewable resources, on durability, compatibility, reparability, and possibilities for the product of being reused
• The presence of hazardous substances, precious metals, or rare earths
• Geographical traceability of the 3 major manufacturing steps (weaving, dyeing, assembly/finishing)
• The presence of plastic microfibers when the proportion by mass of synthetic fibers is greater than 50%

It is prohibited to include the words "biodegradable", "environmentally friendly" or any other equivalent environmental claim on a new product or packaging intended for consumers.

Recycling

• Statement "predominantly recyclable product" or "mostly recyclable packaging"
• If recycled material represents more than 95% of the product, may include the statement "fully recycled product".
• If more than 50% of the material reincorporated in an equivalent product, may include the statement "product recyclable in a product of the same nature," or "recyclable packaging in a product of the same nature"

Traceability requirements

Stating of the country where each step was carried out: 

• Weaving (Modint note: Weaving, knitting or construction of the material)
• Dyeing and printing
• Making

For shoes: 

• Quilting
• Assembly
• Finishing

Presence of plastic microfiber

• Textile products for clothing, footwear and household linen containing >50% synthetic fiber: Statement "releases plastic microfibers into the environment during washing"

Read more>>

Environmental impact labelling

France will require a label detailing a products precise climate impact -- with a similar rule expected for the rest of the European Union by 2026.The French Agency for Ecological Transition (Ademe) is currently testing 11 proposals for how to collect and compare data -- and what the resulting label might look like to consumers -- using 500 real-life items of clothing."The message of the law is clear -- it will become obligatory, so brands need to prepare, to make their products traceable, to organise the automatic collection of data," Erwan Autret, one of the coordinators at Ademe, told AFP. Read the article>>

Modint note: France is still working on pilots regarding the methodology of garment footprint calculation. We do not have any official confirmation on this matter. Also this French development might be challenged on a European level. Modint is participating in Euratex working groups regarding footprint calculations. A position paper on this topic will be published after the summer.

More information? Contact us!