.png){kind=icon}
How does the French environmental textile labelling system converge with the European PEFCR? Methodologies, ESPR 2027 timetable and Digital Product Passport issues.
.png)
Key points to remember :
A solid common base: Both schemes rely on the PEF framework, which is based on Product Life Cycle Assessment. The European PEFCR is the result of a scientific process with no legal framework for communication (6 versions, 6,000 comments, 150 studies), whereas France has opted for an approach based on the PEF framework, to which it has added supplements (non-physical durability, microfibers) to facilitate the transition to communication on a larger scale.
Convergences in progress: Four priority projects have been identified: alignment with sustainability protocols, contribution to work on EF 4.0 (EF 3.1 databases expire at the end of 2025), integration of microfibers and biodiversity into impact calculations, and sharing of large-scale deployment methods.
The European regulatory timetable: the delegated act for the ESPR (Ecodesign for Sustainable Products Regulation) for clothing is expected in 2027, while that for footwear is planned but without a precise timetable (information expected in 2026). A delegated act for the Digital Product Passport is also expected in 2027, and will provide the technical support for transmitting environmental information to consumers and the value chain.
The strategic challenge: Far from opposing each other, the French and European approaches are not intended to compete, but to feed off each other. France provides a field for full-scale experimentation prior to mandatory European deployment, while the PEFCR provides the scientific robustness required for future harmonization. The aim of this gradual convergence is to build a common environmental language enabling brands to measure their impacts, improve their products and communicate in a transparent and comparable way across the European market.
Since October 1, 2025, over 30,000 textile references have been registered on the national declaration portal. This committed deployment bears witness to the operationality of the French Environmental Display (ED) system, but also raises a major strategic question: how can this national dynamic be articulated with the European Product Environmental Footprint (PEF) framework?
In response to this challenge, 2BPolicy organized a morning of discussions on October 22, 2025 in Paris, bringing together the CGDD (Commissariat général au développement durable), ADEME, the Apparel & Footwear PEFCR Technical Secretariat, and several representatives of companies and federations in the sector.
Objective: to take stock of the roadmap for convergence between the two approaches, and identify priority projects for the coming months.
Both the French method and the European PEFCR are based on the Product Environmental Footprint (PEF) framework, an approach based onLife Cycle Assessment, which evaluates the environmental impact of a product from manufacture to end-of-life. Official French texts (decree no. 2025-957 and order of September 6, 2025) explicitly refer to the Product Environmental Footprint as the basis for calculating environmental costs.
Indeed, France has made the strategic choice, from 2023, to use the methodological framework of the European PEF to develop its display system. The 16 environmental impact indicators defined by the European Commission (climate change, acidification, ecotoxicity, resource depletion, etc.) form the scientific basis common to both approaches.
The PEFCR for clothing and footwear is the fruit of a large-scale collaborative effort. It was drawn up by a Technical Secretariat, with the participation of major players such as H&M, Decathlon, Adidas and the European Outdoor Group.
The creative process was particularly rigorous:
This methodological work now covers 13 product categories, from T-shirts to boots and textile accessories.
While the PEFCR aims to establish a harmonized scientific framework on a European scale,French environmental labelling is first and foremost a response to public demand: to enable everyone to find out the environmental cost of a product and compare more sustainable alternatives.
To achieve this goal of transparency for the general public, France had to rise to a major challenge: making the system deployable on a large scale, whatever the environmental maturity of the brands.
Four conditions have been identified as essential for scaling up:
With over 30,000 references already declared, this pragmatic approach is already proving its operational effectiveness.
It is on the question of sustainability that the two frameworks differ most clearly, while retaining a common logic.
The European PEFCR has developed a system of multipliers to adjust the default usage time for each product category (45 washes for a T-shirt, 70 for jeans, 100 for a coat):
The French framework, meanwhile, has made different choices to facilitate large-scale deployment. It incorporates a single durability coefficient (ranging from 0.67 to 1.45) that encompasses extrinsic durability and reparability, taking into account :
Beyond questions of sustainability, several operational differences distinguish the two approaches:
One of the major points of attention raised at the conference concerned the future of environmental databases. The EF 3.1 databases, which contain over 850 data sets on materials and processes, are due to expire at the end of 2025.
While core datasets will continue to be available, specific data on materials and processes will have to be updated. This deadline poses a crucial challenge for the coherence and continuity of assessments.
The question is: towards an EF 4.0 base? What contributions can French players, with their experience of large-scale deployment, make? Feedback from the French system could provide useful input for this European debate.
The discussions also highlighted the need to look more closely at certain aspects that are still insufficiently taken into account:
Speeches by Emilie Carasso (CGDD), Pascal Dagras (CGDD), Vincent Colomb (ADEME), Delphine Droz (La Belle Empreinte), Steve Duhamel (Lacoste), Flore Berlingen, Pierre-Alexandre Naud (Alliance du Commerce) and Baptiste Carriere-Pradal (2BPolicy) converged on a shared observation: the two approaches are not in competition, they feed off each other.
As emphasized by the CGDD in its closing presentation, the French scheme represents "an opportunity to test a PEF-based framework on a large scale". With 30,000 references declared in just a few weeks, France is providing Europe with invaluable feedback on :
Convergence work is taking place in a rapidly changing European context. The revision of the EFP framework is currently underway, steered by the Technical Advisory Board (TAB). By the end of 2025, the European Commission is expected to report on this work and give itself a further six months to conclude, thus opening up a wider consultation phase.
The review covers several key aspects:
The Ecodesign for Sustainable Products Regulation (ESPR) is the binding European legal framework that will give legal force to environmental methodologies.
For clothing, the European Commission has announced that the delegated act will be adopted during 2027. The adoption process is as follows: the Commission must propose a text and have it validated by the JRC (Joint Research Centre), have it consulted by the ecosystem, then forward it to the European Parliament and the Member States. Effective entry into force would take place at least 18 months after adoption.
For footwear, a delegated act is planned, but without a precise timeline at this stage. More detailed information is expected during 2026. However, ADEME has identified footwear as a priority for its work in 2026.
The Digital Product Passport (DPP), provided for under the ESPR, will be the technical medium for transmitting environmental information to consumers and players in the value chain.
A delegated act specific to the PLR is in preparation, but it will only cover its technical and IT architecture, not its content. The content of the PLR will be specified in the sector-specific delegated acts mentioned above.
Beyond technical adjustments, this gradual convergence has a major strategic objective: to build a common language enabling European brands to measure their impacts, improve their products and communicate in a transparent and comparable way across the European market.
At a time when other regulatory measures are being put in place (Digital Product Passport, ESPR), this methodological harmonization represents a competitive challenge for the entire European textile sector.
To find out more :
