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Environmental labeling for textiles: What’s Changing on October 1, 2026

On October 1, 2026, a third party may publish the environmental cost of your products without your consent. What’s changing, what isn’t, and how to respond.

Benjamin THOMAS
September 22, 2025

What’s Changing on October 1, 2026
- If a brand has not published the environmental cost of its products, any third party may calculate and publish it without the brand’s consent.
- Any company that already voluntarily discloses environmental information about its textile products must also display the official environmental cost.

What won’t change: Disclosure remains voluntary in principle. The decree does not make it mandatory for all brands.

Key Timeline
- Oct. 1, 2025: The voluntary phase takes effect. Any brand that wishes to do so may disclose the environmental cost of its products
- Oct. 1, 2026: If a brand has not published the environmental cost of its products, third parties (retailers, NGOs, platforms, etc.) may calculate and publish them without the brand’s consent.
- Going forward: Submitted environmental costs may be updated every 3 months and must be updated no later than 12 months after a change in methodology. The system is intended to be expanded to other sectors, starting with the furniture industry.

Introduction: What Are We Talking About?

Textile environmental labelling is the public system that informs consumers, via a score (the "environmental cost"), of the environmental footprint of a garment over its entire life cycle.

In its first ten months of operation, the environmental cost reporting portal has registered more than 118 brands and 69,000 textile products. None of these brands were required to participate: since its implementation, the program has been voluntary.

October 1, 2026, does not put an end to this voluntary nature. But it changes what “doing nothing” means for brands. As of that date, two restrictions will be lifted, and one of them allows a third party to publish your score on your behalf, based on its own assumptions.

This guide covers the entire framework: what will change as of October 1, 2026; how the environmental cost is calculated; who is affected; what data to collect; and how to communicate without putting yourself at risk.

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1. What's Changing on October 1, 2026

1.1. A third party may publish your environmental cost without your consent

As of October 1, 2025, only brands may submit an environmental cost through the reporting portal.

Effective October 1, 2026, this requirement will be eliminated. If a brand has not disclosed the environmental cost of its products, any third party —including a distributor, NGO, consumer organization, consulting firm, comparison site, media outlet, or competitor— may calculate and publish that information.

This third party will use at least the required parameters. For everything else, it will apply Ecobalyse’s default values. We will see in Section 3 why this point is crucial: these values are conservative, and therefore disadvantageous.

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1.2. The consistency requirement takes effect

A second mechanism, which is less prominent in the commentary on the decree but has broader implications.

Any company that already voluntarily provides information about an environmental aspect of its textile products must now also display the official environmental cost, without contradicting that other information.

Specifically, what triggers this obligation:

  • a carbon footprint listed on a product sheet;
  • a claim such as “eco-friendly,” “low-impact,” or “sustainably designed”;
  • a proprietary environmental rating or an in-house label;
  • a sustainability claim highlighted at the product level.

The display must comply with the ministry's graphic guidelines. Its size must be at least equivalent to that of the price figures and at least equivalent to that of any other aggregated environmental impact score reported for the same product.

It is worth noting the paradox: the brands that are most advanced on environmental issues are the first to be affected, while those that have never made any claims are not subject to any new obligations.

See also: Environmental Claims: What the ECGT Means for Fashion Brands

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1.3. What Remains the Same

Let’s be clear, because a lot of content suggests the opposite: the decree does not make the disclosure of environmental costs universally mandatory as of October 1, 2026. The measure remains voluntary in principle.

A brand that does not communicate any environmental claims has no new obligations at this time. The risk it takes by not acting is therefore not a legal one. It is a reputational and commercial risk: someone else will calculate its score, based on assumptions the brand did not choose.

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2. What is the “environmental cost”?

The environmental cost is a multi-criteria score expressed in impact points. The higher the value, the greater the product's impact.

It aggregates:

  • 16 impact categories derived from the European Product Environmental Footprint (PEF) framework, with appropriate weightings: climate change accounts for 21.06%, freshwater ecotoxicity also accounts for 21.06%; its modeled impact for organic molecules is double that of the European recommendation, while human toxicity (cancer and non-cancer) is weighted at 0%
  • two factors specific to the textile industry, not included in the LCA: the release of microfibers and the export of collected used clothing outside Europe
  • a sustainability coefficient, applied to the aggregate score.

The calculation covers the entire life cycle: raw materials, processing (spinning, weaving or knitting, finishing, garment manufacturing), transportation and distribution, use, and end of life.

The label shows two numbers: the total environmental cost of the garment and the environmental cost per 100 grams of product. This second figure allows you to compare different styles and weights, much like a price per liter.

3. How is the sustainability coefficient calculated?

This is the most critical parameter of the system, and the one that brands underestimate the most. The sustainability coefficient determines the environmental cost. It ranges from 0.67 (for the least sustainable products) to 1.45 for the most sustainable ones. In other words, assuming production impacts are exactly the same, moving from one end of the scale to the other more than doubles the displayed score.

It is calculated based on two criteria, weighted equally.

3.1. Range Width (50%)

The maximum number of new product SKUs offered by the brand in the market segment corresponding to the SKU in question. Five segments are identified: women’s, men’s, children’s, baby, and underwear.

The index is:

  • 100% below 1,000 SKUs per segment
  • 50% of 7,000 items
  • 0% for more than 16,000 items
  • linearly between these points.
The 5 market segments considered are: women's, men's, children's, baby and underwear. The introduction of these 5 market segments is intended to avoid a distorting effect that would penalize a brand covering all market segments compared with another brand covering *only one or several segments (*for example, only women's ready-to-wear).

Within these market segments, we do not consider references that would only address a specific subset of potential customers. For example, references specific to large sizes, pregnant women or people with disabilities.

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Default value if the parameter is not specified: 100,000 SKUs per segment, corresponding to an index of 0. This is also the value applied to brands that are primarily distributed through an online platform or that do not have a unique REP identifier.

3.2. Incentives for Repairs (50%)

Two components:

  • The ratio of the average repair cost to the reference retail price (66% of the total score): 100% if the repair costs less than 33% of the new price, 0% if it exceeds 100%, and a linear scale in between. The price used is the price including tax, excluding promotions.
  • The availability of a repair service (33% of the score), certified by the TLC sector’s eco-organization as part of the repair bonus program. This criterion applies only to brands other than microbusinesses and small and medium-sized enterprises.

Key takeaway: Three optional, undeclared parameters (product line width, repair cost, repair service) are enough to cause the coefficient to drop from 1.45 to 0.67—without any changes to materials, suppliers, or processes.

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2) Application timetable

  • September 15, 2025: opening of the declaration portal
  • October 1, 2025: The voluntary phase takes effect; only brands (or parties authorized by the brand) may publish the environmental costs of their products on the public reporting portal.
  • October 1, 2026: If a brand has not disclosed the environmental costs of its products, third parties (retailers, NGOs, platforms, etc.) may calculate and publish the environmental cost without the brand’s prior consent, based at a minimum on the mandatory parameters.‍
  • Next: The reported environmental costs may be updated every 3 months and must be updated no later than 12 months after a change in methodology. The program is intended to be expanded to other sectors, starting with the furniture industry.

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5. Who is affected?

Stakeholders: All producers, importers, and distributors who place clothing on the French market, regardless of its origin, whether they are French companies or not.

Products included: adult and children's clothing. Eleven categories are covered: T-shirts and polo shirts, dress shirts, sweaters, pants and shorts, jeans, skirts and dresses, coats and jackets, swimwear, socks, boxer shorts and briefs, and boxer briefs.

Current exclusions:

  • shoes, leather goods, textile accessories (scarves, hats, caps);
  • home linens and coverings;
  • disposable clothing or clothing containing electronic components;
  • products in which more than 20 percent of the mass consists of unmodeled materials;
  • secondhand items;
  • Technical products: PPE not sold directly to consumers; sporting goods subject to the ASL Extended Producer Responsibility (EPR) program.

A few categories still need to be addressed in the methodological guidelines: bras, padded down jackets, costumes, and 100% silk shirts.

Important note: The score is calculated by sales reference—that is, by unique color—for a single reference size defined by category.

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6. What data should be collected?

This is where the real workload of the project lies. The calculation itself is instantaneous; the data collection is not.

Why is data key?

Calculating the environmental cost of products requires the collection of numerous data covering all stages of the product life cycle: raw materials, manufacturing, transport, use and end-of-life.

The challenges of accurate data collection :

  • Avoid calculations based on default values that are often penalizing,
  • Promote your eco-design efforts,
  • Keep control of your environmental communications.

In addition to environmental labelling, this data collection work will save you time by enabling you to feed other regulatory requirements: CSRD, ESPR, carbon footprint (scope 3), or Digital Product Passport.

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Required parameters

  • Product category
  • Market segment (women, men, children, infants, underwear)
  • Mass of finished product
  • Type and percentage of materials (those accounting for at least 2% of the total mass and 5% of the total impact must be reported)
  • Geographic Origin of Weaving or Knitting
  • Geographical Origin of the Ennoblement
  • Geographic Origin of the Garment's Manufacture

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Optional Settings, and Why They Matter So Much

Any optional parameter that is not specified defaults to a default value. The ones with the most significant consequences are:

  • product range width per segment → 100,000 SKUs by default;
  • reference price and repair service → worst-case scenario;
  • air freight share → its default value is based on the country of manufacture and the durability coefficient. For products manufactured outside Europe or Turkey, it is 33% if the coefficient is greater than or equal to 1, and 100% if the coefficient is less than 1;
  • origin of raw materials and spinning → default values by material, “country unknown” for spinning;
  • type and percentage of printed area, fading, list of accessories.

Where else is this data used

The data collection effort is not limited to a single purpose. The same datasets are used to feed: - Scope 3 of your GHG inventory (the largest portion, covering purchases, transportation, and use
- CSRD reporting (ESRS E1)
- the ESPR and the Digital Product Passport (DPP)
- your eco-modulations

To learn more: Textile DPP—everything fashion brands need to know about the future digital passport

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7. How to Communicate Environmental Costs

Where and in what form

  • At the point of purchase: in-store label or online product page, in accordance with the standardized visual guidelines set forth in the ministry’s graphic design manual.
  • Two required values: the total score and the score per 100 g.
  • Size: At least as large as the price figures on the shelf, and at least as large as any other aggregate score displayed for the same product.

The Reporting Portal

Any entity that reports an environmental cost must submit the data and score on the public portal. The DGCCRF may verify the accuracy of the reported parameters (composition, country) based on existing labeling requirements and the AGEC Act.

Only certain registered data are public:

  • product identification;
  • the environmental cost and the date it was calculated;
  • the breakdown by the 16 indicators;
  • the name of the entity that performed the calculation;
  • the methodology used.

All other data remains accessible only to government officials authorized to monitor and oversee the program.

Best practice: Create an account, even if you don't submit any products
Creating an account on the reporting portal is free and takes just a few minutes. If you haven't reported any environmental costs, you will be notified when a third party submits one on your behalf.

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6) Why act now when the phase is "voluntary"?

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Keep control of your scores and narrative:

From October 1 , 2026, if a brand has not published the environmental cost of a product, third parties (distributors, NGOs, media, apps...) will be able to calculate and publish it using the official methodology, without prior agreement from the brand.

However, in the absence of specific data, these third parties will use the Ecobalyse default values, which tend to lower the score. The result: a higher environmental cost than if the brand provided its own data. Publishing your own environmental costs now guarantees an accurate representation of your products.

  • Avoid conservative defects: the absence of data leads to penalizing assumptions (country, transport, durability...). Anticipate data collection to secure your scores and conversions.
  • Obligatory condition: if you communicate another aggregate score (e.g. carbon footprint on your product pages), you must co-display the official environmental cost (consistency of scores required).

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Anticipate to control data and meet deployment deadlines

Deploying environmental labelling requires considerable data hygiene, which can be time-consuming:

  • Mapping of data already available (BOM, mass, % materials, countries by stage, processes, transport).
  • Identify data gaps in ERP/PLM/PIM and fill them.
  • Cooperate with suppliers to obtain reliable information.
  • Involve the IT team in interoperability (APIs, LCA tools, Ecobalyse formats, version governance).

The average implementation time we see with our customers (for a complete collection) is around 6 months. The earlier you start in 2025, the better prepared you'll be for 2026. By looking ahead, you can also reduce the operational burden associated with data cleansing, data mapping and calculating the environmental costs of your products.

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Gain a competitive advantage as early as 2026

Calculating your scores in 2026 allows you to:

  • Compare your products with category medians, and target any discrepancies before publication ("private" benchmark).
  • Identify hotspots (materials, processes, usage, end-of-life) and guide the eco-design of future collections.
  • Train your Purchasing, CSR and Product teams in the new tools and processes to ensure a smooth transition to 2026.

Pool your efforts with your other regulatory obligations

The data sets required for environmental costing are also used to :

  • ESPR;
  • Scope 3 of the GHG balance (the most important part of the balance: purchases, transport, use);
  • CSRD reporting (ESRS E1) and DPP (product passport).

Investing in 2025 will enable you to fuel several upcoming regulatory and strategic projects.

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