The interpretation of DPP in France

A central theme of EU strategies for sustainable fashion, the digital passport is increasingly at the center of attention of companies in the fashion system. While waiting to acquire details on the application of the EU directive in our country, an example is provided by France which is leading the way with the AGEC law and the Re-fashion activity.

The AGEC law (Loi Anti-gaspillage pour une économie circulaire) was promulgated on 10 February 2020 and does not only deal with textile-fashion. In fact, it aims to push 360-degree circularity models and is divided into 5 phases which will progressively come into force by 2040: progressive abandonment of disposable plastic, better consumer information, fight against waste and solidarity re-use, action against planned obsolescence, better production and durability of the goods produced. In particular, with Decree n° 2022-748 of 29 April 2022, important objectives are set for the labeling of products that generate waste entering the French market and which apply to all producers, importers and retailers of consumer products, in physical stores as well as online stores.

Here is a summary:

The labels must be digital (e.g. QRCode) but it is not forbidden to make them on paper and they must be accessible during purchase as their purpose is to provide information to consumers on the qualities and environmental characteristics of the products (clothing, home textiles, shoes, bags etc).

Pursuant to the legislation, the label must allow consumers to:

• Consider the environmental and social impact of the product throughout its entire life cycle;
• Show environmental impacts in terms of greenhouse gas emissions, damage to biodiversity, water and other natural resources;
• Take into account the environmental externalities of production systems;
• Geographically trace the 3 main processing phases (weaving, dyeing, assembly/finishing);
• Examine items including:
• reparability, recyclability, possibility of reuse;
• recycled material content;
• use of renewable resources;
• presence of dangerous substances;
• presence of plastic microfibres, when the mass proportion of synthetic fibers is greater than 50%.

The label must be visible and accessible to the consumer, at the time of purchase and afterwards: this implies the creation of a web page dedicated to the product, which must be in French. Indeed, the Loi AGEC requires non-French manufacturers to translate all product information that is made available to buyers.

As for the timing for implementation, the law specifies that its provisions apply with the following frequency:

• January 2023: companies with a turnover exceeding 50 million euros, or which place more than 10 thousand units on the French market every year
• January 2024: companies with a turnover of more than 20 million euros, or which place more than 10 thousand units on the French market every year
• January 2025: companies with a turnover of more than 10 million euros, or which place more than 10 thousand units on the French market every year
• However, it is likely that there will be delays in implementation, as an agreement has not yet been reached on the methodology to be used for calculating the impact, which has been tested since May 2022. At present, it is likely that France will refers to the Product Environmental Footprint (PEF), in order to comply with European regulations.

This methodology, however, is not free from criticism and would require revision.

In addition to the methodological difficulties, concerns have been raised by many regarding the regulatory discrepancy, which risks generating disparities and excessive burdens for fashion companies, which often operate in multiple countries and, consequently, find themselves subject to multiple and divergent obligations.

Edmond Carbon Footprint platform allows you to get started and being compliant in this complex environment.