Ademe and the French government will soon announce their new method for calculating environmental labeling for all textile products. It will initially be applied on a voluntary basis for brands starting in 2025 but may quickly become mandatory.
Meanwhile, the European Union has also been working for many years on an environmental scoring method with the PEFCR Apparel & Footwear for textiles and footwear, which is expected to be applied in the coming years across all European countries.
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Why 2 environmental scoring methods?
The European Commission is working on standards related to assessing the environmental impact of products with the introduction of the Product Environmental Footprint (PEF)as part of the « Single Market for Green Product » initiative.
In parallel, with the desire to move faster and take a leadership role in ecological transition, the French government, through the Climate and Resilience Act, is working on environmental labeling to better inform consumers. The textile environmental labeling that will soon be enactedby decree adds to Article 13 of the Agec law requiring brands to communicate certain information about the product’s manufacturing.
Ademe’s work on the French eco-score is based on the PEF framework (calculation of life cycle analysis) while adding supplements to promote a more virtuous (French and European) industry.
Introduction to PEFCR Apparel and Footwear
The PEFCR is not yet mandatory in Europe. The methodology is still in an improvement phase even though the main principles seem to be set.
Advantages and disadvantages of PEFCR Apparel and Footwear
Having a single method for the entire European Union is desirable for standardizing consumer information and simplifying standards for companies. The PEF efforts for textiles have been underway for many years but are not yet applicable.
PEF relies on life cycle analysis (LCA) to measure the environmental impact of a product using a scientific approach.
However, PEF is not universally accepted, especially among scientists and committed stakeholders. Indeed, LCA does not account for all environmental impacts related to textile manufacturing. Moreover, neither PEF nor the French method measures the social impact of a garment, which is a crucial criterion in one of the industries with the most employees worldwide and which regularly faces scandals over deplorable working conditions in certain countries and/or factories.
The governance of PEFCR A&F is led by the Sustainable Apparel Coalition (SAC) coordinating the Technical Secretariat. This Technical Secretariat, composed of 16 voting members, must present the methodology it has defined to the European Commission for voting. Among these 16 voting members, it is surprising to find nine of the world’s largest textile players with a strong predominance of sportswear (Nike, Lacoste, Decathlon, Sympatex, W.L. Gore & Associates) and fast fashion (H&M, Inditex). All these actors are major users of synthetic materials. And it is also questionable to see American companies within this Technical Secretariat setting the rules within the European Union.
The PEF score still very much improvable
The valuation of synthetic materials over natural materials (plant and animal) is a source of tension because it relies on incomplete scientific studies and/or on questionable arbitrations and allocations.
The opacity around the PEF 3.0 database does not allow easy critical analysis of this data nor its use. The quality of the database is crucial to achieving reliable and understandable environmental scores. The available data are « world » data and therefore very general, which can only lead to an approximate environmental rating, sometimes far from the reality of a product’s manufacture. For example, specific data related to virtuous materials or processes are not available and thus cannot be valorized. A GOTS certified organic cotton T-shirt is rated the same as a conventional T-shirt. This aberration represents a major obstacle in encouraging marketers to offer lower-impact products and in providing fair communication to consumers.
Therefore, the PEF method requires the exclusive use of the PEF 3.0 database to calculate the environmental rating. At this stage, it is impossible to take into account actual supply chain data. A factory that has invested in solar energy cannot be included in the calculation.
The current non-accounting for micro-plastic fiber pollution effectively reduces the environmental impact of synthetic materials in the environmental rating, while plastic pollution is a global issue. Conversely, the environmental ratings of wool garments (and even more so cashmere) skyrocket disproportionately. Are sheep really such a major hazard to the planet that they make the petrochemical industry look like pioneers of ecology?
Again, without questioning the environmental impact of sheep, it’s important to consider specific data from good agricultural practices that are rational and/or organic.
PEF mandates the verification of data before products are marketed (and the display of the rating). Environmental ratings must be based on tangible and verifiable data to prevent certain abuses. However, in an industry with a complex value chain and a severe lack of transparency, how can systematic data control of all products before they go to market be realistically implemented in real life? Who is responsible for these data? Who should perform this control and how should it be conducted?
PEF also requires the calculation of an environmental rating for each size of the same reference. This is a complexity that will lead to operational constraints and significant costsfor a benefit that is questionable. What is the point of displaying a different rating between a size M and a size L? How is it done for size 38?
While the approach undertaken by PEF to achieve an environmental score based on scientific criteria is commendable, some current orientations of the PEF run counter to the goal of reducing the environmental impact of the textile industry. In response to numerous criticisms, work is underway to improve various issues.
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Recap of the objectives put forward by the government regarding environmental labeling:
- Communicate an eco-score to the consumer for each garment to assess the environmental impact of a product at the time of purchase.
- Accelerate the ecological transition of the textile industry
The methodology advanced by Ademe and the Ministry of Ecological Transition has entered its final phase before the promulgation of the text and its presentation to the National Assembly. The final arbitrations are currently under discussion.
At this stage, here are the main components of the French method:
The environmental labeling is part of the 2021 Climate and Resilience Law:
“Displaying intended to provide the consumer with information regarding the environmental impacts (…) of a good, a service, or a category of goods or services marketed on the national territory is made mandatory” — Article L.541-9-11 of the environmental code
The methodology is based on the calculation of the Life Cycle Analysis of each product segmented into 8 stages:
- Raw materials
- Yarn manufacturing
- Fabric manufacturing
- Finishing
- Assembly
- Distribution
- Use
- End of life
Ademe has chosen to calculate 16 impact factors (to align with PEF) expressed in micro points. The total of these 16 factors associated with 3 other criteria results in an LCA score.
The calculation of this LCA thus relies on the method defined by Ademe and the Empreinte database.
The quality of the data used is paramount to achieve an environmental score that truly represents the real impact of a product. Moreover, the LCA calculation is a scientifically proven method but has shown its limits in a complex industry involving a large number of actors and technologies to produce a final product.
Considering that this LCA score does not provide a sufficient level of reliability to achieve its objectives, including combating the excesses of ultra-fast fashion, Ademe and the government have added additional modulations to distinguish more virtuous production modes.
Management of unsold items
Ademe intends to introduce a modulation of the environmental rating related to the export outside the European Union of dormant stocks of textile products, which is not sufficiently taken into account in the LCA calculation.
Physical and emotional durability
Ademe aims to distinguish physical durability related to the quality and lifespan of the product from emotional durability (or non-physical).
The modalities are being studied to introduce criteria for physical quality of a garment affecting the eco-score. These criteria for physical durability will not be taken into account in version 1 of the French method presented by decree in July.
Indeed, the lifespan of a product is a key issue in reducing impact by limiting the overconsumption of so-called « disposable » products. The Dhurabi study proposes a method for measuring this physical durability. However, the modalities for the implementation of potential mandatory quality tests face many very concrete operational and economic difficulties that could significantly impact French SMEs.
The envisaged modulations on emotional durability consist of taking into account criteria related to price, the number of references in a season, or the duration of marketing. These elements therefore do not take into account a notion of desirability or attachment to a product or a brand.
Combating ultra-fast fashion
The government therefore intends to introduce modulations in the calculation of the eco-score in a political challenge aimed at combating the excesses of ultra-fast fashion.
This presupposes defining what ultra-fast fashion is and how an ultra-fast fashion product is more impactful from an environmental standpoint than another textile product.
Advantages and disadvantages of French environmental labeling
French environmental labeling relies on the foundation of PEF while seeking to improve it to encourage the ecological transition of our industry. This approach is commendable and necessary.
The development of a more detailed database that takes into account so-called « sustainable » and certified materials represents a crucial challenge because, ultimately, the eco-score must accelerate the ecological transition of the textile sector, not favor actors who seek to stand still.
However, it is essential to ensure the robustness and operationalization on a large scale of the modulations that Ademe wishes to integrate into its method. The various working groups and meetings attended by Footbridge teams have shown the responsiveness of the Ademe and CGDD teams to achieve a relevant methodology.
Response from Footbridge
The FOOTBRIDGE portal is already ready to calculate the eco-score according to the official Ademe method. We are awaiting the final validations from the Ministry to start the automated calculations from the winter 2024 collections.
In reality, the update of our calculation tool represents a major evolution of the FOOTBRIDGE platform both in terms of the impact measurement of a product and the evolution of collection dashboards.
It is not just about calculating the French eco-score but, in line with our mission, to help our clients understand and act to develop the eco-design of their collection, reduce the impact of their collections; and ultimately, achieve better environmental ratings.
The FOOTBRIDGE platform allows for the inclusion of a number of specific criteria and data to automatically achieve a more precise result for all product references and to valorize eco-design approaches.
Using FOOTBRIDGE to calculate environmental ratings then becomes a key asset for all brands that want to engage in a more sustainable approach and wish to provide their customers with the most accurate information possible.
Summary of the article in a few questions
- What is the Product Environmental Footprint (PEF) and how is it used in the European Union's textile industry?
The Product Environmental Footprint (PEF) is a method developed by the European Commission to measure the environmental impact of products, including those in the textile industry. This approach is based on life cycle analysis (LCA) to quantify greenhouse gas emissions and other impacts throughout the life of the product.
It aims to standardize environmental assessment across Europe, thereby facilitating the comparison of environmental performance of products and services in the European market.
- How does the French method of environmental labeling differ from the European PEF method?
The French method, supported by Ademe, uses the basis of life cycle analysis (LCA) just like PEF, but it includes additional criteria to assess the environmental impact of a product.
These criteria include durability, management of unsold items, or pollution from micro-plastics, providing a more comprehensive evaluation of environmental and social impacts.
The French method relies on the Empreinte database and seeks to promote environmentally friendly industrial practices as opposed to ultra-fast fashion.
- What are the challenges associated with using the PEF 3.0 database to assess the environmental impact of textiles?
The PEF 3.0 database, although a central tool in the PEF method for calculating environmental scores, has been criticized for its lack of transparency and excessive generalization. It does not take into account the specifics of certain materials or more sustainable processes, such as GOTS-certified organic cotton.
Moreover, it does not allow for the use of specific supply chain data, which can lead to environmental assessments that do not accurately reflect the reality of production.
- What does the modulation of the environmental rating in the French method involve, and how does it affect environmental labeling?
The French method provides for modulation of the environmental rating to better represent virtuous production practices.
This modulation may include criteria such as physical durability, measured by quality tests, and emotional durability, assessed based on the price and marketing cycle of the products.
These modulations aim to encourage companies to reduce their environmental impact and fight against the practices of ultra-fast fashion by providing more accurate and representative information to consumers.
- What are the prospects for harmonization between the PEF method and national approaches like that of France?
Although the PEF method aims to standardize the assessment of the environmental impact of textile products at the European level, national initiatives like that of France are developing complementary approaches that respond to local specifics and accelerate the ecological transition.
Efforts are underway to improve the harmonization of methods, with the goal of combining the scientific rigor of PEF with the necessary adaptations to reflect real impacts and encourage more sustainable practices in the textile industry.
- How are physical and emotional durability criteria integrated into French environmental labeling?
In the Ademe method, physical durability is assessed through quality tests aimed at measuring the strength and longevity of products. Emotional durability (or non-physical) is quantified based on the price of products, the number of references in a season, and the marketing duration.
These criteria aim to distinguish higher quality and longer-lasting products, encouraging consumers to choose more durable and environmentally impactful products.
In version 1 of the environmental labeling, physical durability will not be taken into account in the rating calculation.
- What are the impacts of ultra-fast fashion on environmental scores in the French method?
The French method seeks to combat the practices of ultra-fast fashion by incorporating specific modulations into the environmental scores. These modulations penalize products from extremely fast and low-quality production cycles, thereby favoring brands that engage in more sustainable and responsible practices.
The goal is to raise consumer awareness and reduce the overconsumption of single-use products with a high environmental impact.
The modulation coefficients are awaiting validation following ongoing discussions.
- How does the PEF method ensure the verifiability of data used for environmental scores?
The PEF method mandates that data used to calculate environmental scores be tangible and verifiable before products are marketed. This involves rigorous control of information throughout the value chain, although this process is complex in an industry lacking transparency.
Companies must provide concrete evidence of their practices to ensure the accuracy of the displayed environmental scores, thereby ensuring a reliable assessment of the environmental impact of their products.
This is a sensitive point of this method concerning the operational reality of the sector.
