Textile environmental labeling: Glimpact has filed an application with the Council of State

Glimpact has filed an application with the Council of State (Conseil d’État) seeking the annulment of Decree No. 2025-957 and the Order of September 6, 2025, relating to the “environmental cost” of textile products and establishing the “Ecobalyse” calculation method for this cost. Glimpact’s initiative is in no way intended to contest the principle of environmental labeling itself—of which Glimpact is one of the historic promoters—but to guarantee that this labeling rests on a rigorous scientific methodology that is harmonized at the European level, stable over time, legally secure, and does not respond to purely arbitrary or political considerations. This referral to the Council of State is all the more well-founded given that, through this decree, France is violating the fundamental provisions of the Ecodesign for Sustainable Products Regulation (ESPR) adopted by the European Union on June 13, 2024; a regulation France could not ignore and which precisely establishes a unique methodological framework, based on science and therefore objective (the PEF method).

For over ten years, the European Union has undertaken a vast harmonization effort around the PEF (Product Environmental Footprint) method, now adopted by the EU as the scientific reference framework in the Ecodesign Regulation to measure the environmental impact of a product throughout its entire life cycle. This method will apply as early as 2027 within the scope of this regulation’s application for the fashion and textile sector and the implementation of the Digital Product Passport (DPP). France, by adopting its specific index termed “environmental cost,” claims to draw inspiration from it. In practice, the “Ecobalyse” methodology deviates from it to such an extent that it produces results incompatible with those of the European sectoral framework applying the PEF method to the clothing sector—the PEFCR Apparel & Footwear—validated by the European Commission in May 2025, but above all by providing manufacturers with different ecodesign levers.

The divergences relate to structural aspects: the definition of the functional unit, the perimeter of impact categories, the weightings applied, or indeed the modeling of durability and the life cycle. Whereas the PEF method relies on data, rules, and weightings harmonized at the European level, the French method introduces different parameters, merges certain impact categories, adds others, and modifies coefficients without compelling justification. Arbitrariness has supplanted scientific rigor. It is on this clear basis that the requirements and obligations regarding ecodesign and the future "Digital Product Passport” will be defined; these will be binding on all manufacturers in the sector for the application of the ESPR regulation via delegated acts of the European Commission sector by sector, with the act for clothing and footwear scheduled for 2026.

These differences make the scores incomparable and create a break in coherence for companies operating in an integrated European market. Concretely, the same product can obtain two very different scores depending on whether the French method or the European method is used, which directly contravenes the objective of clarity for the consumer.

Added to this methodological divergence is a central element of the French mechanism: the public platform Ecobalyse, designated by the texts as the tool for the calculation and dissemination of the “environmental cost.” Although presented as a neutral technical instrument, Glimpact has been able to demonstrate that Ecobalyse does not faithfully reproduce the methodology fixed by the Order. Thus, the tool becomes a factor of scientific and regulatory instability, even though it occupies a central place in the mechanism.

The situation is further complicated by the fact that the decree authorizes any person—association, competitor, or private individual—to calculate and publish an environmental score for a textile product, including by relying on estimated data when real data is not accessible. By permitting this publication without prior control and conferring upon it a status of de facto legitimacy via the Ecobalyse platform, the text creates a strong incentive for companies to retake control of the score themselves. In practice, this amounts to forcing them to adopt the French methodology, even if they are already working according to European standards.

It must be added that any company choosing to communicate a score based on another method, particularly the PEF method, is compelled to also display the French score. This obligation of double labeling strongly incentivizes companies to renounce labeling based on the PEF method—the reference framework nevertheless adopted by the EU for the ESPR regulation—which constitutes a manifest irregularity under EU law. The European Commission had explicitly requested that the French system remain “totally voluntary.” By introducing mechanisms that render the French method de facto unavoidable, the decree contravenes the principle of mutual recognition and the free movement of goods in the internal market and, above all, creates market fragmentation resulting from the development of divergent national approaches on improving the environmental sustainability of products, which the ESPR regulation aims to prohibit as stated in its preamble.

This situation poses a problem of legal security for French textile companies, in a context where they are already weakened by very strong international competition. It exposes them to a double methodological constraint, places them in a perilous situation forcing them to adapt their industrial processes to an isolated national specificity, and undermines the investments they have made to comply with the PEF framework. It also creates scientific and operational instability that makes it difficult to build a credible trajectory for reducing their environmental impact. Which, in light of the ecological emergency, is a dangerous absurdity.

Through this appeal, Glimpact therefore asks the Council of State to restore a legible, stable, and coherent framework, compliant with European commitments and the methodological requirements necessary to ensure the credibility of environmental labeling. The objective is simple: to guarantee that this essential tool for the ecological transition relies on a solid, harmonized, and operationally viable scientific base, in order to effectively support companies and correctly inform consumers.

The French Ecobalyse mechanism, contrary to its objectives as fixed by Article II of the Climate and Resilience Law, thus runs counter to the stakes of the imperative ecological transition of the fashion and textile industry.

« Companies do not need confusion; they need clarity. By creating a provisional method, France is isolating its textile sector at the very moment Europe is implementing a unique, rigorous, scientific, and sustainable framework within the context of one of the greatest regulatory and binding advances for the advent of the ecological transition. It is urgent to give companies a stable framework, compliant with science and the law, which allows them to significantly reduce their environmental footprint by giving them the right ecodesign levers. The ecological transition comes at this price. » Christophe Girardier, President of Glimpact