The Textile Environmental Score: A System to Watch For

While at the European level, the Product Environmental Footprint Category Rules – PEFCR—for apparel and footwear—have just been published, and in France, the display of the environmental cost of clothing has just been approved by the European Commission; let’s take a closer look at these two measures.

💡 Key Takeaways :

If both managers– European and French – Although they are not perfectly equivalent, their similarities are notable. The two approaches have fed off each other and will continue to do so, and while the two scoring systems are expected to coexist in the short term (much like organic farming labels), the goal is clearly to move toward a single score across the entire European Union.

Furthermore, while these two scores are not currently mandatory, a company would be well advised to begin assessing the environmental cost of its products now, in order to anticipate regulatory requirements and implement a transition strategy. Uncertainties regarding the calculation method are no longer an obstacle; companies can now evaluate their product portfolios using these two approaches.

💡 Some key definitions:

1. Environmental Labeling : Information displayed on a product that indicates its overall environmental impact, intended to help consumers make more sustainable choices.
2. Environmental Cost : An assessment of the environmental impacts of a product or service throughout its life cycle.
3. Eco-score : Indicator which assesses a product's environmental impact based on several criteria.
4. Product Environmental Footprint (PEF) : A method developed by the European Commission to assess a product’s environmental footprint throughout its life cycle, based on harmonized criteria.
5. Product Environmental Footprint Category Rules (PEFCR) – Apparel & Footwear : Specific rules for the textile and footwear sector governing the application of the PEF method to ensure consistent and comparable assessments.
6. Digital Product Passport (DPP) : A digital passport containing essential information about a product’s origin, composition, repairability, and durability, to improve transparency and circularity.
7. Ecodesign for Sustainable Products Regulation (ESPR) : A European regulation aimed at extending ecodesign requirements to all products in order to improve their sustainability, repairability, and recyclability.

Environmental Labeling

an effective tool for the regulator…

Among the various tools available to lawmakers to influence the behavior of economic actors, providing consumers with access to information ranks high among the most effective measures.

Let's take the example of the now-famous Nutri-Score, which rates the nutritional quality of a food product on a scale from A to E. This new information has led to changes in consumer behavior (demand for products rated A or B has increased^[1]) that producers' behavior (the supply aimed at obtaining more favorable scores has increased^[2]).

Changing behavior is precisely one of the goals of environmental labeling for textile products, which is currently under development. The goal is to provide information on a product’s environmental impacts throughout its entire life cycle^[3], to transform the supply—with producers favoring theeco-design to achieve a better score—and as demand decreases—consumers are reducing their consumption of high-impact products.

mbut a composite score that is, by its very nature, biased.

While providing a summary score has the advantage of making the information easier to understand, calculating that summary score always involves making methodological choices. Thus, a score highlights and emphasizes certain criteria, while obscuring or downplaying others. Take, for example, the AB Organic Agriculture certification: this certification recognizes farms that do not use chemical inputs, thereby reducing the impact on biodiversity, even though these same farms have a greater climate impact than conventional agriculture due to lower yields.

The development of a scoring system therefore has political implications, which explains why the creation of environmental labeling—both at the European and French levels—took time and required consultation with numerous stakeholders.

This also indicates that interpreting this environmental label must always be accompanied by a thorough understanding of how it was developed.

Environmental labeling of textiles: a long-standing issue.

Now that we’ve provided some background, let’s take a closer look at the current state of environmental labeling in the textile sector. This sector, which has significant environmental impacts (including pressures on biodiversity, resource use, carbon footprint, pollution, and waste), is one of the first sectors to have been the subject of discussions regardingenvironmental signage (including food products, electronics, furniture, the hospitality industry, and construction products^[4]).

Then these reflections on thetextile environmental labeling have accelerated:

• at the European level, through the establishment in 2019 of a Technical Secretariat to develop the Product Environmental Footprint Category Rulessector-specific Apparel and Footwear : the A&F PEFCR.
• In France, thanks to regulations. Two articles have established environmental labeling requirements for the textile sector:
  • theArticle 15 of the AGEC Act^[5] from 2020, which states that “the environmental labeling system […] is now mandatory, primarily for the apparel sector.”
  • Article 2 of the Climate and Resilience Act^[6] of 2021, which replaces Article 15 but confirms that environmental labeling will apply “primarily to the apparel sector.” Article 2 of the Climate and Resilience Act provided for a pilot phase lasting up to five years to define “the methodology to be used as well as the selected labeling procedures.”^[7].

Methodological developments at the European and French levels have been intertwined, with the two approaches reinforcing one another. Let’s take a closer look at these developments, as well as their similarities and differences.

The main characteristics of European and French methodologies.

The finalized methodologies have several characteristics:

• First, The scores are not in the form of a limited scale—like Nutri-Score—but rather a value. This format has one advantage: it reminds consumers that every product has an impact—a non-zero “environmental cost.” A score on a scale, on the other hand, risks “numbing” the consumer’s judgment, potentially leading them to overconsume products that receive high ratings, resulting in a rebound effect^[8].

• Second, the scores take into account the impacts across the product’s entire life cycle: this involves quantifying the product’s impacts from the raw materials needed for its design through its manufacturing, transportation, and use, all the way to the end of its life.

• Finally, as we have seen, developing a composite indicator is a significant political issue: which environmental criteria should be used (and thus made visible or invisible), and how should they be weighted (and thus given greater or lesser priority) to produce a useful score? Two different approaches can lead to two very different results. And in fact, if PEFCR A&F and the French Eco-Score While they share commonalities (incorporation of the sixteen generic PEF criteria presented below, as well as issues related to circularity and sustainability), they also differ in certain respects (for example, the weighting factors differ between the two methodologies, the French Eco-Score includes microfiber pollution in its calculation, whereas the PEFCR A&F requires it to be listed separately; the French Eco-Score includes exports outside Europe in the score, while the PEFCR A&F does not). Despite these nuances, it is important to note the similarity between these two systems, which are intended to converge toward a single environmental score at the European Union level.

What's next for environmental labeling in the textile industry?

Both initiatives reached important milestones in mid-May 2025: the PEFCRs for apparel and footwear were published, and Agnès Pannier-Runacher announced that the European Commission had approved the labeling of the environmental cost of clothing.

Today, both at the European and French levels, systems for reporting environmental scores remain voluntary. As a result, European companies may share results with third parties (B2B partners or governments, but not end consumers) subject to verification^[9]. For France, it is stated that “the way is clear for the deployment [of the system] as early as the second half of 2025, always on a voluntary basis”^[10]. And in fact, starting October 1, 2025, brands can display their environmental impact online or in-store.

It should be noted, however, that these scores are becoming benchmarks in the regulatory landscape. Thus, the PEF Is it listed as the reference method in the context of theDigital Product Passport (DPP) integrated into the Ecodesign for Sustainable Products Regulation (ESPR), but also as part of the Director of Corporate Sustainability Reporting (CSRD) or as part of the Green Claims Directive.

In this context, for a company in the textile industry, it is without regret to begin developing an environmental understanding of their product portfolio right away. Indeed, even though the regulations are not yet mandatory, ADEME recommends that companies to anticipate these environmental labeling schemes, first of all to spread out the costs the human and financial resources needed to implement this scoring system, and then to seize opportunities competitive by promoting eco-design now to improve this score even before it becomes mandatory.

Carbone 4 is now able to help companies prepare for environmental labeling in several ways:

• First, our firm specializes in valuation carbon footprint at the product level, throughout its entire life cycle. We provide our customers with diagnostic tools they can use to design their products with sustainability in mind.
• What's more, we support our clients in their product portfolio strategy : evaluation and decision-making tools, ideation workshops to develop an effective action plan, and application to the company’s operational realities.
• Finally, Carbone 4 can assist its clients with Life Cycle Assessments(LCA)more specific and based on multiple criteria, in order to advance the state of the art regarding materials, processes, or products that have not yet been adequately evaluated.

Anticipating inevitable regulatory changes allows companies to deepen their understanding of the physical flows underlying the use of textile products, work toward making their product portfolio more sustainable, and reevaluate their material choices.

If you would like to learn more about environmental labeling issues, regulatory challenges, and how to develop a solid environmental strategy, please feel free to contact the team at Carbone 4.