Environmental claims:
where to start
- 01/01/2023 Carbon neutrality regulated
- 27/09/2026 EmpCo applicable
- 01/10/2026 Textile labelling by third parties
EmpCo has applied since 27 September 2026 without a French law having been passed: the 7 questions to address about your claims, with dates and a budget.
A real projectMaison Close: Bilan Carbone® and environmental labelling, backed by evidenceLuxury lingerie, French brandRead about the project
Special caseDo you sell to businesses?EmpCo protects consumers, but the French Consumer Code already applies the rules on misleading practices to those targeting businesses (Article L. 121-5). Your customers will also ask you for evidence of what they display.Prepare an evidence sheet ↗
Special caseDo you sell clothing?Since 1 October 2026, a third party can publish your clothing's environmental cost without your consent, and a brand publishing its own score must display that cost alongside it. Labelling remains voluntary.What changes on 1 October ↗They have commissioned Celsius
To address, in order.
Does EmpCo already apply in France?
Not directly: the Directive has applied since 27 September 2026, but France has not passed its transposing law, which is in committee at the National Assembly. Courts interpret French law in its light, and that law already penalises misleading claims, the words banned by the AGEC law and undocumented carbon neutrality.
Start from your next deadline (website redesign, launch, annual report) and work back 6 to 9 months to reword, substantiate and obtain approval.
Does it apply to my company, even if it is an SME?
Yes, as soon as you address consumers and your message relates to the environment, whatever your size. That message can be a word, a leaf or a green background, a label or a range name, and a commitments page written in 2023 and still online also counts.
Remove the visual at the same time as the word: retaining the green leaf or the “Nature” range name leaves the claim in place.
What penalties do I face, and from whom?
A misleading commercial practice can cost a company up to €1.5 million, an amount that can rise to 10% of turnover or 80% of advertising expenditure when the claim is environmental. The DGCCRF carries out inspections, and competitors or associations can bring proceedings: the Paris Judicial Court ruled against TotalEnergies on 23 October 2025.
Address the most visible and most generic claims first, starting with the homepage and packaging.
Which wording should I abandon?
The 4 environmental practices on the blacklist: a generic word (“eco-friendly”, “green”) without the EU Ecolabel or equivalent, a claim extended to the entire product, neutrality through offsetting, an uncertified label. The AGEC law already bans “biodegradable” and “environmentally friendly” on products and packaging.
For packaging already printed, decide reference by reference: the Commission accepts a corrective sticker on products on the shelves.
What about “carbon neutral”, or our “net zero” target?
On a product, “carbon neutral” currently requires a public report (life cycle footprint, reduction pathway, offsetting) and will be banned, once EmpCo is transposed, if it relies on offsetting. A “net zero” target must be based on a dated, quantified plan verified by an independent expert.
Remove neutrality claims from your products, display the measured reduction and present your carbon credits separately, as a contribution.
What evidence should I retain for each claim?
Evidence that exists when the claim is published and covers the same scope as the wording. A supplier certificate is sufficient for a recycled content percentage; a climate claim about a product requires an ISO 14067 footprint, an overall benefit a multi-criteria LCA, and corporate climate communications a published Bilan Carbone®.
Keep a sheet for each claim: exact wording, scope, method, supporting evidence, validity and review dates, ready for an investigator.
Where should I start?
With an inventory of your communication materials: website, product sheets, packaging, advertisements, social media, tender responses, including old pages. Test each statement against 3 questions: does it specify the benefit and its scope, does the customer infer more than you substantiate, does the evidence already exist?
Have the exposed wording on your website and packaging identified: Celsius classifies it against Directive (EU) 2024/825 and sets out the evidence expected for each claim.
The dates to remember.
- 202301/01“Carbon neutral” on a product or service: public report mandatoryIn force
- 202618/02EmpCo transposing law adopted by the Senate, still in committee at the National AssemblyIn force
- 202612/08PPWR: a claim about a property it regulates must go beyond the minimumIn force
- 202627/09EmpCo applies; France has not yet passed its transposing lawIn force
- 202601/10Textiles: a third party can publish your clothing's environmental cost without your consentIn force
What it costs.
The cost of a review depends on the number of communication materials and the evidence already available. Allow €3,000 to €5,000 excl. VAT for a critical review if you publish a comparison.
- A simplified LCA to substantiate a claimDuration: 4 to 8 weeks€5,000 to €12,000 excl. VAT
- A full LCA, to ISO 14040 and 14044Duration: 3 to 6 months€12,000 to €25,000 excl. VAT
- A Bilan Carbone®, for corporate communicationsDuration: 3 to 4 months for an SME€10,000 to €30,000 excl. VAT
Maison Close:
Bilan Carbone® and environmental labelling, backed by evidence.
Luxury lingerie, French brand
For this French luxury lingerie brand, we carried out the Bilan Carbone® covering all 3 scopes, prepared its products' environmental labelling using the European PEF method and trained its teams. The constraint set from the outset: environmental communications supported by evidence, consistent with the brand's positioning.
- 3 scopesfor the brand's Bilan Carbone®
- PEFthe European method chosen to prepare the labelling
- 5 monthsproject, with 2 consultants including 1 LCA engineer
A review
of your environmental claims.
We inventory your messages in context, match each claim to its evidence, propose revised wording and compile the evidence file. Legal decisions remain with your legal adviser.
