How to comply with the French Decree 748 for Packaging and Textiles by January 2023?

Release
Sep 20, 2022
Tags
Sustainability
Compliance

While you’ve been busy amending your packaging with the correct Triman logo and waste sorting signage, France reinforces its commitment to better environmental strategies through the French Decree 2022-748. Published on April 29th, 2022, in applying the zero waste law (loi AGEC) from 2020: this decree applies to all fashion brands selling garments, shoes, and home textiles in the French market. The decree is meant to ensure more transparency to consumers through new and improved environmental labeling.

The legislation requires the fashion industry and fashion brands to provide accurate information on the environmental qualities and characteristics of the products consumers purchase and use daily. The objective is to allow consumers to make informed purchase decisions and better manage the textile and packaging waste.

What does the decree say exactly, and what do you need to do to comply by January 2023?

What does your brand have to do?

The French Decree 748 concerns all producers and importers, including e-commerce players, considering their annual turnover in the French market and the number of units in the market. To make the process easier, the French Decree 748 features a gradual implementation:

  • From January 2023

                   Companies with a turnover of >50M euros

                    Putting in the market >25 000 units of waste-generating products

  • From January 2024

                    Companies with a turnover of >20M euros

                    Putting in the market >10 000 units of waste-generating products

  • From January 2025

                   Companies with a turnover of >10M euros

                    Putting in the market >25 000 units of waste-generating products

DOs and DON’Ts of textile products compliance.

For all your garments, shoes, and home textiles, you need to ensure that the following information is available to consumers at the point of sales (online or in the shop) and after sales:

  • Compostable claims are not allowed. If your garment is supposed to be compostable, you won’t be able to mention it in your product description. France only authorizes packaging made to collect organic waste to hold this statement.
  • Environmental claims are forbidden. The decree prohibits using terms such as “biodegradable,” “environmentally-friendly,” or any other equivalent environmental claim that might cause misinformation.
  • Recyclability. The French eco-organism LEKO/CITEO will provide a tool to calculate the recyclability of a product. Depending on the result of the calculations, the mention “predominantly recyclable packaging” should be added to the garment description. The statement “fully recycled product” can be used if more than 95% of the product is made from recycled materials. If the product can be recycled without losing its attributes (if 50% of the product can be reused in a similar product), then the producer can use the claim “recyclable product in a product of the same nature“.
  • Hazardous substances should be declared with the mention “contains hazardous substances“, if greater than 0.1% or “contains extremely dangerous substances” if there are several used, as well as the mention of the harmful substances.
  • Traceability. There should be an indication of the country where the main manufacturing steps took place (knitting, dyeing, garment manufacturing or sewing, assembling, and finishing for shoes). This requires that you, as a brand, have been collecting information about your supply chain in advance.
  • The presence of synthetic fibers should be mentioned if the synthetic fiber represents > 50% of the mass fiber via the sentence “releases plastic microfibers into the environment during washing”.
  • Bonuses and penalties related to the product’s environmental performance should be declared.

DOs and DON’Ts for packaging products to be compliant

For all your garment and shoe packaging provided to consumers such as hangtags, hangers, shoe boxes, etc., you need to ensure that the following information is available for them at the point of sales (online or at a shop) and after sales:

  • Recycled content of Packaging. If your packaging contains recycled material, you can inform consumers by mentioning the percentage of recycled material contained in your packaging, stated in a form such as “packaging contains more than X% recycled content“.
  • Recyclability of packaging. The French eco-organisms (CITEO and LEKO) are providing a database to help you identify which packaging is recyclable or not in the French market. Based on the information provided, you will need to declare the recyclability grade of your packaging
  • Compostable material claims are forbidden. France only allows mentioning compostable for packaging destined to collect organic waste. No packaging manufactured for other purposes such as communication for the fashion industry shall mention “compostable”.
  • Environmental claims are forbidden. France does not allow any environmental claims such as “biodegradable” or “environmentally friendly” on packaging anymore.

Waste contribution

You are required to indicate any penalties or bonuses due to the environmental characteristics of your packaging. It is the French eco-organisms who are in charge of determining it.

Where should this information be published?

The French Decree 748 mentions that proper information should be accessible to consumers before and after purchase through posters, labels, or digitally – a dedicated page per product should be built to inform consumers about the specifications and environmental characteristics of the product.

The good news is that by providing this information in a digital format as a brand, you can make use of QR codes or NFC technology, aligning with the EU strategy for a sustainable and circular textile industry which mentions the possibility of increasing transparency and information to consumers via a digital product passport.

Can you provide this information in English?

Any information which answers to the French Decree 2022-748 can only be available in French. For this reason, you must create specific product pages for the French market.

What happens with your current stock of garments/shoes/packaging?

If your brand has stock manufactured before April 29th, 2022, this can be sold/used until January 1st, 2023.

How can Trimco Help You Comply?

Communication support. Trimco is able to provide you with a digital solution to communicate about your product specifications as required by the French Decree 2022-748. We are able to design and print QR codes for you to communicate with your consumers easily at every stage of the textile or packaging lifecycle.

Traceability. Trimco’s Product DNA® solution allows you to collect information from your suppliers to provide validated and accurate information to consumers. Trimco helps you onboard your suppliers to collect all certifications and information required by the French Decree 2022-748 in just a few months.

Sources: Decree 2022-748, April 29, 2022 (FR) and Zero Waste law 2020

Do you have any questions, or would you like to know how we can support you? Get in touch.

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