Please find below a short summary of the key points raised by the European Commission in response to France’s draft notification on the Eco Score for textiles (Notifications 2025/86/FR and 2025/87/FR).

1. Voluntary Nature of the Scheme:
   The Commission emphasized that there are currently no EU-level rules mandating environmental labelling for textiles. Therefore, the proposed French labelling scheme must remain entirely voluntary. Any provision or administrative practice that could effectively make the scheme mandatory or create market barriers must be avoided.
2. Traceability Criteria Concerns:
   The Commission questioned the inclusion of "provision of traceability information" as a basis for calculating “extrinsic durability”, noting its unclear connection to the concept and suggesting it be reconsidered.
3. Corporate Size Consideration:
   It recommended that the environmental cost calculations—especially for “extrinsic durability”—should take into account the overall scale of a company’s operations, such as the number of different products they market.
4. Obligation to Notify Final Text:
   France is reminded to communicate the final adopted version of the texts to the Commission as required by Directive (EU) 2015/1535. As a reminder the decrees still need to be adopted by the Senate and the Conseil d’Etat.

While we welcome the fact that the Commission emphasizes the need for a voluntary scheme, we are still concerned that this could generate a de facto obligation for companies operating in France. Once the final text will be notified and enters into force FESI can decide to file in an official complaint for an internal market infringement procedure.

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