Environmental Scoring Methodology for Textiles in France: An In-Depth Exploration

Environmental Score in France: ADEME's Technical Foundation

The purpose of environmental labeling is to empower consumers to consider the environmental impact when choosing products. It takes the form of an Eco-score reflecting the main environmental impacts of a product, calculated throughout its lifecycle.

For more information on the objectives, deployment timeline, and the future mandatory nature of environmental labeling, you can refer to this article.

Currently, it is a voluntary system that can be displayed on products at the discretion of the brands. However, to fulfill its functions, it is regulated: fashion brands choosing to use it must comply with ADEME's technical foundation.

The ecological transition agency has indeed selected and co-developed various tools to enable a harmonized and reliable calculation of impact scores:

1. General principles and a methodological framework transversal to all products: the European Product Environmental Footprint (PEF) and the AFNOR's (French official Standards Agency) best practice reference (BP X30-323-0).
2. Sectoral reference frameworks: these indicate how Life Cycle Assessments (LCAs) should be conducted for each product family (functional unit, indicators selected based on the environmental issues of the products, calculation method, etc.). We will delve into the textile reference framework in the next section, and reference documents are available on the Empreinte database website.
3. A public database: Empreinte (previously Impacts). It provides generic data for conducting LCAs, such as the average impact of a material, a type of energy consumed, a mode of transportation, etc.
4. Automatic calculation tools for pilot sectors: Ecobalyse for clothing articles. The aim is to make environmental labeling accessible to all companies in pilot sectors by facilitating the evaluation of their product's impact. Simply inputting key data (type of clothing, mass, raw materials, country of certain stages of the production process) into the simulator provides the calculated impact according to reference methods using data from the ADEME database (a list of detailed impacts and the aggregated PEF score for Ecobalyse). This is a semi-specific approach: a calculation based on generic/average data, but with some information that can be specified to refine the result.
5. Visual proposal: A chart has been developed by ADEME to represent the environmental impacts of products. It can be downloaded from the cross-cutting documents available on the Empreinte database website. It offers several more or less compact variants, with more or less detail on different environmental indicators depending on the available space. Even in cases where only the aggregated version is displayed, consumers must always have access to the details of the indicators, following the transparency principle.

The controls on environmental labeling are conducted by the DGCCRF (French General Directorate for Competition, Consumer Affairs, and Fraud Prevention), as part of the fight against misleading advertising. Environmental labeling differs in this regard from labels (e.g., Oeko-Tex), which are controlled by approved third-party organizations.

Environmental Impact Assessment of Apparel: ADEME's Textile Reference Framework

ADEME has been working since 2008 to define relevant methodologies by product category in collaboration with stakeholders from each sector (e.g., apparel, food, electrical and electronic).

A working group has notably developed an environmental labeling framework for the textile sector and apparel items. You can find the detailed information in the reference documents on the textile industry available on the Empreinte database website (Documents → Base Impacts), but we summarize here the important elements for you.

Environmental indicators selected for the impact assessment of apparel textiles

A working group identified the three most significant environmental challenges for the textile sector:

1. Climate change
2. Water-related consequences, considering consumption and pollution through eutrophication and aquatic ecotoxicity
3. Consumption of non-renewable natural resources and energy

The study conducted led to the selection of the following three indicators for ADEME's environmental labeling method in 2016:

1. Greenhouse gas emissions (in kg CO2 eq.) - a common indicator for all products, textiles or not
2. Eutrophication (in kg phosphorus eq.)
3. Water consumption (in m3)

ADEME also chose the calculation rules for these indicators.

In March 2023, the government, in a communication on the methodological work orientations, indicated that the following 8 impact criteria are being studied for the future fashion eco-score:

1. Water consumption
2. Physical durability of textiles
3. Production conditions
4. Use of pesticides and chemicals
5. Release of micro-plastics
6. Valorization of recycled materials
7. Valorization of reconditioned textiles
8. Impact of fast fashion

Following methodological advancements, Ecobalyse, the automatic impact calculation tool built from ADEME's technical foundation, considers 16 indicators (derived from ADEME, the PEF), plus 2 complementary indicators to better capture textiles environmental impacts.

Life cycle stages considered in the LCA of clothing

The working group modeled the life cycle of fashion items and established that the impact assessment methodology for apparel should consider the following stages:

1. Production of raw materials (breeding/cultivation/extraction and production of fibers)
2. Production and end of life for certain accessories (e.g., zippers)
3. Production and end of life of packaging
4. Clothing manufacturing (spinning, finishing, weaving, knitting, garment assembly)
5. Transportation of items between manufacturing stages
6. Transportation of items from the manufacturing location to the store
7. Use: washing, drying, ironing
8. End of life (disposal, reuse, recycling)

Methodological choices made for the calculation of the environmental impact of fashion items

Choices have been made regarding the data used as the basis for calculations. For example:

• The functional unit (the scale at which Life Cycle Assessments are conducted) is "a worn and maintained clothing article" and its packaging system as provided to the consumer.
• The reference usage duration (used as input data for Life Cycle Assessments) is modeled based on the number of maintenance cycles, which vary by clothing category (50 cycles for a shirt, 30 for a sweater, 2 for a scarf).
• Reference sizes have been established for women (38), men (L), and children's clothing has been segmented by ages and standardized at 6 months, 4 years, and 10 years. If a company wishes to perform a calculation for another size, it must apply a corrective factor as a percentage of the article's mass.
• The calculation of the end-of-life impact of clothing is based on the average distribution of clothing at the end of life among reuse, fraying, incineration, burial, etc.
• Three types of data are used in Life Cycle Assessments:
  - Generic data, set based on averages, for example, the electricity consumption of consumers' washing machines.
  - Semi-specific data, where a default value is also used, but with a higher level of precision from specific product information provided by the operator. For example, specifying the country where a manufacturing step is carried out allows the use of the country's generic energy mix in the calculation.
  - Primary, or specific, data obtained from direct measurements (e.g., product composition).

To learn more about the questions that may arise from the methodological choices and trade-offs made during the design of environmental labeling, we invite you to read our dedicated article.

The Xtex Call for Projects: Experimenting Alternative Fashion Eco-score Methodologies

In 2021, ADEME launched the Xtex call for projects following the Climate and Resilience Law, Article 2 of which provides for environmental scoring and experimentation to determine a method. The goal is to allow stakeholders to propose alternative methodologies to the ADEME technical foundation for the textile sector.

To anticipate mandatory environmental labeling, it is interesting to delve into this call for projects because the selected and studied proposals are the basis for the method chosen by the public authorities.

To be eligible to participate in the Xtex experiment, proposed methodologies had to comply with the following conditions:

• They must include a precise description:a. of their multi-criteria and multi-stage approach allowing the calculation of the product's environmental performance through LCA, accounting for its significant environmental impacts, following ISO 14040 and ISO 14044 standards.b. of the method of displaying environmental performance to the consumer, via a score or a rating that must notably indicate greenhouse gas emissions.
• Three different companies must commit to testing the methodology in real conditions if selected and subsequently produce a report for ADEME.

The call for projects includes other optional criteria: compliance with other ISO standards for environmental communication (ISO 14025 or ISO 14027), the possibility of considering qualitative indicators if justified and relevant, or the integration of consumer tests.

In January 2022, ADEME published the list of 11 alternative methodologies selected.

A methodology is also being developed in parallel by Ecobalyse and the Digital Factory of Ecology.

The participants in the experiment suggested - in addition to the LCA indicators - additional indicators they deem relevant for a more representative score of the environmental impact of clothing (e.g., eco-design, micro-plastics, traceability, social impact, certifications, and labels).

After case studies, the test results of these methods are currently being analyzed, and a report will be submitted to Parliament soon, of which we will keep you informed of the content.

This will open a period of deliberations and adjustments to the method, development of tools for its deployment, and testing. A decree will then be published - presumably by the end of 2023 - making environmental labeling progressively mandatory.

As of the end of 2023, the decree has still not been published, which means that the implementation of the official methodology is likely to be delayed.

Conclusion: Environmental labeling, a device based on trade-offs

Environmental labeling will become mandatory by 2024 in France, after extensive work by public authorities and stakeholders who have co-constructed it since 2008.

But the adoption of a methodology involves choices and biases that can be subject to debates. To express their concerns about the choices that could be made by public authorities, five environmental assessment actors (La Belle Empreinte, Clear Fashion, Green Score Capital, Goodfabrics, and ECOEFF LAB) published an op-ed in Le Monde in early March.

For further details, we invite you to consult this article summarizing the debates on methodological choices in designing environmental scores for clothing articles.