France runs ahead of the European Union on product data, and it does so with its own vocabulary. If you sell clothing to French consumers, whether or not your company is established in France, four French obligations and one European deadline are pointing at your product pages.
They share no scope, no thresholds and no calendar. Confusing them is expensive both ways: you either assume everything applies and postpone all of it, or assume nothing does and miss the one that catches you at any volume.
Here is the sorting, with the legal references.
| Obligation | Threshold | Since |
|---|---|---|
| Triman and sorting instructions | none | 2022 |
| Manufacturing places on the product page | none | July 2026 |
| AGEC product sheet | 10 M EUR and 10,000 units | 2023, lowered in 2025 |
| Environmental cost display | voluntary | October 2025 |
| EU Digital Product Passport | nothing due yet | delegated act pending |
Does French law reach a shop outside France?
Yes, and this is the first thing to settle.
The trigger is placing products on the French market for French consumers, not being established in France. The 2022 decree says so explicitly, naming producers, importers, distributors and other operators placing products on the market, including those using a website, a platform or any other online distribution channel.
Units are counted as those placed on the French market annually. One thing the texts do not settle: whether the turnover criterion is worldwide or French only. Neither the decree nor the official guidance says, so treat it as an open question rather than an answer.
What applies with no threshold at all
Triman and the sorting instructions apply to everyone. The 2021 decree sets no turnover and no volume threshold. The only flexibility is about size: where the product's largest face is under ten square centimetres and nothing accompanies it, the marking may be dematerialised.
Manufacturing places on the product page is the one almost nobody has noticed. The law of 8 July 2026 on fast fashion creates article L. 541-9-1-2 of the environment code: for textile products sold online, the manufacturing places must be shown clearly on the platform, in type at least the size of the price and next to it.
Two details change everything. There is no threshold. And the information goes on the product page itself, not into a separate sheet. Several implementing decrees are still pending, but the principle is voted.
The AGEC product sheet, and a citation trap
This is the best known obligation and the most often miscited.
First, a documentary trap. The environment code articles created by the 2022 decree were recodified in April 2024. Guidance pointing at article R. 541-221 is citing a text that has moved. The live articles are R. 541-227 for the thresholds, R. 541-228 for the information, R. 541-229 for the format.
The thresholds are cumulative, both have to be exceeded: 50 million euros of turnover and 25,000 units in 2023, 20 million and 10,000 in 2024, 10 million and 10,000 since 1 January 2025. No further step is set for 2026. Below them the sheet is not required.
What it has to carry, for clothing: recycled material content, except for leather articles, recyclability, the presence of hazardous substances above 0.1 percent by mass, traceability, and the presence of microplastic fibres above 50 percent synthetic content.
Traceability means three countries, not one origin. Article R. 541-228 asks for the country where each stage is principally carried out: weaving, dyeing and printing, and making up. Weaving covers knitting and non-wovens too. For footwear the three stages are stitching, assembly and finishing.
Where the geography differs between parts of a garment, the tie-breaker is not in the decree but in the official guidance: name the country making the largest proportion by mass of the model's textile fibres, and, where that varies by production unit, the one producing the largest number of units.
Where to publish it. The sheet is dematerialised only, on a dedicated site or page, free, accessible at the moment of purchase, and, importantly, reusable and machine-readable. A PDF whose text cannot be selected does not comply. It does not have to be visible in a physical shop, it must be kept for two years after the last unit is placed on the market, and writing "information not available" is forbidden.
A point that surprises people: no QR code is required. Neither the decree nor the guidance mentions one. It is industry practice, not a rule.
Failure carries an administrative fine capped at 3,000 euros for an individual and 15,000 euros for a company.
Counting, to know whether the sheet catches you
Both criteria have to be crossed together. Staying under either one keeps you outside the product sheet obligation.
Units are counted over a year, on the French market, and across every product family the decree covers, not clothing alone. Turnover is that of the last closed accounting year, without the text saying whether to read it worldwide or in France.
In plain terms, a shop sending a few thousand pieces a year into France stays under the ten thousand unit criterion, and the product sheet is not required. That exempts it from nothing else: Triman and the online display of manufacturing places carry no threshold at all.
The environmental cost, and the 1 October 2026 switch
The French display scheme rests on decree 2025-957 and the order of 6 September 2025, in force since 1 October 2025. It is voluntary, at the European Commission's request. The public Ecobalyse calculator is the state tool, and the decree designates its portal for declarations.
Scope is a closed list of eleven clothing categories: boxers and briefs, long underwear, socks, shirts, jeans, skirts and dresses, swimwear, coats and jackets, trousers and shorts, jumpers, t-shirts and polos. Household linen, single-use garments, garments with electronic components and footwear are out of scope.
Voluntary does not mean without consequence, and two rules are worth reading before October.
A third party may compute and publish your score. Article D. 541-244 lets anyone calculate the environmental cost of a reference from available or estimated data. If the producer later determines its own figure, that one prevails and third parties must align within a month. The condition requiring the brand's prior agreement applies only until 1 October 2026. After that date a third party may publish without your consent.
Showing any other environmental score obliges you to show this one. Article D. 541-245 is explicit: anyone voluntarily communicating a score covering one or more environmental impacts of a textile product must also communicate the environmental cost. The order goes further, requiring its type size to be at least equal to that of the price and of the competing score. This obligation sits under the same 1 October 2026 transition.
So a brand displaying an in-house indicator or a numbered label today will have to display the environmental cost beside it from October.
The EU passport, and the question nobody answers
The Digital Product Passport is European law, and nothing is due today for a textile product: the delegated act is not written. The detailed calendar is covered in a separate article.
Which leaves the question everyone asks and nobody answers: will the French product sheet survive the European passport, or be absorbed by it?
Honestly, there is no official position. The September 2025 ministerial guidance contains not one occurrence of the word passport, nor of ESPR. What circulates on this point comes from software vendors, not from public authorities.
Four things to do before 1 October
Check whether you already display an environmental score, an in-house indicator, a label rating, a carbon figure. If you do, the obligation to display the environmental cost as well will reach you, with a type-size constraint attached.
Look at where your manufacturing places sit. If they live in a separate sheet, they also have to appear on the product page, next to the price.
Decide whether you want to own your environmental cost. After 1 October a third party may publish one without your agreement. Calculating and publishing your own is the only way to make your figure the one that stands, since the producer's prevails and third parties have a month to align.
Lift composition and countries out of your descriptions. That is the work serving all four texts at once, and the only part that takes real time.
What overlaps, and why that is the good news
Look at what these texts ask for, ignoring their names.
The countries of the production stages are wanted by the AGEC sheet and by the new online display obligation. Composition and recycled content feed the AGEC sheet, the environmental cost calculation and the future passport. Hazardous substances appear in the AGEC sheet and at batch level in the passport's preparatory work.
In other words, one clean set of data feeds all four. This is not four projects. It is one, presented four ways.
That is exactly why it is worth lifting this information out of product descriptions and into structured fields, whatever threshold catches you today. The method is set out in the textile passport data, and the practical path in the passport seen from WooCommerce.