DPP Compliance Guide for French Companies

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France's Position as a Sustainability Pioneer

France has long been at the forefront of sustainability legislation within the European Union, and the arrival of the Ecodesign for Sustainable Products Regulation (ESPR) represents both a validation of French policy leadership and a new set of requirements that French companies must navigate. EU Regulation 2024/1781, which entered into force on 18 July 2024, builds upon many of the principles that France has already embedded in its national legislation, particularly the landmark AGEC law (Anti-Gaspillage pour une Economie Circulaire) enacted in 2020.

The AGEC law introduced requirements for repairability indices, restrictions on the destruction of unsold goods, and enhanced consumer information obligations, all themes that resonate strongly with the ESPR. French companies that have already adapted to AGEC requirements may find certain aspects of ESPR compliance more familiar than their counterparts in other EU member states. However, the ESPR goes significantly further in scope and detail, particularly with its introduction of mandatory Digital Product Passports (DPPs) for a wide range of product categories.

This guide examines the specific implications of the ESPR for French companies, the sectors most affected, and the practical steps needed to achieve full compliance with DPP requirements.

How French Law Aligns with the ESPR

France's existing legislative framework provides a useful foundation for ESPR compliance, but there are important differences and additional requirements that companies must understand. The AGEC law, the Climate and Resilience Law of 2021, and various sector-specific regulations have already introduced concepts that the ESPR now elevates to an EU-wide standard.

The repairability index, which France pioneered for certain electronics and appliances, is conceptually aligned with the ESPR's requirements for repairability information in Digital Product Passports. French companies that have implemented repairability scoring systems can leverage this experience when building out their DPP data sets. However, the ESPR's requirements may differ in detail from the French national system, and companies must ensure that they meet the specific data fields and formats specified in the relevant delegated acts.

France's extended producer responsibility (EPR) schemes, which are among the most comprehensive in Europe, also provide relevant infrastructure. The data collection and reporting systems that companies have developed to comply with EPR obligations can often be adapted to support DPP requirements, reducing the incremental effort needed for ESPR compliance.

Nevertheless, the ESPR introduces requirements that go beyond existing French law, including the mandatory creation of machine-readable Digital Product Passports, new environmental footprint methodologies, and expanded transparency obligations. French companies should not assume that existing compliance measures are sufficient and must conduct thorough gap analyses against the specific ESPR requirements for their product categories.

Key French Industries Affected

France's diverse industrial base means that the ESPR will affect companies across numerous sectors. Certain industries, however, face particularly significant impacts due to their prominence in the French economy and the timing of ESPR delegated acts.

• Fashion and luxury goods: France is the global capital of fashion, home to major luxury houses and a vast network of textile manufacturers. The ESPR's textile-specific requirements, including material composition transparency and environmental footprint data, will have a major impact on this sector.
• Cosmetics and personal care: France is the world's largest exporter of cosmetics, and products in this category may face ESPR requirements related to packaging sustainability and ingredient transparency.
• Automotive: With major manufacturers like Renault, Stellantis (Peugeot, Citroen), and a substantial components supply chain, France's automotive sector will need to comply with ESPR requirements for vehicle parts and batteries.
• Agri-food and packaging: While food products themselves may not fall directly under the ESPR, packaging materials used by France's large food industry will be subject to sustainability requirements.
• Electronics: French electronics companies and distributors will face requirements for energy efficiency data, repairability information, and recycled content disclosure.
• Construction and building materials: France's construction sector will need to provide detailed sustainability data for building products, including embodied carbon and recyclability metrics.

Companies in these sectors should closely monitor the ESPR timeline and deadlines to understand when their specific obligations will take effect.

Current Readiness of French Companies

French companies benefit from a regulatory culture that has long emphasised environmental responsibility, and many businesses have existing sustainability reporting and data collection systems in place. The AGEC law, in particular, has driven widespread adoption of repairability assessments, waste reduction programmes, and consumer information initiatives that provide a baseline for ESPR compliance.

Large French corporations, particularly those in the CAC 40, have generally been proactive in sustainability reporting and are well-positioned to extend their efforts to encompass DPP requirements. Many have dedicated sustainability teams, established ESG reporting frameworks, and experience with EU regulatory compliance that can be leveraged for the ESPR.

Small and medium-sized enterprises (PME) in France, however, face greater challenges. While awareness of sustainability obligations is relatively high, the technical complexity of implementing Digital Product Passports, including data standardisation, system integration, and supply chain coordination, can be daunting for smaller businesses with limited resources. The French government and business support organisations such as Bpifrance and the CCI (Chambers of Commerce and Industry) are developing guidance and support programmes, but individual companies must take proactive steps to assess their readiness.

Understanding what a Digital Product Passport entails and the data infrastructure it requires is an essential first step for any French company preparing for compliance.

Practical Steps for French DPP Compliance

French companies should approach DPP compliance as a natural extension of their existing sustainability efforts, building on the foundations laid by French national legislation. The following steps provide a structured approach to achieving compliance.

• Conduct a regulatory gap analysis: Compare your current compliance status under AGEC and other French laws with the specific requirements of the ESPR and its relevant delegated acts. Identify areas where additional data collection or process changes are needed.
• Leverage existing data assets: Review the sustainability data you already collect for AGEC compliance, EPR reporting, or voluntary sustainability programmes. Much of this data may be directly applicable to DPP requirements.
• Invest in data infrastructure: Ensure that your IT systems can support the creation, storage, and sharing of Digital Product Passports in the standardised formats required by the ESPR. Consider cloud-based solutions like MyProductPassport that can accelerate implementation.
• Coordinate with supply chain partners: Engage suppliers, particularly those outside France, to establish data-sharing protocols and ensure that upstream sustainability data is available and reliable.
• Align with French and EU standards: Work with standards bodies such as AFNOR and CEN-CENELEC to ensure that your DPP implementation complies with evolving technical standards.
• Plan for phased implementation: Begin with product categories subject to the earliest delegated acts, and use the experience to build organisational capability before broader rollout.

For a strategic framework for ESPR preparation, consult our guide on preparing your business for ESPR, which provides actionable insights applicable to companies in any EU member state.

The French Fashion Industry and Digital Product Passports

The fashion and luxury sector deserves particular attention given its importance to the French economy and the early prioritisation of textiles under the ESPR. France is home to globally recognised brands whose products are synonymous with quality and craftsmanship. The ESPR's transparency requirements present an opportunity for these brands to demonstrate their sustainability credentials through comprehensive Digital Product Passports.

French fashion companies will need to provide detailed information about fibre composition, country of manufacture, environmental footprint, and end-of-life guidance for each garment or accessory. For luxury brands, this transparency can reinforce narratives of quality and responsibility. For fast-fashion operators, the requirements may necessitate more fundamental changes to sourcing and production practices.

France has already moved ahead of the ESPR timeline in some respects. The AGEC law requires clothing manufacturers to disclose the presence of microplastics and to participate in textile recycling schemes. The ESPR will build on these requirements and extend them across the EU, creating a level playing field that French companies have been advocating for.

The integration of DPP data with customer-facing digital experiences, such as QR codes on garment labels that link to comprehensive sustainability information, represents a particularly compelling opportunity for French fashion brands to engage environmentally conscious consumers.

Navigating French and EU Regulatory Layers

French companies face the complexity of operating within multiple regulatory layers: national French law, EU regulations, and potentially international standards for products exported beyond Europe. Managing this complexity requires a systematic approach to compliance that avoids duplication of effort while ensuring that all applicable requirements are met.

Where French national law and the ESPR overlap, companies should aim to build unified compliance systems that satisfy both sets of requirements simultaneously. This is more efficient than maintaining separate processes and reduces the risk of contradictory or incomplete compliance. Working with legal advisors who understand both French and EU regulatory frameworks is advisable, particularly during the transition period as ESPR delegated acts are published.

The complete guide to the ESPR provides the broader European context that French companies need to understand alongside their national obligations. By taking a holistic view of their regulatory landscape, French companies can turn compliance complexity into a competitive advantage.

Conclusion: France's Opportunity to Lead

France's pioneering sustainability legislation has given its companies a head start in many aspects of ESPR compliance. The AGEC law, extended producer responsibility schemes, and a culture of environmental awareness provide a strong foundation upon which to build Digital Product Passport capabilities.

However, the ESPR introduces new requirements that go beyond existing French law, and companies must not become complacent. Those that proactively assess their gaps, invest in digital infrastructure, and engage their supply chains will be best positioned to achieve compliance efficiently and to leverage the commercial opportunities that transparency creates. France has the opportunity to lead Europe in DPP implementation, and the companies that seize this opportunity will be rewarded with stronger market positions and deeper customer trust.