Do You Need an AGEC Product Sheet, a Digital Product Passport or Both?

France's AGEC product sheet is a legal duty now for brands over both thresholds, while the EU textile passport is still to come, and the same sourced facts can serve both.

Reading time: 7 min
Published by: ActivateDigital
Last verified: 10 October 2026
Sources: 9

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A denim jacket on a hanger with a hand holding a phone with a dark screen reading its white swing tag.

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In 60 seconds
Who has to publish the French product sheet
What a textile sheet has to say
Where and how the sheet must be available
The AGEC sheet, the DPP and environmental cost compared
Will the DPP replace the French sheet?
Reuse the facts, not the legal conclusion
What to do now if you're a small brand selling into France
Keep exploring
Sources

In 60 seconds

For textiles sold to consumers in France in October 2026, the AGEC product sheet is the one that's a legal duty, and only for a business over both French thresholds: more than €10 million turnover and at least 10,000 units of the products concerned placed on the French market each year. The EU Digital Product Passport for textiles isn't an obligation yet. The Commission plans to adopt the textiles delegated act in Q4 2027. The two are different disclosures under different laws, though many of the facts underneath them are the same.

Who has to publish the French product sheet

The duty comes from Article 13 of France's 2020 anti-waste and circular economy law (loi AGEC). Décret n° 2022-748 of 29 April 2022 set out the detail in the Code de l'environnement. Those articles were renumbered in April 2024 and now sit at R. 541-227 to R. 541-230. The ministry's FAQ, updated in November 2025, still sets out the same thresholds and textile qualities.

The duty falls on whoever places new consumer products on the French market: producers, importers and other operators. The ministry's FAQ counts a retailer selling goods under its own brand as a producer. Second-hand and refurbished goods sold by professionals are outside it.

Both thresholds have to be met. They were phased in:

From	Turnover	Units placed on the French market per year
1 January 2023	over €50 million	at least 25,000
1 January 2024	over €20 million	at least 10,000
1 January 2025	over €10 million	at least 10,000

According to the FAQ, turnover means the last financial year's turnover from the products concerned placed on the French market. Units are the total of those products placed nationally. A brand under either figure has no duty to publish the sheet. Retailers that only resell another producer's goods aren't required to republish it, though the FAQ encourages marketplaces to do so.

The products concerned are those in France's producer responsibility categories. Textiles fall under category 11°, which the FAQ describes as clothing textiles, household linen and footwear. Other categories, such as electrical equipment, toys and furniture, carry their own set of qualities. This article covers textiles only.

What a textile sheet has to say

The 2022 decree gives each quality its own trigger and its own fixed French wording.

Quality	When it applies to textiles	What the sheet says
Recycled content	Category 11° products, except leather articles	"produit comportant au moins X % de matières recyclées". The FAQ says mass is calculated on a reference size for the model
Recyclability	Category 11° products meeting the recyclability conditions	"produit majoritairement recyclable" or, where the stricter condition is met, "produit entièrement recyclable"
Hazardous substances	A listed substance present above 0.1 % by mass	"contient une substance dangereuse" or "contient une substance extrêmement préoccupante", followed by the substance names
Traceability	Category 11° products	The country where each step took place. For textiles: weaving (which the FAQ says includes knitting and non-woven), then dyeing and printing, then making up. For footwear: stitching, assembly and finishing
Plastic microfibres	Synthetic fibres above 50 % of the product's mass	"rejette des microfibres plastiques dans l'environnement lors du lavage"

The decree also bans terms such as "biodégradable" and "respectueux de l'environnement" on new consumer products and their packaging.

Where and how the sheet must be available

Article R. 541-229, in force since 8 April 2024, sets the output rules:

Digital, and free to access at the time of purchase.
Reusable so it can be aggregated, with the data extractable for automated processing.
Published on a dedicated website or page, in a sheet titled "fiche produit relative aux qualités et caractéristiques environnementales".
Kept available for two years after the last unit of the product is placed on the market.

The FAQ adds that there's one sheet per model, at the finest level the information differs, such as per colour, titled with the model's name and reference, and that any update has to be dated on the sheet. A PDF whose text can't be selected doesn't meet the rule. No standard file format is imposed. A required quality can't be filled in with "non disponible". The DGCCRF enforces the duty, with fines of up to €3,000 for an individual and €15,000 for a company. One point catches brands below the thresholds: R. 541-229 says environmental information you choose to put on a physical medium, such as a label or swing tag, has to follow the same rules.

The AGEC sheet, the DPP and environmental cost compared

French textile brands often hear about three outputs at once. They answer different laws.

	AGEC product sheet	EU DPP for textiles	French environmental cost
Legal basis	French law: AGEC Article 13, Code de l'environnement R. 541-227 to R. 541-230	ESPR, Regulation (EU) 2024/1781, through a textiles delegated act	French framework under the 2021 Climate and Resilience law
Status in October 2026	In force	Not yet required. Delegated act planned for Q4 2027	Notified to the Commission in 2025 as a voluntary framework
Who	Producers and importers over both thresholds	To be set by the delegated act	Whoever chooses to display it
Content	A fixed list of qualities with fixed wording	To be set by the delegated act	One score in impact points
Where it lives	A dedicated web page per model	To be set by the delegated act	At the point of purchase if displayed
Market	France	EU	France

The Commission's own FAQ is plain on the DPP: "There is no general obligation for a product to have a DPP." It only becomes one when a delegated act for that product group says so. We track where the textile act has got to on the current textile DPP status.

Will the DPP replace the French sheet?

Partly, possibly and not yet. Recital 18 of the ESPR says that once a delegated act sets ecodesign requirements for a product group, Member States should no longer set national performance or information requirements on the product parameters that act covers. Until a textiles delegated act exists, nothing in the ESPR displaces the French sheet. When it arrives, the question becomes which French qualities overlap with parameters it covers. That can't be answered before the act is drafted.

France notified the draft decree to the Commission under the EU's technical regulation procedure (TRIS 2021/0644/F) in October 2021. The record lists comments from the Commission and Sweden. It records no detailed opinion. The decree was adopted in April 2022 and has applied since 2023.

Reuse the facts, not the legal conclusion

Neither output satisfies the other. A complete AGEC sheet isn't a DPP, and a DPP built later won't automatically carry the French wording. What carries across is the evidence underneath.

An illustration. A jersey dress is 62 % polyester and 38 % cotton by mass, knitted in Portugal, dyed in Portugal and made up in Morocco. That composition triggers the French microfibre statement today, because synthetic fibre is above 50 %. The same composition is a fact the Commission lists as likely content for the textile DPP. The countries for each step answer the French traceability duty now, and the Commission also lists origin information as possible DPP content. The supplier document that proves the composition is the same document in both cases. What certificates, declarations and test reports establish is a separate question from which output uses them. The legal conclusion drawn from it is not.

That's why it helps to keep each fact once, with its source and the date it was checked, in a governed product record, and to produce each output from it under that output's own rules. We explain how to start from what you hold in The data you already have, and what the textile passport is likely to need in Digital Product Passport for textiles.

What to do now if you're a small brand selling into France

Check both thresholds against your last financial year, counting only products concerned placed on the French market. Below either one, you have no duty to publish the sheet.
Check your labels anyway. Environmental information you put on a physical medium voluntarily has to follow the French rules, whatever your size.
If you're in scope, work model by model. Collect fibre composition by mass, evidence for any recycled content, supplier declarations on listed substances and the country for each step: weaving or knitting, then dyeing and printing, then making up.
Publish one dated sheet per model on a dedicated page, in a form a machine can read, and keep it up for two years after the last unit is placed on the market.
Don't build a textile DPP as a legal duty yet. Keep the underlying facts sourced so they're ready when the delegated act lands.

This answer would change if the textiles delegated act is adopted, if the Code de l'environnement articles are amended, or if the ministry issues the optional order on the technical presentation of the pages.

Keep exploring

The questions this page usually raises next.

Sources

Keep each fact once, with its source.

The French sheet and a future passport draw on the same product facts. Start from the records and evidence you already hold.

Organise the product evidence you already hold Check what your current data supports