1. Has the EmpCo Directive been implemented into national law?
    1. Has a draft implementing act already been published?
    2. What is the expected timeline for transposition of the Directive?
    3. Are any provisions envisaged exceeding the minimum harmonisation requirements, or specific deviations? Please specify.
  2. Have official guidelines, FAQs or interpretative guidance been issued by competent authorities or consumer protection bodies regarding the application of the EmpCo Directive?
  3. Are there any national or regional EN ISO 14024 type I ecolabelling schemes that substantiate a generic environmental claim as they demonstrate “recognised excellent environmental performance”?
  4. Which sanctions and enforcement mechanisms are available or envisaged (e.g. administrative fines, prohibition orders, injunctions, market bans, civil enforcement actions)?
  5. Which authorities or institutions are competent for enforcement and supervision?
  6. Is there already specific case law on environmental claims and/or sustainability labels? 

jurisdiction

France
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1. Has the EmpCo Directive been implemented into national law?

No.

1.1 Has a draft implementing act already been published?

Yes.

1.2 What is the expected timeline for transposition of the Directive?

In principle, by 27 March 2026 but it seems that it will be later.

1.3 Are any provisions envisaged exceeding the minimum harmonisation requirements, or specific deviations? Please specify.

N/A.

2. Have official guidelines, FAQs or interpretative guidance been issued by competent authorities or consumer protection bodies regarding the application of the EmpCo Directive?

No.

3. Are there any national or regional EN ISO 14024 type I ecolabelling schemes that substantiate a generic environmental claim as they demonstrate “recognised excellent environmental performance”?

No.

4. Which sanctions and enforcement mechanisms are available or envisaged (e.g. administrative fines, prohibition orders, injunctions, market bans, civil enforcement actions)?

Normal sanctions for misleading commercial practices, i.e.:

Natural persons:

  • Imprisonment for up to:
    • 2 years or
    • 3 years if the offence was followed by the conclusion of one or more contracts,
    • 5 years if the offence was committed online; and
  • A fine of up to: 
    • €300,000 or
    • €750,000 if the offence was committed online

Legal entities:

  • A fine of up to :
    • €1.5 million or 
    • €3.75 million if the offence was committed online, or
    • 10% of average annual turnover, or
    • 80% of the expenditure incurred in carrying out the advertising or the practice

5. Which authorities or institutions are competent for enforcement and supervision?

The Directorate-General for Competition, Consumer Affairs and Fraud Prevention (DGCCRF).

6. Is there already specific case law on environmental claims and/or sustainability labels? 

There are examples of published criminal settlements imosed by the DGCCRF concerning green claims (€40M against Shein).

Moreover, on 23 October 2025, the Paris Commercial Court ruled against Total Energies for misleading commercial practices relating to claims made in its environmental communication regarding its “ambition to achieve carbon neutrality by 2050” and “to be a major player in the energy transition”.