PARIS, March 31, 2026 — The Autorité de la concurrence has published informal guidance on a proposed voluntary charter encouraging retailers to promote household electrical and electronic products with stronger environmental and energy performance.
The guidance was issued following a request from the Agence de l’environnement et de la maîtrise de l’énergie, which is developing a charter aimed at encouraging retailers in France to highlight products with better sustainability characteristics.
The proposed initiative seeks to increase the visibility of products with higher environmental and energy ratings, including those assessed under the EU Energy Label and France’s repairability and durability indices.
In its assessment, the competition authority’s General Rapporteur concluded that the project appears compatible with competition rules given that participation in the charter would be voluntary, open and non-exclusive. However, the authority identified several points participants should consider to avoid potential competition concerns.
Among these, retailers must retain full freedom to define their own sustainability strategies and should not align their commercial behaviour through the adoption of identical commitments. The authority also stressed the need for meaningful individual commitments that genuinely contribute to sustainability objectives and avoid risks of “greenwashing.”
The regulator further warned that retailers and ADEME must ensure that no commercially sensitive information is exchanged between competitors during the implementation of the charter, including indirectly through data sharing or coordination mechanisms.
The authority also highlighted potential risks for consumers and suppliers if commitments result in reduced product variety, higher average prices or the exclusion of suppliers specialising in less sustainable products.
In addition, the guidance cautions against collective commitments that would restrict retailers from developing their own sustainability rating systems in favour of regulatory labels, as such arrangements could raise competition concerns.
The advisory opinion forms part of the authority’s “open door” policy launched in 2020, which allows companies to seek informal guidance on complex projects involving sustainability initiatives. The regulator introduced a formal framework for such guidance in 2024 following a public consultation and in line with the European Commission’s updated horizontal cooperation guidelines.
The sustainability charter initiative marks the fifth project to receive informal guidance from the authority under the scheme.
