Decree No. 2025-1102 of November 19, 2025 specifies the conditions for applying Article 23 of the so-called “Climate and Resilience” law by setting out the calculation methods for achieving the target for retail businesses to devote 20% of their sales area for fast-moving consumer goods to the sale of products without primary packaging, including bulk goods.
What does the law provide for?
Article 23 of Law No. 2021-1104 of August 22, 2021, on combating climate change and strengthening resilience to its effects—known as the “Climate and Resilience Law”—provides that « as of January 1, 2030, retail stores with a surface area greater than or equal to 400m2 shall devote at least 20% of their sales area for fast-moving consumer goods to the sale of products presented without primary packaging, including bulk sales, or a measure with an equivalent effect expressed in terms of the number of items or as a proportion of turnover. »
This text refers to a decree specifying the objectives to be achieved.
Who is affected?
The decree applies to retail stores:
– with a sales area of 400 m² or more,
– for which the sale of fast-moving consumer goods represents more than 5% of annual turnover excluding tax.
How is the 20% target calculated?
Based on sales area
This involves measuring the proportion of the sales area for fast-moving consumer goods dedicated to products sold without primary packaging, after deducting:
- the sales area for products that cannot be sold in bulk (particularly for hygiene reasons), and
- 75% of the sales area dedicated to certain product categories (alcoholic beverages, cosmetics, detergents, single-use hygiene products, other consumer goods sold in reusable primary packaging or refill systems).
Based on turnover
This involves calculating whether the business generates at least 20% of its annual turnover (excluding tax) from fast-moving consumer goods sold without primary packaging, after deducting turnover from products that cannot be sold in bulk and 75% of turnover from certain product categories (see list above).
Based on the number of items
This involves calculating whether the business generates at least 20% of its annual sales volume, expressed in number of items, from the sale of consumer goods sold without primary packaging, after deducting the annual sales volume resulting from the sale of fast-moving consumer goods that are prohibited from being sold in bulk, and 75% of the sales volume resulting from the sale of certain product categories (see list above).
To better understand this new regulation, you can consult the DGCCRF’s practical information sheets and/or contact us.