Climate & Resilience Law Article 23 - Development of Bulk Sales
This measure aims to reduce packaging, particularly primary packaging, and to develop the sale of unpackaged products, especially in bulk, in retail.
The current restriction in Article L.120-1 of the Consumer Code concerning "mobile sales points" is removed, in order to broaden the possibilities for selling without packaging.
Decree No. 2025-1102 of November 19, 2025, on Sales Areas for Bulk Products
This decree, published on November 21, 2025, specifies the calculation method for the objective set by the "Climate and Resilience" Law, which requires that 20% of the sales area for consumer goods in stores larger than 400 m² be dedicated to products without primary packaging, including bulk products.
Section II of Article 23 of the "Climate and Resilience" law stipulates that "Retail stores larger than 400 m² must, by 2030, dedicate at least 20% of their sales area for consumer goods to the sale of products without primary packaging, including bulk sales." The objective thus applies to products sold in bulk as defined by the Consumer Code, but also more broadly to other products sold unpackaged (particularly in quantities not chosen by the consumer). This provision aims to support the reuse of packaging and reduce single-use packaging waste, with a view to a circular economy and reducing the environmental impact of consumption.
Decree No. 2025-1102 of November 19, 2025, specifies the methodology to be used by retail businesses with a sales area of over 400 m² for which the sale of fast-moving consumer goods (FMCG) represents more than 5% of their annual turnover excluding VAT, to measure the development of this sales method.
To achieve the target of 20% of products sold without primary packaging, the businesses concerned can choose one of the following three calculation methods:
Calculation based on sales area
This involves measuring the proportion of the FMCG sales area dedicated to products sold without primary packaging. Certain products are excluded (products prohibited from being sold in bulk, particularly for hygiene reasons) or taken into account in a modified way (alcoholic beverages, cosmetics, detergents, certain single-use hygiene products, and products sold in reusable or refillable packaging).
The sales area used to measure the bulk sales target (20%) corresponds to the floor space occupied by the display units for consumer goods, after deductions for:
• Products whose sale in bulk is prohibited
• 75% of the area dedicated to the following categories: Alcoholic beverages/Cosmetics/Detergents (excluding specific exceptions)/Single-use hygiene products (excluding toilet paper and paper towels)/Products sold in reusable packaging or via home refill systems
Area to be considered = Total sales area of consumer goods - Area of products prohibited from being sold in bulk - 75% of the area of the modified categories
Calculation in terms of revenue
The business can reach the target by generating 20% of its annual revenue (excluding VAT) from products without primary packaging. The same exclusions and adjustments as for sales area apply.
Revenue to be taken into account = Total revenue from fast-moving consumer goods - Revenue from products prohibited in bulk - 75% of revenue from adjusted categories
Calculation by number of SKUs
The store can also meet the target by achieving 20% of product SKUs sold without primary packaging. Here again, prohibited or adjusted SKUs are either not taken into account or are only partially taken into account.
Volume to be taken into account = Total volume of fast-moving consumer goods - Volume of products prohibited in bulk - 75% of the volume of adjusted categories
This calculation method should allow the businesses concerned to experiment and choose the simplest calculation method, in order to limit the administrative burden associated with monitoring the target set by law by 2030.