Decree No. 2025-1102 “on the sales area targets for the sale of fast-moving consumer goods presented without primary packaging” was published in the Official Journal of the French Republic on 21 November 2025. It sets out the framework for calculating the space devoted to bulk products in shops larger than 400 m².
This Decree has been drawn up in application of Article 23 of Law 2021-1104, known as the Climate and Resilience Law, which stipulates that “by 1 January 2030, retail outlets with a surface area of 400 square metres or more shall devote to the sale of products presented without primary packaging, including sales in bulk, either at least 20% of their sales area of mass-market products, or an arrangement with an equivalent effect expressed in terms of number of references or proportion of turnover.”
The Decree…
It sets out the methods for calculating this target and specifies the methodology to be used by retailers. It also provides for alternative options based on turnover or the number of items sold.
It excludes from the calculation basis the sale of products that cannot be sold in bulk for public health reasons, and introduces a modulation for five types of products:
• Alcoholic beverages
• Cosmetics
• Detergents
• Single-use hygiene products
• Other fast-moving consumer goods sold in reusable primary packaging or refillable containers
For them, the sales area, turnover or total number of references taken into account for measuring the 20% target is subject to a 75% deduction.
