Understanding the French Carbon Score for Medicines

Michael Lenaghan

Associate Director

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Michael Lenaghan

Michael applies expertise in lifecycle assessment and circular economy principles to help organisations translate environmental data into decisive climate action.

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Casey Merbler

Client Discovery Lead

North America

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Casey Merbler

Casey brings nine years of experience in corporate sustainability, combining mission-driven expertise with a strong business lens. At Anthesis, Casey has spent four years helping companies design and implement strategies that deliver measurable environmental and long-term business value.

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Table of Contents

• What is the French carbon score?
• Commercial significance of the carbon score
• What should companies do to prepare?
• Why primary data is critical
• How Anthesis can help

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From August 21, 2026, France’s Climate and Resilience Law (Loi Climat et Résilience) requires all public procurement contracts to include environmental assessment criteria, with recommended weighting of 10–20%.

The “Carbon Score” for medicines (“score carbone médicament”) has been explicitly designed by the French Government to fulfill this requirement for public contracts of pharmaceutical products.

France’s carbon score also marks a major first step globally for the integration of product carbon data in procurement decision-making, with the UK’s NHS due to enact similar measures in 2028, and other EU countries expected to follow suit.

To maintain their competitiveness in French public contracts beyond August 2026, pharma companies must develop the strategic capability to develop and disclose product carbon footprints across their portfolio.

What is the French carbon score?

The French carbon score is a Product Carbon Footprint (PCF) methodology aligned with ISO and the GHG Protocol – but is significantly more prescriptive.

The carbon score methodology includes:

• Goal & scope definition (cradle-to-grave; multiple prescribed functional units)
• Strict data hierarchy and emission factor selection
• Mandatory data quality scoring (Data Quality Review-based uncertainty)
• Documentation and supplier attestation
• Evaluation matrix submission format (standardised Excel)

Critically, final scores may be adjusted or rejected based on:

• Data uncertainty level
• Economic data use
• Missing or low-quality data (surcharges)

The score is based on a product’s carbon footprint (expressed in kg CO₂e), but may be inflated as a result of ‘surcharges’ triggered by data gaps or low data quality. Therefore, a lower carbon score is more highly favoured in procurement processes.

Commercial significance of the carbon score

Current government procurement guidance in France recommends that environmental criteria account for around 10–20% of the total tender evaluation score. As a result, pharmaceutical companies that are unable to provide carbon scores for their products, or those whose products score poorly due to higher carbon footprints or surcharges resulting from incomplete data or excessive uncertainty, will face a significant commercial disadvantage in public tenders. ​

In practice, data quality and completeness will directly influence environmental scoring and therefore overall tender competitiveness.

Impacts of poor data quality or completeness include:

1. Uncertainty threshold
   • All PCFs are assigned Data Quality Review-based uncertainty to assess and quantify data uncertainty
   • PCFs with >45% uncertainty will be deemed non-compliant
   • Primary production and supplier data can materially reduce risk
2. Economic data cap
   • Economic emission factors are capped at 25% of ingredient/packaging footprint
   • A heavy reliance on spend-based data increases compliance risk
3. Surcharge mechanisms
   • Missing or low-quality data triggers specific percentages of carbon penalties
   • Surcharges stack on top of one another
   • Surcharges can inflate final carbon score, directly harming tender competitiveness

Taking these impacts into account, two products with similar real emissions can perform very differently depending on evidence quality and documentation robustness.

What should pharmaceutical companies do?

Pharma companies must build and implement a credible, scalable PCF capability, aligned with the carbon score methodology and reporting requirements, and supported by structured internal and supplier data collection and documentation controls.

Key methodological and operational requirements:

Area	Practical Requirement
Scope & boundaries	Cradle-to-grave; defined inclusions/exclusions per Presentation Code (CIP)
Functional unit	Presentation Code (CIP), Common Dispensing Unit (UCD), and Defined Daily Dose (DDD) calculations required
Data hierarchy	Strict prioritisation of primary over secondary; economic emission factors limited
Data quality	Embedded Data Quality Review scoring per input
Allocation	Defensible site, batch, and shared-service allocation logic
Governance	5-year validity; reassessment if >10% change
Documentation	Full audit trail and structured evidence pack

What a compliant capability looks like

A company must operationalise:

• A scalable PCF capability, aligned with carbon score methodology and reporting requirements
• Embedded Data Quality Review scoring logic
• A supply chain data and documentation collection program
• Standard operating procedure for activating and integrating PCFs for French public contracts
• Internal training and governance ownership

The Carbon Score sets the bar for pharmaceutical PCFs. A PCF capability that meets and performs well under the French carbon score will align with ISO and the GHG Protocol, and will support customer disclosure and decarbonisation. The reverse is not guaranteed. 

Why primary data is critical

Obtaining and integrating primary production and supplier data into PCFs is key to staying under critical carbon score thresholds and avoiding punitive surcharges.

There are two valid options for supplier data:

• Footprint Data – PCFs, Environmental Product Declarations (EPDs), or Life Cycle Assessments (LCAs) which meet carbon score requirements and come with supporting documentation. These result in the lowest uncertainty score.
• Primary activity and product data – which the customer converts into carbon data according to carbon score requirements.  This data results in a moderate uncertainty score.

In the absence of supplier data, average data – following a strict data hierarchy and using prescribed data sources – is required, bearing the highest uncertainty score.

The carbon score requires different levels of data, verification, and documentation depending on the class of supplier good: Active Pharmaceutical Ingredients (APIs) (highest requirement), Excipients, Packaging, Logistics (lowest requirement).

How Anthesis can help pharmaceutical clients

We can design and embed carbon score–aligned product carbon footprint capabilities that ensure compliance and competitiveness in French public contract and simultaneously leverage these to enable wider customer disclosure and decarbonisation.

1. Carbon score–aligned PCF architecture

Design and build a calculation framework and tool fully aligned with the French carbon methodology, integrating production, spend, and supplier data to generate compliant, tender-ready outputs. If required, we can also provide direct PCF development as a managed service.

2. Internal data structuring & readiness

Assess existing product and production data, identify and close gaps, and structure inputs to meet uncertainty thresholds and documentation requirements, ensuring data performance thresholds are met and reducing surcharge exposure.

3. Structured scope 3 supplier data programme

Develop and implement a targeted supplier engagement model to secure compliant primary data and required attestations. Embed quality control, documentation checks, and integration pathways to convert supplier inputs into compliant carbon score outputs. This can include a managed service to convert primary supplier product/activity data into carbon data using Anthesis Intelligence.

4. Governance, operating model & capability transfer

Define the internal operating model required to sustain compliance and performance, including:

• Clear roles, decision points, and accountability
• Data and documentation control processes
• Audit trail architecture
• Targeted training to embed capability internally

Through these services, we ensure a strategically designed, carbon score–ready product carbon capability, compliant under French rules, resilient to audit, commercially competitive in procurement, and scalable across the portfolio.