What impact do rating systems have on competition? 

What is a rating system? 

Rating systems are tools for evaluating and ranking products or services based on specific criteria such as quality, performance, sustainability or environmental impact. They cover a wide range of sectors and are expressed by numbers, shapes, colours or letters. 

On a national level, laws and regulations impose mandatory labelling requirements for certain product categories. For instance, since 2018  , an energy label is mandatory on household electrical appliances and, since the AGEC law  , which came into force in 2021, a reparability index (replaced by a durability index in 2025) is compulsory for household washing machines and televisions. In addition, since the "Grenelle" laws of 2009 and 2010, environmental labelling has been created to raise consumer awareness of the environmental impact of the products and services they buy. A system has been set up to develop such labelling in the textile and food sectors.

On an European level, a proposal for a directive of 17 June 2024 regarding the justification and communication of explicit environmental claims, known as the "Green Claims Directive", is currently being adopted. It aims to respond to companies’ concerns linked to the diversity of rating systems, as it is a source of costs and logistical constraints, and to provide a framework for the environmental claims and labels voluntarily used by companies. 

Sustainable development, a competitive parameter

For some years now, sustainable development considerations such as animal welfare, the protection of human health and the environment have featured among consumers' purchasing criteria, alongside price, quality and innovation. Companies are investing more and more in these systems, and the sustainability of products, or even claims of 'being green', have become parameters of competition, which the competition authorities take into account when examining competitive practices.
Creation favourable conditions to competitive operation
The development of a rating system may present competitive risks, both in terms of the choice of rating criteria and the role they play in market behaviour. Accordingly, the French Competition Authority believes that compliance with certain conditions will ensure that the system operates competitively.

• Transparency of rating systems ;
• Robust calculation methods ;
• Objectivity of criteria ;
• Independence of players in the system construction process.

It should be noted that when setting up a rating system, the French Competition Authority draws attention to the fact that discussions between competitors may concern sensitive subjects in terms of competition law, such as price, quality, product supply, production or distribution mechanisms. Sharing this information could be problematic, if it reduces uncertainty on the market and facilitates the coordination of companies' behaviour. 

Similarly, the representativeness of the stakeholders is a key factor, given the issues involved in the choice of criteria and their weighting, in the creation of a system. Consequently, the FCA draws attention to the importance of effective representation of the economic players (companies and consumer associations) and the sectors concerned, otherwise the information generated could be considered potentially misleading for consumers and the rating system could lose its initial function of providing information on the merits. 

Points to watch when implementing rating systems 

Stakeholders are urged to be vigilant when implementing rating systems with regard to : 

• Access to databases and inputs;
• Any denigration practices;
• Possible lobbying practices ;
• Selective disclosure of ratings;
• Imposing a rating system on a business partner.

In conclusion, rating systems, by virtue of the information they provide, "stimulate competition". Players must therefore ensure that they are based on robust elements and that their development and implementation do not infringe competition rules.