HVE and the EGalim Law: What Changes on 1 January 2027 for Public Catering
It is a discreet deadline that will nonetheless reshape part of public catering’s supply: on 1 January 2027, level 2 of the environmental certification of farms will stop counting towards the 50 % of sustainable, quality products required by the EGalim law. Only High Environmental Value — level 3 — will remain eligible on that basis.
The framework: article L. 230-5-1 of the Rural Code
The 2018 EGalim law inserted article L. 230-5-1 into the Rural and Maritime Fishing Code, setting collective catering an objective of 50 % sustainable, quality products, of which at least 20 % from organic farming, in the total value of food purchases.
This list of eligible products aggregates several families: official quality and origin signs, products from organic farming, products bearing the fishing eco-label, and products from farms holding the environmental certification.
It is on this last point that the change bears.
What changes and why
Products from farms certified at level 3, that is HVE, count towards the 50 % with no time limit.
Products from farms certified at level 2 also count, but until 31 December 2026. From 1 January 2027, they will drop out.
The logic of this time limit is explicit: it was designed to encourage farms enrolled at level 2 to progress towards level 3, giving them several years to reach the High Environmental Value requirements. It is a transition device, not an exclusion.
Recall the difference between the two levels, because it is decisive. Level 2 rests on a set of means-based requirements — sixteen requirements spread across the four themes: biodiversity, crop protection strategy, fertilisation management, water resource management. Level 3 rests on outcome indicators and requires at least ten points on each of the four grids, with no compensation. The gap is not cosmetic: it is a change of nature.
Note in passing that level 1, which rested on a self-assessment and led to no certificate, was removed by a decree published in late October 2023. The scheme therefore has only two levels left.
What this changes for a farm
If you hold level 2 and public catering is a share of your turnover, your timetable is already tight.
The reasoning falls into three steps:
- Measure the real gap to level 3. A self-assessment on the four grids will tell you whether you are a few points or a whole theme from the threshold. It is the first thing to do, and it takes a few days, not a few months.
- Handle the blocking criteria. The revised standard applicable since 1 January 2023 introduced blocking criteria on the biodiversity and crop protection strategy themes: their breach prevents certification, whatever the point total. They come before any optimisation.
- Book the audit. The HVE certificate is issued for three years after an initial on-site audit. Booking lead times with approved certification bodies vary; plan ahead, all the more as the deadline nears and other farms make the same calculation.
The full path is detailed in our guide on how to obtain HVE certification.
What this changes for a public buyer
On the buyer’s side, vigilance bears on three concrete points.
Check the level, not the word “certification”. A supplier announcing a farm “certified environmental” may be at level 2. Ask for the certificate itself: level, approved certification body, validity dates, scope. It is the only document that counts in the 50 % calculation.
Anticipate processed products. The “From a High Environmental Value farm” logo can only be placed on a processed product if it is made of at least 95 % agricultural raw materials from HVE-certified farms. The rules are detailed in our article on the HVE logo and labelling.
Secure contracts straddling the deadline. A multi-year contract signed in 2026 and performed in 2027 will see its calculation shift mid-performance. Provide for the clause allowing level 3 to be required from 1 January 2027, or another family of eligible products to be substituted.
A legibility issue, not just compliance
Behind the regulatory mechanics lies a real communication problem: few diners — and few non-specialist buyers — can tell a level 2 from a level 3, nor what each guarantees.
This is not specific to HVE. The work of Grunert, Hieke and Wills published in 2014 in Food Policy shows that consumer knowledge of sustainability labels remains limited, that their actual use is low, and that the accumulation of signs fuels confusion rather than information (see the study). The 1 January 2027 limit has at least one merit: it simplifies the message by leaving only a single level of environmental certification in the 50 %.
For managers, the practical consequence is that recounting will be needed. A purchasing dashboard that today aggregates “environmental certification” without distinguishing levels will have to be reworked line by line before the end of 2026.
Take action
If you are a level-2-certified farm with a public catering outlet, launch the self-assessment on the four grids now and contact an approved certification body: the 31 December 2026 deadline leaves few seasons. If you are a buyer, go through your suppliers one by one and demand the certificate. For the whole scheme — levels, standard, audit, valorisation — see our guide to HVE certification.
Frequently asked questions
+What exactly does the EGalim law say about the 50 %?
Article 24 of the 2018 EGalim law inserted article L. 230-5-1 into the Rural Code, requiring collective catering to include a minimum share of 50 % sustainable, quality products, of which at least 20 % from organic farming. Products from farms certified High Environmental Value count towards this 50 %.
+Does level 2 still count today?
Yes, until 31 December 2026. Products from farms certified at level 2 of the environmental certification count towards the 50 % until that date. From 1 January 2027, only products from farms certified High Environmental Value — level 3 — will still count on that basis.
+What should a public buyer check on a certificate?
The exact level — a certificate 'of environmental certification' says nothing of its level —, the name of the approved certification body, the validity dates, and the scope covered. For a processed product, you must also check the share of agricultural raw materials from certified farms, the logo usage threshold being set at 95 %.