Pillar guide
The Complete Guide to French Textile EPR for Fashion Brands
How French textile EPR works for apparel brands: registration with a PRO, eco-modulation, eco-fee calculation, declaration deadlines, labelling rules, and penalties up to €30,000.
Who this guide is for
Compliance, finance, and product-data leads at upper-mid-market EU/UK apparel brands (100–500 FTE) that already file French textile EPR declarations, or are about to.
01
What French textile EPR is
Extended Producer Responsibility makes the brand that first places clothing, household linen, or footwear on the French market financially responsible for its end of life.
- Extended Producer Responsibility (EPR) for textiles is built on France's AGEC law (Anti-Gaspillage pour une Économie Circulaire), which made France the first country in the EU to require mandatory EPR for clothing, household linen, and footwear, with rules in place since 2007 and the current framework administered by Refashion, the approved eco-organism for the sector. The "producer" obligated to register and pay is whichever entity first places the product on the French market — this can be the brand itself, an importer, a distributor selling under its own label, or in some cases a marketplace facilitating third-party sales. In scope: clothing, household linen (bed linen, table linen, bath linen), and footwear sold to French consumers. Outside scope: items that never enter the French market, and certain technical or protective categories defined narrowly in the Refashion tariff tables.
02
Who must register, and by when
Registration with an approved producer responsibility organisation is mandatory before you sell, not after your first reporting period.
- Registration with Refashion is mandatory before you place your first product on the French market — not after your first sales period closes. There is no meaningful de-minimis threshold for apparel: unlike some other EPR streams, textile EPR in France applies from the first unit sold, so small catalogues are not automatically exempt. Non-EU sellers shipping into France must register either directly or through an authorised representative established in France, who takes on reporting responsibility on their behalf. Failing to register carries fines of up to €30,000, and this exposure exists independently of whether your actual eco-fee liability is large or small — the penalty is for the compliance failure, not the fee amount.
03
How eco-fees are calculated
Fees are per unit, set by product category, then adjusted by eco-modulation bonuses and penalties.
- Refashion offers two declaration routes. Under the simplified declaration, 2026 flat rates are €0.5799 per clothing item, €0.6525 per household linen item, and €0.6414 per footwear item — no eco-modulation applies under this route. Under the detailed declaration, fees are set per specific product line and demographic (for example, a men's T-shirt is priced separately from a child's T-shirt), with per-item rates in 2026 ranging from roughly €0.02 for smaller items like children's underwear up to over €0.21 for items like men's boots, then adjusted by eco-modulation bonuses or maluses.
- Worked example: A brand sells 50,000 men's T-shirts (code V-11-H-EM0, €0.0396/item) and 20,000 pairs of men's jeans (code V-16-H-EM0, €0.1098/item) in France in one year, with none meeting eco-modulation bonus criteria. Base fee: (50,000 × €0.0396) + (20,000 × €0.1098) = €1,980 + €2,196 = €4,176 total eco-contribution declared to Refashion for that period. If 10,000 of those T-shirts carried a GOTS certification (qualifying for the €0.03/item environmental certification bonus at >100,000 unit volume, or €0.30/item under 100,000 units), the brand would deduct that bonus from its final contribution — this is the calculation Atelier Compliance automates across your full catalogue rather than one SKU at a time.
04
The annual declaration process
A declaration is a reconciliation exercise: catalogue attributes, sales volumes, category mapping, and a defensible calculation trail.
- A declaration reconciles three data sources: your product catalogue (attributes like category, material composition, certifications), your sales volumes by SKU (from ERP or finance systems), and the category mapping that connects each SKU to its correct Refashion tariff code. You'll need clean exports from your ERP or PIM system covering units sold into the French market for the reporting year, plus any certification or durability documentation you want to claim eco-modulation bonuses against. Every SKU should map to exactly one Refashion category, and any manual overrides to that mapping should be recorded with a reason, since this is precisely what an auditor or Refashion itself will ask about if a declared total looks inconsistent with your catalogue size. The Refashion declaration window for the 2026 cycle (covering 2025 sales) runs from 14 January to 28 February, with payment due by 31 March — missing this deadline risks default surcharges and, for repeated failures, escalation toward the €30,000 non-registration-level penalty.
05
Labelling and consumer information
Sorting instructions and product information obligations sit alongside the financial contribution.
- Alongside the financial contribution, French law requires sorting instructions (the Triman logo and accompanying sorting guidance) on nearly all clothing, footwear, and household linen sold in France, telling consumers how to dispose of or recycle the item. Since October 2025, brands must also prepare for environmental characteristics disclosure — France's Environmental Cost framework — under which any third party, including retailers, NGOs, or comparison platforms, may publish a brand's environmental score from October 2026 onward, using conservative default assumptions if the brand hasn't published its own data first. Labelling breaches — missing Triman marking, incorrect sorting information, or absent environmental disclosures — can attract penalties of up to €15,000 per infringement, assessed separately from the eco-fee itself.
06
Beyond France: EU and UK direction of travel
Textile EPR is spreading across member states, with the Digital Product Passport and EUDR arriving alongside it.
- France was the sole EU country with mandatory textile EPR for years, but the EU's own Textile EPR Directive is expected to reach final adoption in 2026, after which producers get a three-month window to register in each applicable member state — meaning brands active across Europe will soon face multiple, country-specific registration and reporting obligations rather than just France's. The UK has signalled interest in a similar framework for textiles but has not yet legislated mandatory EPR for the sector as of 2026. This is exactly why a scheme-agnostic data model matters now: brands building their reporting process around one country's tariff codes today will need to re-architect it when a second and third scheme arrive, whereas a system that treats "scheme" as a first-class, swappable object can absorb new markets without touching existing reporting history.
07
Building a repeatable operating model
Most brands fail on process, not interpretation. The fix is versioned rules, immutable evidence, and a single reviewed workflow.
- Most compliance failures in this space come from process breakdown, not misunderstanding the rules — a spreadsheet with no version history, a mapping decision nobody documented, a fee calculation nobody can reproduce six months later. A repeatable operating model typically assigns clear ownership across four roles: a compliance owner who tracks deadlines and regulatory changes, a finance owner who reconciles declared fees against budget, a product-data owner who maintains accurate SKU-to-category mappings, and where needed, an external advisor for edge cases like eco-modulation certification. An evidence pack an inspector will accept typically includes the raw sales data, the category mapping with any overrides explained, the specific fee ruleset version applied, and a timestamped approval trail showing who signed off before submission. When migrating off spreadsheets, load your historical declarations as read-only reference data rather than trying to force old records into the new system's live workflow — this preserves your reporting history for audits that look back multiple years while letting your new declarations run cleanly through the versioned process going forward.
Want this workflow running, not documented?
Atelier Compliance runs the declaration cycle end to end: import, category mapping, fee calculation, approval, and an evidence pack you can hand to an auditor. Plans typically at £49/month.