The compliance stack: textile EPR, EUDR, and DPP explained

French textile EPR — Refashion

France is the reference case: the first textile EPR scheme in Europe, running since 2007 through a single approved eco-organisme, Refashion. It is the mature end-state worth modelling closely, because it shows what compliance done properly looks like operationally.

Who is obligated

Any business first placing new clothing, footwear, or household linen (TLC) on the French market — maker or importer, online sellers included — from the first unit sold. There is no volume threshold.

Registration

Producers join Refashion via its member Extranet, which enrols them in SYDEREP (ADEME's national register) and issues an IDU (unique identifier), one per filière. The IDU must appear on terms of sale and on the brand's website.

Declaration deadline

28 February each year, covering volumes placed on market in the prior year. Refashion then files the consolidated declaration to ADEME by 30 April.

Payment deadline

31 March, with late-payment penalties after that date.

Fee structure

Per-piece éco-contribution, set annually and eco-modulated by durability and recyclability. 2026 simplified rates: approximately €0.58 per clothing item, €0.65 per household linen item, €0.64 per footwear item — available only below 5,000 items per year. The detailed regime uses granular per-category rates, for example €0.032 for an adult T-shirt and €0.158 for a coat.

Non-EU brands

A France-established representative (mandataire) is compulsory under Article L.541-10-9-1 of the French Environment Code, created by Law No. 2026-602 of 8 July 2026 — closing a gap left by a 2023 Conseil d'État annulment.

Penalties

Administrative fines under Article L541-9-5: up to €7,500 per company for non-compliance, and a flat €30,000 for failing to register at all. Marketplaces are also liable for non-compliant sellers.

Labelling

Triman / Infotri sorting-instruction logo requirements run alongside the eco-fee obligation.

EUDR — EU Deforestation Regulation (EU 2023/1115)

The second live regime, and the sharper near-term lever: the deadline is closer than the EU textile EPR mandate and enforcement is civil and criminal, not only administrative.

• Applies to operators and traders placing relevant commodities on the EU market — leather, natural rubber, and, critically for fashion, cotton and related deforestation-risk materials — requiring due-diligence statements and supply-chain traceability.
• Compliance deadline confirmed at 30 December 2026 for large and medium operators, following a second Commission postponement finalised via Regulation (EU) 2025/2650, adopted 19 December 2025.
• Micro and small operators have until 30 June 2027.
• The European Commission's implementation review, published 4 May 2026, confirmed these dates hold. No further postponement is currently expected.
• From 30 December 2026, large and medium operators must have a Due Diligence Statement filed for every in-scope shipment.
• Most brands of 100–500 FTE and £30–150M revenue fall inside the large or medium operator definition, and therefore face the December 2026 date.

EU-level textile EPR mandate — Directive (EU) 2025/1892

The regulatory backstop that makes the French and German schemes non-optional across the whole EU eventually.

• Directive (EU) 2025/1892 amends the Waste Framework Directive and came into force 16 October 2025, introducing mandatory EPR for textiles and footwear EU-wide for the first time.
• Member states must transpose the directive into national law by 17 June 2027.
• Working national EPR schemes must be operational by 17 April 2028.
• Practically: France and soon Germany are the early movers; the other 25 member states follow on a multi-year runway.

German textile EPR

Germany has no textile EPR law yet. It is actively drafting one, with stakeholder consultation that closed on 24 April 2026.

• There is no concrete German fee schedule or reporting portal to comply with today.
• A scheme-agnostic data model matters here: the same catalogue and volume data should mirror the German rules once they crystallise, without re-platforming.

Digital Product Passport / ESPR

The Ecodesign for Sustainable Products Regulation (ESPR) will require a Digital Product Passport for textiles.

• The textile-specific delegated act is expected late 2026 or early 2027.
• Mandatory compliance is likely mid-2028.
• Correctly treated as a later-stage expansion layer, not part of a first reporting cycle.

UK textile EPR

As of June 2026 no mandatory UK textile EPR scheme exists and no legislation has passed.

• January 2026: WRAP published a ten-point industry Blueprint for a UK Textiles EPR scheme via the UK Textiles Pact, proposing a single non-profit PRO, eco-modulated fees, and alignment with EU definitions.
• Industry estimates the cost to UK local authorities of continuing without EPR at £200M per year — pressure toward eventual legislation.
• There is still no PRO structure, fee schedule, or timeline.
• A purely UK-domestic brand has zero current mandatory obligation, but the Blueprint's EU-alignment language means an EU-first data architecture should extend naturally once a mandate lands.