What is France EPR Textile

France was the first country in the world to introduce mandatory Extended Producer Responsibility for textiles. The scheme has been in force since 1 January 2007 under Article L.541-10-3 of the French Environmental Code (Code de l'environnement). It was substantially expanded by Law 2020-105 of 10 February 2020 — the AGEC law (loi anti-gaspillage pour une économie circulaire) — and operates under a renewed 2023–2028 cahier des charges (specifications).

The scheme — known as the TLC filière (Textiles, Linge de maison, Chaussures) — covers clothing, household linen, and footwear. It requires all producers placing these products on the French market to finance the collection, sorting, reuse, and recycling of end-of-life textiles. The legal responsibility remains with the producer regardless of whether obligations are fulfilled individually or through a Producer Responsibility Organisation (PRO).

ADEME (Agence de la transition écologique) and the Ministry for Ecological Transition (DGPR) oversee the scheme. Day-to-day management is handled by the sole approved PRO, Refashion (formerly Eco-TLC), which as of 2025 has over 14,000 registered members.

Does This Apply to E-Commerce & Online Sales

Yes. The French EPR scheme applies to any company that places TLC products on the French market for the first time, including foreign brands selling directly to French consumers via e-commerce, marketplace platforms, or distance selling.

Under Article R.541-87 of the Environmental Code, a "producer" is anyone who places a regulated product on the French market for the first time. This definition explicitly captures importers, foreign brand owners, and online sellers — including those with no physical establishment in France.

Online marketplaces do not automatically discharge the EPR obligation of third-party sellers listing products through their platforms. Each brand or seller placing products on the French market under their own name or trademark must hold their own registration and Unique Identification Number (UIN). Producers must also maintain a register of their third-party resellers, including those resellers' UINs, and declare volumes placed on the market by resellers who do not hold their own UIN.

Who is the "Producer" under France EPR?

Under the French Environmental Code, a producer (metteur sur le marché) is any company that, in a professional capacity, places TLC products on the French market for the first time. This covers:

1. French manufacturers producing and selling clothing, footwear, or household linen domestically.
2. Importers bringing TLC products into France for the first time under their own name.
3. Private label owners whose brand name appears on products manufactured outside France.
4. Foreign brands selling directly to French consumers via e-commerce or distance selling, with no French establishment.
5. Distributors and retailers who import products under their own brand or resell products from suppliers who do not hold a UIN.

Where a foreign brand sells through a French-established importer or distributor who assumes the role of first placer on the market, that entity becomes the producer. Foreign brands selling directly retain the obligation themselves and must either register directly with Refashion or appoint an authorized representative in France.

Who Must Register for EPR Textiles in France

All producers placing TLC products on the French market must register with an approved PRO — in practice, Refashion — and obtain a Unique Identification Number (UIN). This obligation has applied since 1 January 2022 under the AGEC law.

The UIN must appear on invoices, websites, and general terms and conditions. It is issued by ADEME after registration with Refashion is validated and the regularisation procedure — registration, declaration, and initial payment — is completed.

Upon joining, producers must regularise not only the current year but also the two preceding declaration years. For example, a company joining in 2025 must declare volumes for 2025, 2024, and 2023.

Producers may alternatively establish an individual compliance system approved by the Ministry for Ecological Transition, but this is complex and used by fewer than 5% of the market.

France EPR Textile Registration Threshold

The AGEC law does not establish a minimum volume or turnover threshold below which the EPR obligation does not apply. All producers placing TLC products on the French market are obligated, regardless of size.

However, a simplified flat fee is available for small producers: companies with annual revenues under €750,000 or selling fewer than 5,000 units per year may pay a flat annual contribution of €75 instead of calculating unit-by-unit fees. This simplification applies to the financial contribution only — registration, UIN, and reporting obligations still apply.

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Textiles Covered (and Excluded)

The TLC filière covers three product categories:

Clothing (Apparel) All consumer clothing and occupational/workwear placed on the French market, including outerwear, underwear, sportswear, and professional garments.

Footwear All footwear sold to households in France, regardless of material.

Household Linen Bed linen, table linen, toilet linen (towels), and kitchen linen.

The following are outside the current TLC scope:

• Bags, belts, and blankets — not covered under the TLC decree
• Curtains — not covered under TLC (covered separately under the furniture waste stream in some interpretations)
• Single-use sanitary textiles — covered under a separate EPR stream; CITEO was approved as the eco-organisation for this category in June 2025
• Second-hand and pre-owned textiles being resold without modification
• Custom-made items produced by self-employed tailors

Producer Responsibility Organization (PRO)

Refashion is the sole approved PRO for the TLC filière in France, accredited by the Ministry for Ecological Transition. It is a not-for-profit eco-organisation governed by a consortium of manufacturers and industry federations. As of 2025, Refashion has over 14,000 registered members and manages a national network of textile collection points — approximately one drop-off point per 1,400 inhabitants.

Refashion's resources are allocated across collection, sorting, and processing of used textiles and footwear (29%); incentives for sustainable design (20%); repair and reuse programmes (23%); and research and development on sorting and recycling technologies (5%).

Producers may alternatively fulfil their obligations by setting up an individual collection system approved by the Ministry for Ecological Transition, but this requires meeting stringent technical and operational requirements and is not a practical route for most companies.

EPR Registration in France

The registration process with Refashion is as follows:

1. Create an account on the Refashion extranet (pro.refashion.fr) and complete the company profile.
2. Sign the membership contract with Refashion.
3. Pay the one-off joining fee.
4. Declare volumes placed on the French market for the current year and the two preceding declaration years (regularisation obligation).
5. Pay the eco-contributions corresponding to declared volumes.
6. Receive the UIN issued by ADEME, which must appear on all invoices, websites, and general terms and conditions.
7. Submit annual declarations covering volumes placed on the market for the previous calendar year, between 15 January and 28 February each year.

Authorized Representative

Foreign companies without a French legal establishment may appoint an authorized representative established in France to manage their Refashion registration and EPR obligations. The representative acts on behalf of the foreign producer and takes on the administrative obligations, but legal responsibility under the Environmental Code remains with the producer.

Authorized representatives are commonly used by non-EU brands, smaller foreign e-commerce sellers, and companies without French-speaking compliance staff. Compliance service providers operating in France offer this service.

Foreign companies selling through French-established distributors who act as first placer on the market may have those distributors assume the producer role — but this must be explicitly agreed and the distributor must hold a valid UIN for the products concerned.

What Data Must Be Reported

Producers must declare the following data to Refashion annually:

• Total number of units placed on the French market during the previous calendar year, broken down by product category (clothing, footwear, household linen) and by size category where applicable
• Material composition data relevant to eco-modulation, including recycled fibre content and recyclability characteristics
• Volumes placed on the market by third-party resellers who do not hold their own UIN — producers must maintain a register of these resellers including their names and quantities

Declarations are submitted via the Refashion extranet between 15 January and 28 February for the previous calendar year. For products eligible for eco-modulation bonuses, supporting documentation must be provided through the extranet to substantiate the claim.

First Reporting Period & EPR Reporting Deadlines

The French textile EPR scheme has been in force since 1 January 2007, with the UIN requirement mandatory since 1 January 2022. Companies joining now must regularise the current year plus the two preceding declaration years.

Key recurring deadlines:

• 15 January – 28 February: Annual declaration window for volumes placed on the market in the previous calendar year
• Q1 each year: Eco-contribution payment based on the previous year's declared volumes
• Late payment: Penalties apply as defined in the Refashion membership contract
• 2028: Collection rate target of 60% of volumes placed on the market

Labels & Marketing Claims

Triman Logo and Sorting Instructions (Info-tri) The Triman logo and consumer sorting instructions are mandatory on all TLC products sold in France, or on their packaging, or on the product's online page. This requirement has been in full force since early 2023. The specific formatting and content of sorting instructions are defined in Refashion's published guidelines. Products without compliant sorting information are non-compliant.

Fibre Composition Labelling All textile products sold in France must carry fibre composition labels under EU Regulation (EU) No 1007/2011. Labels must be in French.

Ban on Destruction of Unsold Goods The AGEC law prohibits the destruction of unsold non-food consumer goods, including clothing. Producers and distributors must donate, recycle, or reuse unsold stock. This applies to goods returned by consumers as well as unsold inventory.

Environmental Claims Environmental and sustainability claims are governed by the Unfair Commercial Practices Directive and French consumer law. The Empowering Consumers for the Green Transition Directive (2024/825/EU) must be transposed by March 2026, after which unsubstantiated environmental claims — including vague terms such as "eco-friendly" or "sustainable" — will be prohibited. France has also proposed an Eco-Score (Environmental Cost label) for textiles under its Climate and Resilience Law, voluntary from October 2025 with expanding scope from October 2026.

EPR Eco Fees & Eco-Modulation

Eco-contributions are calculated per unit and vary by product category, size, and eco-modulation criteria. Average fees are approximately €0.01 per garment, with a maximum of approximately €0.06 per item for products attracting penalties.

Small producer flat fee: Companies with revenues under €750,000 or selling fewer than 5,000 units may pay €75 per year as a simplified contribution.

Eco-modulation bonuses (reduced fees) apply to:

• Products incorporating at least 15% post-consumer recycled fibres — 50% discount on the standard tariff
• Products incorporating at least 30% pre-consumer recycled fibres — 25% discount on the standard tariff
• Products certified with recognised environmental labels accepted by Refashion (e.g. GOTS, Oeko-Tex Made in Green, European Ecolabel)
• Products assessed as durable under Refashion's technical criteria

Eco-modulation penalties (increased fees) apply to:

• Products containing metalloplastic fibres or electronic components that hinder recycling
• Products classified as fast fashion under applicable criteria

Eco-modulation is not automatic. Brands must declare eligible products through Refashion's declaration process and provide supporting documentation via the extranet.

Risks, Penalties & Common Mistakes

1. Operating without a UIN. The UIN has been mandatory since 1 January 2022. Selling TLC products in France without a valid UIN exposes companies to fines of up to €7,500 per unit of product concerned under Article L.541-9-5 of the Environmental Code. A fine of up to €30,000 applies for missing UIN on invoices and documentation.
2. Failing to regularise past years on joining. Companies joining Refashion must declare and pay eco-contributions for the current year plus the two preceding years. Failure to regularise is a compliance breach.
3. Missing the annual declaration deadline. Declarations must be submitted between 15 January and 28 February. Late declarations attract penalty interest as defined in the membership contract.
4. Missing Triman and sorting information on products. This is a current, enforceable requirement since 2023. Non-compliant labelling is actionable by market surveillance authorities.
5. Destroying unsold stock. The AGEC law bans destruction of unsold goods. Violations are subject to enforcement under French consumer and environmental law.
6. Claiming eco-modulation bonuses without documentation. Eco-modulation reductions require submitted supporting documentation. Undocumented claims are invalid and may result in recalculation of contributions owed.
7. Assuming marketplace membership covers individual sellers. Each seller placing products under their own name must hold a UIN. Marketplace membership does not discharge individual brand obligations.

What E-Commerce Sellers Should Do Now

1. Confirm whether your business places TLC products on the French market for the first time under your own name — including via direct e-commerce, marketplace channels, or through French distributors.
2. Register with Refashion (pro.refashion.fr) and obtain your UIN. Regularise the current year and the two preceding declaration years.
3. Display the UIN on all invoices, websites, and general terms and conditions.
4. Implement the Triman logo and sorting instructions on all products or their online product pages, in accordance with Refashion's published guidelines.
5. If your annual revenue is under €750,000 or you sell fewer than 5,000 units, confirm eligibility for the €75 flat fee simplified contribution.
6. Build product-level records for fibre composition and recycled content to support eco-modulation declarations where applicable.
7. Review the ban on destruction of unsold goods and confirm your returns and inventory management process complies with the AGEC law.
8. If you have no French establishment, identify and appoint an authorized representative in France to manage registration and compliance on your behalf.

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FAQ

Is the French textile EPR scheme mandatory for all brands selling in France?

• Yes. The scheme has been mandatory since 1 January 2007 and applies to all producers placing clothing, footwear, or household linen on the French market, regardless of company size or country of establishment. There is no volume or turnover threshold below which the obligation does not apply, though small producers may use a simplified €75 flat fee.

Do foreign brands selling online into France need to register?

• Yes. Foreign brands selling directly to French consumers via e-commerce are treated as producers under the French Environmental Code and must register with Refashion, obtain a UIN, and comply with all declaration and contribution obligations. They may appoint a French-established authorized representative to manage this on their behalf.

What is the UIN and why does it matter?

• The Unique Identification Number (UIN) is issued by ADEME after registration with Refashion and payment of eco-contributions. It must appear on all invoices, websites, and general terms and conditions. Operating without a UIN exposes companies to fines of up to €7,500 per unit of product concerned. It is effectively the licence to sell TLC products in France.

What labelling is required on products sold in France?

• The Triman logo and consumer sorting instructions are mandatory on all TLC products or their packaging or online product pages, in force since early 2023. Fibre composition labels must be in French under EU Regulation 1007/2011. From September 2026, unsubstantiated environmental claims will be prohibited under the transposed Green Claims Directive.

What happens if a company has not registered but has been selling in France for several years?

• Companies that join Refashion must regularise the current year and the two preceding declaration years. They must declare volumes placed on the market for those years and pay the corresponding eco-contributions. Fines for past non-compliance — up to €7,500 per unit — remain a risk under Article L.541-9-5 of the Environmental Code.