Country dossier / EU-27
Textile EPR in France
Operational since 2007; major 2026 amendment
Broad research: 6 Oct 2026 · Selected verification: 2 Nov 2026. Source review coverage is stated below.
The final Order of 20 October 2026 was published on 21 October and entered into force on 22 October. It fixes the D ≤ 0.8 formula and per-item schedule for listed apparel; Refashion states that the amended module applies from 22 October. The earlier September legal baseline, the withdrawn TRIS draft and current operating instructions remain separate records. Limit: no complete 2027 ordinary-fee guide or detailed company-identification and billing audit.
Organisations & financing route
Refashion
Constitution & legal approval
Approved operational textile PRO
Implementation timing
Operating since 2007
Next evidence trigger
2026 eco-modulation evidence before 30 November 2026; Refashion identification/billing detail and 2027 campaign
Competent authority
Ministry responsible for ecological transition; ADEME (SYDEREP/IDU); Refashion operates the approved collective TLC scheme.
Legal basis
Environment Code L.541-10-1(11); Law 2026-602 of 8 July 2026; Order of 23 November 2022 specifications as amended by the final Order of 20 October 2026 (NOR TECP2627746A), published 21 October and in force 22 October. The final order replaces subsection 2.2.3.1 and is kept separate from the earlier 24 August order and the withdrawn TRIS draft.
Product scope
Current TLC scope covers consumer clothing, footwear and household linen under French classifications. Check workwear/professional products individually; do not extrapolate either the EU future Annex or another French EPR stream to all carpets, mattresses or leather goods.
Fees & financial basis
Detailed 2026 declaration schedule: €0.0190–€0.2175 per declared item/category (unit, pair or set under nomenclature). Simplified schedule and administrative charges differ. New qualifying commercial-practice penalties are additional: see section 4, not the ordinary fee range.
Eco-modulation
Durability, specified finished-product labels and eligible recycled inputs receive conditional bonuses; recyclability penalties also exist. The commercial-practice penalty has an earlier legal baseline from 1 September 2026, while the final amended schedule entered into force on 22 October and Refashion applies that module from 22 October. It covers only the listed apparel products with D ≤ 0.8; footwear and household linen are excluded from this particular penalty. The final 2026–2027 amounts run from €0.50 to €12 per item, rising by category through 2030, and D weights assortment breadth (G) and repair incentive (R) equally. Penalised products cannot receive bonuses. ADEME still identifies concrete company-identification and billing instructions as an operational follow-up point. Sources: S122 ↗–S124 ↗, S130 ↗ and S141 ↗.
Targets & denominators
Current PRO specifications retain collection and treatment targets. Exact percentages and denominators, including separate non-reused material and synthetic-fibre targets, are set out in section 4 to avoid confusing collection with recycling.
Registration & reporting
Register for the relevant French IDU and maintain Refashion category-level units and weight evidence, supporting test/certification records and recycled-material traceability. The 2026 declaration campaign concerned 2025 POM, with January–February declaration and March payment dates; obtain the new campaign calendar for 2026 POM. Refashion's published 2026 eco-modulation process requires reference registration and evidence before 30 November 2026, quantity declarations in Q1 2027 and controlled bonus payment or penalty invoicing in Q2 2027. Treat that operating process separately from the order's legal effect and continue to check the company-identification and detailed billing instructions. Sources: S130 ↗ and S141 ↗.
Organisations & approval status
Refashion: approved operational collective textile/footwear/household-linen organisation. Its approved remit is stream-specific. General waste collectors or furniture PROs should not be substituted.
Next milestones
Assess exposure under the final 20 October schedule without erasing the earlier September legal baseline. Obtain the current Refashion identification and billing instructions and check the July law's French representative provision for foreign producers. Prepare the 2027 declaration and eco-modulation evidence; verify the 2027 ordinary fee guide when issued.
Practical risks & controls
Risk: budgeting only the ordinary fee, claiming bonuses on penalised products, or using old certification/test validity rules. Mitigation: evaluate D by listed product type, preserve category aggregation and audit evidence, check representative obligations, and obtain a current campaign-specific reconciliation.
Sources and verification dates
S031 · France: Law 2026-602 of 8 July 2026, Article 5 ↗ Access limited · 19 Oct 2026S032 · France: consolidated textile PRO specifications, effective 29 August 2026 ↗ Access limited · 19 Oct 2026S033 · Refashion: 2026 eco-fee guide ↗ Reopened 19 Oct 2026S034 · Refashion: 2026 eco-modulation guide (English) ↗ Reopened 19 Oct 2026S035 · Quels sont les documents à fournir pour les éco ... ↗ Base record 6 Oct 2026S036 · Notification Detail | TRIS - European Commission ↗ Base record 6 Oct 2026S109 · France: Order of 24 August 2026 — final commercial-practice penalty mechanism ↗ Access limited · 17 Oct 2026S122 · ADEME: ultra-fast-fashion penalty — legal effect and implementation details ↗ Reopened 19 Oct 2026S123 · France: ministry methodology for the commercial-practice penalty, 28 August 2026 ↗ Reopened 19 Oct 2026S124 · ADEME: penalty scope and threshold at or below 0.8 ↗ Reopened 19 Oct 2026S130 · Refashion: 2026 eco-modulation evidence and campaign timetable ↗ Reopened 2 Nov 2026S140 · France: withdrawn TRIS draft 2026/0559/FR on the commercial-practice penalty ↗ Reopened 2 Nov 2026S141 · France: final Order of 20 October 2026 on the commercial-practice penalty ↗ Reopened 2 Nov 2026Common EU framework
A constituted organisation, a pilot and an authorised compulsory system have different legal effects. Unresolved scope, approval, tariff and filing questions remain visible in this dossier. Source-page reopening is not a complete current licence audit.