2 Nov 2026
Broad country baseline: 6 Oct 2026.
Selected final checks: 17 Oct 2026.
Latest targeted review: 2 Nov 2026 (see coverage below).
Published changes & implementation milestones
The dates behind the intelligence.
Scheduled review: Monday, 08:00 Europe/Madrid. The change log records published changes; research dates show what has actually been reviewed.
Monday · 08:00
Europe/Madrid. Linked to the existing weekly regulatory review. Next scheduled review: 9 Nov 2026.
A schedule is not evidence of a completed update. Material changes are published with sources and a dated history.
Completed review log.
| Review date | Countries checked | Findings | Coverage limits | Evidence |
|---|---|---|---|---|
| 2 Nov 2026 | Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland, United Kingdom | Directed review of the EU framework and all 30 jurisdictions. Twenty-seven national source sets were directly retrieved. No new operating country, authorisation or ordinary fee was verified. France's final 20 October order and its 22 October amended operational date were added while preserving the separate September legal baseline, the withdrawn TRIS history and unresolved billing detail. RE-VISTE and GERESCAL remain a pilot and a constituted organisation, not proof of final compulsory-sector authorisation. | Partial thematic review, not 30 complete national legal, licence and tariff audits. Finland and Ireland returned HTTP 403 and Latvia timed out; their earlier country review dates were retained. Several sources are planning pages or historic instruments and cannot prove absence of duties. No complete 2027 provider-tariff audit, national gazette sweep or current licence audit was completed. France's ordinary 2026 fee guide was not changed and Refashion billing detail for the commercial-practice penalty remains a separate verification point. | S002 ↗, S004 ↗, S005 ↗, S137 ↗, S010 ↗, S013 ↗, S016 ↗, S019 ↗, S138 ↗, S025 ↗, S028 ↗, S130 ↗, S141 ↗, S139 ↗, S040 ↗, S126 ↗, S047 ↗, S049 ↗, S055 ↗, S059 ↗, S062 ↗, S065 ↗, S142 ↗, S099 ↗, S073 ↗, S077 ↗, S079 ↗, S082 ↗, S085 ↗, S116 ↗, S128 ↗, S129 ↗, S093 ↗, S103 ↗, S117 ↗ |
| 26 Oct 2026 | Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland, United Kingdom | Directed source review across all 30 jurisdictions and the EU framework. No new operating country, authorisation or fee was verified. Recorded withdrawn French TRIS notification 2026/0559/FR without changing the effective French regime; RE-VISTE and GERESCAL remain initiatives/organisations rather than proof of final compulsory-sector authorisation. | Partial thematic review, not 30 complete national legal, licence and tariff audits. Finland returned a government-service outage, Ireland returned HTTP 403 and Latvia timed out; their prior country dates were retained. Several sources are planning pages or historic instruments and cannot establish absence of duties. EUR-Lex anti-robot restrictions persisted. No 2027 French fee guide, complete provider-tariff audit or all national gazette searches were completed. | S002 ↗, S004 ↗, S005 ↗, S137 ↗, S010 ↗, S013 ↗, S016 ↗, S019 ↗, S138 ↗, S025 ↗, S028 ↗, S130 ↗, S140 ↗, S139 ↗, S040 ↗, S126 ↗, S047 ↗, S049 ↗, S055 ↗, S059 ↗, S062 ↗, S065 ↗, S068 ↗, S099 ↗, S073 ↗, S077 ↗, S079 ↗, S082 ↗, S085 ↗, S116 ↗, S128 ↗, S129 ↗, S093 ↗, S103 ↗, S117 ↗ |
| 19 Oct 2026 | Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland, United Kingdom | Directed source checks across all 30 jurisdictions and the EU framework; existing Hungarian footwear scope corrected; Hungarian and French filing milestones, Swedish consultation, Italian parliamentary step, Lithuanian proposal, Norwegian proposed start, Belgian provisional scope and Spanish organisation evidence expanded. No new country classified as operational; fees were not changed. | Partial thematic review, not 30 complete national legal/licence/tariff audits. Full baseline dates and dated downloads retained. Retrieval restrictions affect EUR-Lex, Hungarian annual fee instrument, Légifrance, Spain TRIS/MITECO, FI/IE, historic CCT URL, PT PDF and WRAP. Latvian 2026 RAS price and individual approvals not revalidated; OVAM/Polish secondary deadline conflicts not substituted for primary law. Direct re-audit of Swedish guidance S094 ↗ was limited; government consultation S132 ↗ read directly. | S005 ↗, S008 ↗, S137 ↗, S010 ↗, S013 ↗, S016 ↗, S019 ↗, S024 ↗, S138 ↗, S025 ↗, S028 ↗, S033 ↗, S034 ↗, S122 ↗, S123 ↗, S124 ↗, S130 ↗, S037 ↗, S139 ↗, S040 ↗, S126 ↗, S045 ↗, S046 ↗, S047 ↗, S049 ↗, S051 ↗, S133 ↗, S134 ↗, S054 ↗, S055 ↗, S057 ↗, S058 ↗, S059 ↗, S135 ↗, S062 ↗, S065 ↗, S068 ↗, S070 ↗, S113 ↗, S127 ↗, S131 ↗, S099 ↗, S136 ↗, S073 ↗, S077 ↗, S079 ↗, S082 ↗, S085 ↗, S091 ↗, S116 ↗, S120 ↗, S128 ↗, S129 ↗, S093 ↗, S094 ↗, S132 ↗, S103 ↗, S105 ↗, S117 ↗, S096 ↗, S001 ↗, S032 ↗, S043 ↗, S044 ↗, S071 ↗, S088 ↗, S090 ↗, S109 ↗, S121 ↗, S125 ↗, S002 ↗, S003 ↗ |
Published change log.
Legal implementation
Final French commercial-practice penalty order added
Underlying event / legal date: 21 Oct 2026The 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 the 2026–2030 per-item schedule for listed apparel. The earlier September legal baseline, the withdrawn TRIS file and Refashion's operating instructions remain separate records; ordinary 2026 eco-fees are unchanged.
S141 ↗ S130 ↗ S122 ↗ S123 ↗ S124 ↗ S140 ↗Coverage expansion
Current Netherlands authority evidence added
The ILT authority page now supports the operating date, covered textile categories, notification and annual-reporting route, three producer organisations and the 55% combined 2026 target. It does not add footwear or establish provider tariffs.
S142 ↗ S068 ↗ S070 ↗ S113 ↗ S127 ↗Procedural evidence
Withdrawn French TRIS draft recorded without changing operative law
Underlying event / legal date: 16 Oct 2026TRIS notification 2026/0559/FR proposed replacing the 24 August 2026 order and setting a commercial-practice penalty schedule, but the official file is marked withdrawn. It is preserved as procedural history and is not presented as an adopted order, a tariff change or operating instruction.
S140 ↗ S122 ↗ S123 ↗ S124 ↗Coverage correction
Existing Hungarian footwear scope and Q3 filing deadline clarified
The current national annex explicitly includes CN Chapter 64 footwear except parts. Article 27(1) makes the Q3 2026 authority return due on 20 October 2026 (calendar inference); foreign e-commerce representation is recorded separately. This is not a new October law. The 2026 annual rate remains inherited because its instrument could not be reopened.
S126 ↗ S045 ↗ S044 ↗Coverage expansion
National proposals and parliamentary milestones remain conditional
Added Sweden’s 25 September consultation (closes 30 December), Italy’s 1 October parliamentary step, Lithuania’s autumn legislative programme and Norway’s post-consultation budget proposal. These do not establish approved schemes, zero fees or operational commencement.
S132 ↗ S133 ↗ S134 ↗ S135 ↗ S136 ↗Evidence update
Operational calendar and scheme evidence refreshed without changing fees
Added Refashion’s 2026 evidence / 2027 settlement calendar, current CCT contributions and Spanish organisation/pilot evidence. France’s legal commercial-practice penalty and its still-unresolved operating instructions stay separate. RE-VISTE and GERESCAL remain distinguished from final compulsory-sector authorisation.
S130 ↗ S127 ↗ S128 ↗ S129 ↗ S122 ↗ S124 ↗Authority guidance
Portugal briefing is now a completed guidance event
Underlying event / legal date: 8 Oct 2026APA held its textile EPR briefing on 8 October and published the presentation. This is preparation guidance, not evidence of a final tariff or a licensed operating textile scheme.
S077 ↗ S121 ↗Pilot evidence
GERESCAL added to the Spanish scheme landscape
Underlying event / legal date: 15 Jun 2026First-party evidence describes an in-store footwear collection pilot with participating brands. Constituted activity is shown separately from final compulsory-sector authorisation.
S120 ↗Legal implementation
French penalty: commencement and implementation are separate
Underlying event / legal date: 1 Sept 2026The commercial-practice penalty is legally effective. ADEME notes that detailed application and identification arrangements still require clarification by Refashion. Household linen and footwear are outside this particular penalty.
S122 ↗ S123 ↗ S124 ↗National & European milestones
Adoption, operation and reporting are separate events.
| Date | Jurisdiction | Milestone | Legal certainty / qualification |
|---|---|---|---|
| 1 January 2025 | EU | Separate textile collection requirement | Existing requirement; not proof of operating EPR. |
| 16 October 2025 | EU | Directive 2025/1892 entered into force | Enacted. |
| 1 January 2026 | Finland / Hungary | New mainland authority / 2026 statutory textile tariff | Current administrative/rate changes. |
| 27 March 2026 | Germany | Official design paper issued | Preparatory; consultation deadline passed. |
| 15 April 2026 | Luxembourg | Revised waste plan approved | Policy/plan; EPR implementation still required. |
| 7 May–21 August 2026 | Norway | Regulatory consultation | Completed; adoption not verified. |
| 27 May 2026 | Spain | TRIS notification | Draft; final BOE text not verified. |
| 8 July / 1 September 2026 | France | New law / commercial-practice penalties | Enacted law and legal commencement; scheme implementation details still require confirmation. S122 ↗. |
| 19 July 2026 | EU relevant enterprises | Unsold apparel/footwear destruction ban | Related ESPR duty; size/exemption checks. |
| 23 July 2026 | Italy | Conferenza Unificata opinion recorded | Procedure, not final entry into force. |
| 27 August 2026 | Sweden | Interim enabling-law proposals | Proposal submitted. |
| 9 September 2026 | Lithuania | Autumn textile-EPR legislative programme announced | Proposal, not final adoption. S135 ↗. |
| 25 September–30 December 2026 | Sweden | Government consultation KN2026/01849 | Interim enabling-law proposal; not operational scheme approval. S132 ↗. |
| 25 September 2026 | Norway | Budget proposal retains proposed 1 January 2027 start | Not enacted commencement; potential later tax is separate. S136 ↗. |
| 28 September 2026 | Spain | Extended TRIS standstill end | Does not equal adoption. |
| 1 October 2026 | Italy | Government accepts reformulated order of the day 9/3118/7 | Parliamentary milestone, not final decree or register opening. S133 ↗, S134 ↗. |
| 8 October 2026 | Portugal | APA textile EPR briefing held; presentation published | Completed guidance event, not final sector-law adoption. S121 ↗. |
| 20 October 2026 | Hungary | Q3 2026 authority return | Calendar inference from Article 27(1); quarterly return due day 20. S126 ↗. |
| 13 November 2026 | Sweden | Final agency report due | Mandated report, not a fee start. |
| Before 30 November 2026 | France | 2026 eco-modulation evidence submission | Published programme calendar; separate commercial-practice malus instructions unresolved. S130 ↗. |
| 1 January 2027 | Norway | Proposed EPR entry | Conditional on final Norwegian adoption. |
| Q1 / Q2 2027 | France | Eco-modulation quantities / verified settlement | Quantities in Q1; bonus payment and penalty invoicing after verification in Q2. S130 ↗. |
| Q1 2027 | Switzerland | Planned circular-textile roadmap workshop | Voluntary initiative milestone. |
| 17 June 2027 | EU-27 | Transposition deadline | Member State legal deadline. |
| 17 April 2028 | EU-27 | Latest scheme establishment | Member State deadline; earlier rules can apply. |
| 17 April 2029 | EU specified micro-enterprises | Extended application deadline | Outside 24-month horizon; not blanket exemption from existing national rules. |
Historical and future milestones are retained together. A proposed start date remains proposed until final adoption is evidenced. Source packs are linked from the corresponding country dossiers.
Country coverage & review dates.
| Country | Broad research baseline | Latest targeted check | Next evidence trigger |
|---|---|---|---|
| Austria | 6 Oct 2026 | 2 Nov 2026 | Final national law, register, scheme authorisation and tariff |
| Belgium | 6 Oct 2026 | 2 Nov 2026 | Final national law, register, scheme authorisation and tariff |
| Bulgaria | 6 Oct 2026 | 2 Nov 2026 | Final national law, register, scheme authorisation and tariff |
| Croatia | 6 Oct 2026 | 2 Nov 2026 | Final national law, register, scheme authorisation and tariff |
| Cyprus | 6 Oct 2026 | 2 Nov 2026 | Final national law, register, scheme authorisation and tariff |
| Czechia | 6 Oct 2026 | 2 Nov 2026 | Final national law, register, scheme authorisation and tariff |
| Denmark | 6 Oct 2026 | 2 Nov 2026 | Final national law, register, scheme authorisation and tariff |
| Estonia | 6 Oct 2026 | 2 Nov 2026 | Final national law, register, scheme authorisation and tariff |
| Finland | 6 Oct 2026 | Not a complete new country audit | Final national law, register, scheme authorisation and tariff |
| France | 6 Oct 2026 | 2 Nov 2026 | 2026 eco-modulation evidence before 30 November 2026; Refashion identification/billing detail and 2027 campaign |
| Germany | 6 Oct 2026 | 2 Nov 2026 | Legislative proposal following ministry design process |
| Greece | 6 Oct 2026 | 2 Nov 2026 | Final national law, register, scheme authorisation and tariff |
| Hungary | 6 Oct 2026 | 2 Nov 2026 | Q3 2026 authority reporting · 20 October 2026; next annual fee instrument |
| Ireland | 6 Oct 2026 | Not a complete new country audit | Final national law, register, scheme authorisation and tariff |
| Italy | 6 Oct 2026 | 2 Nov 2026 | Final decree in Gazzetta Ufficiale and system approvals |
| Latvia | 6 Oct 2026 | Not a complete new country audit | Current exemption approval, contract and reporting reconciliation |
| Lithuania | 6 Oct 2026 | 2 Nov 2026 | Final national law, register, scheme authorisation and tariff |
| Luxembourg | 6 Oct 2026 | 2 Nov 2026 | Final national law, register, scheme authorisation and tariff |
| Malta | 6 Oct 2026 | 2 Nov 2026 | Final national law, register, scheme authorisation and tariff |
| Netherlands | 6 Oct 2026 | 2 Nov 2026 | 2026 performance reporting and 2027 filing calendar |
| Norway | 6 Oct 2026 | 2 Nov 2026 | Post-consultation decision on proposed January 2027 start |
| Poland | 6 Oct 2026 | 2 Nov 2026 | Final national law, register, scheme authorisation and tariff |
| Portugal | 6 Oct 2026 | 2 Nov 2026 | National legislation and licensing after APA 8 October briefing |
| Romania | 6 Oct 2026 | 2 Nov 2026 | Final national law, register, scheme authorisation and tariff |
| Slovakia | 6 Oct 2026 | 2 Nov 2026 | Final national law, register, scheme authorisation and tariff |
| Slovenia | 6 Oct 2026 | 2 Nov 2026 | Final national law, register, scheme authorisation and tariff |
| Spain | 6 Oct 2026 | 2 Nov 2026 | Gazetted decree, regional authorisations and producer register |
| Sweden | 6 Oct 2026 | 2 Nov 2026 | Final agency report · 13 November 2026; consultation closes · 30 December 2026 |
| Switzerland | 6 Oct 2026 | 2 Nov 2026 | Final national law, register, scheme authorisation and tariff |
| United Kingdom | 6 Oct 2026 | 2 Nov 2026 | Final national law, register, scheme authorisation and tariff |