Textile EPR in France for non-EU sellers (Refashion, filière TLC)

If you sell new clothing, footwear or household linen to buyers in France, from any country, you name a representative in France by written mandate and join Refashion, the only approved textile eco-organisme. You declare your units each year and pay a fee per item, and ADEME issues your IDU. The representative duty has applied since 10 July 2026. The 2026 law adds ultra-fast fashion rules, one of them a penalty on the fee from 1 September 2026. Its advertising and influencer bans and its information duty reach only ultra-fast-fashion products as defined, so they start from 1 January 2027 at the earliest.

The EU rule, and who counts as a producer, is in textile EPR in the EU. This page is only what France adds. The other French rules are on the France page.

Do this, in this order

1. Check your products against the stream. It covers new clothing, footwear and household linen for private individuals, and new textile products for the home, except furnishing elements (L. 541-10-1, 11°). ADEME excludes garments made of 100% leather or natural fur. Refashion also excludes products for exclusively professional use and upcycled products made entirely of second-hand materials. Furniture and decoration textiles are the furniture stream.
2. Name your representative in France, by written mandate (L. 541-10-9-1). The next section has the law.
3. Register with Refashion on its member Extranet and sign the contract (Refashion).
4. Declare the units you placed on the market in the previous year, and pay the invoices. The dates are in the table below.
5. Receive the IDU. ADEME generates it once you are registered, up to date with the fee and compliant (Refashion). Give it to each marketplace. What to type in each registration field, and where the IDU must appear, is on the IDU page.
6. Put the Triman logo and the sorting instructions on the product. Refashion states they have been compulsory on clothing, household linen and footwear placed on the French market since 1 February 2023 (Refashion). The fine for leaving them off is under Triman.
7. If you sell online, show where the product is made, next to the price. It is rule 4 in the 2026 section below.

The representative duty has applied since 10 July 2026

A person not established in France that is subject to EPR appoints, by written mandate, a person or company established in France as representative. The representative takes over the EPR duties it accepts in the mandate (article L. 541-10-9-1, inserted by article 5 of loi no. 2026-602 of 8 July 2026). The text names no EU or non-EU distinction, so a seller in another EU country is bound too. The duty counts as met for products whose EPR duties an operator established in France, named in article L. 541-10-9, already fulfils. That article covers the online platforms and marketplaces that facilitate distance sales.

The law was published in the Journal officiel no. 159 of 9 July 2026 (Sénat). Article 5 dates only another of its points, 1 September 2026, and the new article cites no decree. A law with no date applies from the day after its publication (article 1 of the Civil Code). The full detail of the mandate, with the other eco-organismes, is on the packaging page. The EU side of the role is in authorised representative for EPR.

Refashion is the only eco-organisme

ADEME lists one approved eco-organisme for the stream, Refashion (formerly Eco-TLC), accredited from 1 January 2023 to 31 December 2028. Refashion describes two ways to comply: set up your own system, approved by joint order of the ministries, or join the eco-organisme and pay a contribution (Refashion). Refashion says that, as an online seller or marketplace, you are covered “even if based abroad” (Refashion). The law puts the duty on anyone who makes, handles, sells or imports the products (L. 541-10).

No volume is too small. Article L. 541-10-13 has every producer subject to EPR register and receive an IDU, and sets no exemption below a quantity.

What it costs

You pay Refashion’s eco-fee. It is not set by law. For 2026, Refashion’s call for funds is your estimated 2026 volumes times its per-item scale, plus administrative fees of EUR 30 and the ADEME fee. Later, the balance is adjusted on the volumes you actually placed on the market (Refashion eco-fee guide 2026 and Refashion). The scales are Refashion’s own documents, not law, and change each year.

The simplified declaration is open to a marketer that declares no product eligible for eco-modulation and fewer than 5,000 items a year. The rate is higher because it covers the missing detail. The scale includes the repair and reuse funds.

Refashion’s 2026 eco-modulations are three bonuses (durability, environmental certification, recycled raw materials) and a penalty for recyclability. It applies to a product with metalloplastic fibres or wires, or with electrical or electronic equipment, and the two penalties add up. The amount is set per product line. For 1 January to 30 June 2026 it goes up in proportion to the eco-fee, and for 1 July to 31 December 2026 it doubles, as the Ministry of the Environment decided in a letter of 27 April 2026 (Refashion eco-modulations guide, version of 3 June 2026). A product with a penalty gets no bonus. The general level of EPR fees is in EPR fees.

New in 2026: the ultra-fast fashion rules

The law of 8 July 2026 defines “mode ultra-express” in a new article L. 541-9-1-1. It is the practice of a producer of stream products that shortens their use or life through a high number of new references and a weak incentive to repair. A person who enables distance sales through a marketplace, platform or similar interface is judged on all the new references it offers. The exception is the references for which it can show that the brand holder is the producer and the interface is not its main sales channel.

The article does not apply to a person established in another EU or EEA state, save after the e-commerce directive procedure (directive 2000/31/EC, art. 3(4) and (5)). It does not exclude a person established outside the EU and EEA, so it can reach a seller in the US, the UK or China. The thresholds, such as the number of references, and the content of the messages a person using the practice must display are for a decree of the Conseil d’État. A provision that needs implementing measures starts when they do (Civil Code, article 1).

The advertising ban, the influencer ban and the information duty apply only to ultra-fast-fashion products as defined, once that decree sets the thresholds. They start from 1 January 2027 at the earliest. The fee penalty (rule 1) and the place of manufacture (rule 4) do not wait for it.

1. A penalty on the fee, from 1 September 2026. Article L. 541-10-27 II sets the range, and the arrêté of 24 August 2026 (Journal officiel no. 200 of 28 August 2026) sets the amount per product type. It applies to a product of a listed type whose score D is 0.8 or less. The law’s range per product is EUR 0.25 to EUR 12 in 2026, EUR 0.50 to EUR 14 in 2027, EUR 0.75 to EUR 16 in 2028, EUR 1 to EUR 18 in 2029 and EUR 2 to EUR 20 from 2030. The arrêté fixes:

A product with the penalty gets no bonus. On the producer’s reasoned request, the eco-organisme must cap the penalty at 50% of the product’s selling price excluding tax.

D is 0.67 + (1.45 - 0.67) x (0.5 x G + 0.5 x R), where G is the breadth of the brand’s range and R the incentive to repair. The Ministry’s methodological note sets them:

• G is 100% under 1,000 references per segment, 50% at 7,000 and 0% above 16,000, with a straight line between. The segments are women, men, children, babies and underwear. The count is the most references on sale on one day of the year, on the brand’s own website.
• A default of 100,000 references per segment applies to a brand mainly sold through an online platform, and to a brand sold on a multi-brand site without its own IDU.
• R weighs the average repair cost against the new price (100% under 33%, 0% above 100%) and whether the brand offers a repair service labelled by Refashion. For a small or medium business R is the repair-cost part alone. For a larger one it is 0.66 times that part plus 0.33 times the repair-service part.

2. An advertising ban, from 1 January 2027 at the earliest, for ultra-fast-fashion products only. The modalities are for a decree of the Conseil d’État. Article L. 229-61-1 bans advertising for ultra-fast fashion products and the promotion of brands that use the practice. The word “gratuit” (free) may not be used as a marketing tool for these products. The ban does not reach media services under another EU state’s jurisdiction, nor information society services provided by a person established in another EU or EEA state, save after the e-commerce directive procedure.

3. An influencer ban, from 1 January 2027 at the earliest, for ultra-fast-fashion products only. Anyone doing commercial influence online, paid or not, may not promote these products or brands, directly or indirectly.

4. The place of manufacture online, from 10 July 2026. A stream product sold online must show where it is made, clearly and legibly on the platform, in characters as large as the price and next to it (article L. 541-9-1-2). It applies from 10 July 2026 on the same reasoning as the representative duty, and the article cites no decree.

Marketplaces

A marketplace that facilitates distance sales of EPR products for a third party must meet the EPR duties for them, unless it holds proof that the seller already has. Holding an IDU for the product counts as that proof (L. 541-10-9). A marketplace submits one consolidated declaration for their own products and their sellers without an IDU, with the list of those sellers, and keeps a register of the compliant sellers (Refashion). That is why a marketplace asks for your textile IDU. A third-party declarant that files for clients is not the marketer: each client must be registered with Refashion and give the declarant a power of attorney (Refashion).

Deadlines

Refashion’s dates are for the 2026 round, from its January 2026 guide.

If you do nothing

Under article L. 541-9-5, the minister notifies you of the facts and the penalty you face, you have one month to answer in writing or orally, and the minister then decides by a reasoned decision. The sanctions are made public (L. 541-9-8).

For a breach of the EPR duty itself, the per-unit amount takes into account the estimated average annual quantity you placed on the market over the length of the breach and the maximum unit contribution set by the approved eco-organismes of the stream. A producer that joins no eco-organisme and runs no individual system is not registered and gets no IDU, so the first row applies to it. A failure to appoint a representative falls under “any other EPR breach”: article L. 541-10-9-1 sits in the same section of the Code as article L. 541-9-5, and no text sets a separate fine for it. Articles 8 and 9 of the law name L. 541-9-1 and L. 541-9-1-1 for the information fine and the DGCCRF’s powers, and do not name L. 541-9-1-2. The DGCCRF’s agents investigate the ultra-fast fashion rules and the advertising ban.

What does not apply

• There is no single French EPR number. The textile IDU covers the textile stream only. A seller in textiles and packaging holds two, one for each (IDU page).
• The ultra-fast fashion article does not apply to a seller established in another EU or EEA state, save after the e-commerce directive procedure. The representative duty does.
• Second-hand clothing placed on a foreign market and then imported is outside the stream (ADEME). Its packaging is not: it falls under the packaging scheme.
• The EU date of 17 April 2028 for textile schemes does not wait on France: France already runs its scheme. The EU rule is in textile EPR in the EU.