Refashion: The Complete EPR Guide for Apparel, Linen, and Footwear Brands

Non-EU fashion brands shipping to French consumers, direct, via marketplaces, or through wholesale, are in scope of the Refashion EPR stream from the first unit sold. Refashion is the sole accredited eco-organism for the French TLC stream (Textile, Linge de maison, Chaussures) and covers apparel, household linen and footwear under one IDU.

This article maps the practical filing and ongoing operational shape of Refashion compliance for non-EU brands.

What does the TLC stream cover?#

Refashion covers:

• Clothing: T-shirts, tops, dresses, pants, jackets, knitwear, underwear, swimwear, hosiery, activewear.
• Household linen: bed linen, bath towels, table linen, kitchen linen, decorative textiles.
• Footwear: shoes, boots, sandals, sneakers, slippers.
• Fashion accessories (where primarily textile or leather): handbags, scarves, hats, belts.

What is out of scope: pure metal jewellery, hard plastic accessories (sunglasses fall under separate rules), professional workwear in some specialised cases.

How does Refashion set eco-contributions?#

Refashion applies its own eco-modulation grid:

• Base rate per unit, varying by product category (a T-shirt pays differently from a winter coat).
• Durability bonus: products with verified durability claims (number of wash cycles, etc.) get reductions.
• Recycled fibre bonus: declared use of recycled content reduces the rate.
• Proximity bonus: products manufactured within Europe get a small bonus over those manufactured elsewhere.
• Eco-design bonus: products designed for recyclability or repairability get further reductions.

Two declaration regimes exist. Refashion's simplified regime is billed per piece at a higher rate (about EUR 0.58 per clothing item in 2026) and is reserved for fewer than 5,000 pieces a year with no eco-modulated product; the detailed regime is usually far cheaper per piece.

For a non-EU fashion brand, the proximity bonus is structurally unavailable (manufacturing typically in Asia). The durability and recycled-fibre bonuses are realistic levers. See /blog/eco-modulation-france-bonus-eco-contributions for the broader eco-modulation framework.

How does registration with Refashion work?#

Standard flow for a non-EU brand:

1. Authorized representative engaged in France (mandate signed electronically).
2. Catalog prepared with categories (clothing/linen/footwear), unit counts, material breakdown, French sales estimate.
3. You sign the Refashion membership; we act as your declaring facilitator under your power of attorney, and Refashion invoices you directly.
4. Refashion issues the identifier after membership, the signed contract and your first declaration and payment, then about ten business days.
5. Declarations follow: most streams are declared once a year.

Can Refashion claim contributions for earlier years?#

Registration is due from your first sale in France, and eco-organisations can claim contributions for earlier years: up to five years at Refashion (the current year and four previous ones), three at Ecomaison, Ecosystem and Valobat, one at Citeo, none at Léko. Identifiers are never backdated. We tell you before signing whether earlier years are at stake.

What does Refashion compliance cost?#

Non-EU fashion D2C brand shipping €800,000/year to French consumers (mid-price apparel, mostly clothing):

• Representative covering TLC (textile) + Packaging: our fee is a fixed annual amount per EPR stream, confirmed in a written quote within one business day, independent of your eco-contributions. It depends on the declaration regime and frequency, the number of references and, above EUR 1,000 of eco-contribution per stream, its size. A one-time setup per stream and a refundable security deposit are stated in the quote.
• Refashion membership fee: set by Refashion (eco-organism membership fees run from €0 to €450/year depending on the stream).
• Citeo packaging membership: ~€150/year.
• Eco-contribution on TLC (~5,000 units, mid-price clothing): ~€1,500 to €3,000/year.
• Packaging eco-contribution: ~€600 to €1,200/year.

For higher-volume brands (€2M+ French revenue), the eco-contribution scales but the representative fee stays a fixed annual amount.

Why does Refashion matter more for D2C brands?#

D2C fashion brands selling direct on their own Shopify storefronts or via Instagram Shopping rarely face marketplace-driven EPR enforcement (there is no marketplace checking). However:

• ADEME runs direct audits of high-profile fashion D2C brands.
• French press and consumer activist groups increasingly call out non-compliant fashion brands.
• B2B opportunities (wholesale to French stores, capsule collaborations with French retailers) require verifiable TLC IDU.

Refashion registration is operationally less time-critical than packaging or WEEE for marketplace sellers, but legally identical in obligation.

Common operational issues#

Missing the packaging side. Fashion brands sometimes register Refashion only and forget that the shipping boxes also need Citeo registration. Two filings are needed.

Underestimating unit counts. Refashion declares by unit, not by weight. Brands tracking only revenue or weight need to extract unit data from their order management.

Category misclassification. A "kitchen apron" can be classified as workwear (out of scope) or as kitchen linen (in scope). Filing matters.

Returns volume. Fashion D2C brands have 20-40% return rates. Returned units that re-ship to other French customers may be double-counted. Refashion accepts net-of-returns declarations if documented.

FAQ#

Does Refashion cover both clothing and footwear under one IDU?#

Yes. Refashion is the single accredited eco-organism for the TLC (Textile, Linge de maison, Chaussures) stream and covers clothing, household linen and footwear under one IDU per producer. You file one dossier; it covers your full TLC catalog.

Does Refashion apply to handbags, belts and accessories?#

Fashion accessories (handbags, belts, scarves, hats) are generally in scope when made primarily of textile or leather and intended for personal wear. Pure-metal accessories (jewellery, metal-only buckles) typically fall outside Refashion. The line is blurry for hybrid accessories, check with your representative for borderline categories.

I am a D2C brand on Shopify, not on a marketplace. Do I still need Refashion?#

Yes. Refashion applies to first placing on the French market regardless of channel. Shopify D2C sales to French consumers trigger the obligation. No marketplace check happens, but the underlying legal obligation exists and ADEME can audit Shopify-based sellers directly.

Refashion + Packaging in one mandate#

We cover TLC and Citeo under one engagement. You sign the Refashion membership; we act as your declaring facilitator under your power of attorney, and Refashion invoices you directly. Our fee is a fixed annual amount per EPR stream, from €190/year excl. VAT for streams under the eco-organism flat-fee regime, confirmed in a written quote within one business day, /pricing. Send your catalog summary through Request a written quote.

Sources & references#

All legal and regulatory claims in this article trace back to the following primary sources (Légifrance, EUR-Lex, ADEME and equivalents). Verified 24 May 2026.

• SYDEREP, registre public des producteurs (ADEME)
• Citeo, éco-organisme emballages ménagers
• Refashion, éco-organisme textile, linge, chaussures (TLC)
• ADEME, Agence de la transition écologique
• Cadre général des filières REP, Ministère de la Transition écologique