Liable Companies and Products

Find out if you are subject to the Textile and Footwear Sector.

Companies subject to the law

You are considered as a "producer" (or “marketer”) if you manufacture, import, assemble or introduce for the first time on the national market (Metropolitan France and local authorities listed below), clothing textiles, household linen and shoes, whose end user is the consumer. More generally, a "producer/marketer" is a company invoicing French VAT for the first time on clothing textiles, household linen and shoes destinated for a consumer. Products designated for professional use are not eligible, except if the end user is the consumer.

Depending on the case, can be regarded as sender on the market:

A manufacturer or instructing party selling under its brand name articles manufactured in France or abroad;
An importer (wholesaler or retailer) introducing products on the French market (including listed overseas territories) products for end consumers;
A distributor with its own brand, directly imported products (multi-brand), or operating under license;
A marketplace for its own sales and those of its third-party sellers not registered with Refashion (even with foreign headquarters).

Find article L541-10 of the Environment Code on your regulatory obligations.

For information, companies purchasing only in France are not subject to EPR, which is the responsibility of their supplier/manufacturer/importer. Please note that, to date, no marketers are exempted from paying their contribution. For example, self-employed entrepreneurs must also register and declare their quantities placed on the market.

Companies subject to the law

You are considered as a "producer" (or “marketer”) if you manufacture, import, assemble or introduce for the first time on the national market (Metropolitan France and local authorities listed below), clothing textiles, household linen and shoes, whose end user is the consumer. More generally, a "producer/marketer" is a company invoicing French VAT for the first time on clothing textiles, household linen and shoes destinated for a consumer. Products designated for professional use are not eligible, except if the end user is the consumer.

Depending on the case, can be regarded as sender on the market:

A manufacturer or instructing party selling under its brand name articles manufactured in France or abroad;
An importer (wholesaler or retailer) introducing products on the French market (including listed overseas territories) products for end consumers;
A distributor with its own brand, directly imported products (multi-brand), or operating under license;
A marketplace for its own sales and those of its third-party sellers not registered with Refashion (even with foreign headquarters).

Find article L541-10 of the Environment Code on your regulatory obligations.

For information, companies purchasing only in France are not subject to EPR, which is the responsibility of their supplier/manufacturer/importer. Please note that, to date, no marketers are exempted from paying their contribution. For example, self-employed entrepreneurs must also register and declare their quantities placed on the market.

If you are a marketplace, please note the following information:

A marketplace is defined as a digital platform, portal or similar system that facilitates remote sales or delivery of products on behalf of a third-party reseller.

Since January 1st, 2022, Article L. 541-10-9 of the Environmental Code (in French only), provides that marketplaces are in charge of the EPR obligations and declare the products of its third-party sellers that do not have an unique identification number (UIN).

The marketplace thus assumes the status of producer:

For quantities placed on the market under its brand;
For quantities placed on the market on behalf of third-party ressellers who do not have an UIN

To find out if your third-party resellers are already contributing to their quantities placed on the market, you can ask them for their unique identification number.

Third-party ressellers have two possibilities to meet their obligations:

1. Via Refashion by making the declaration of their annual quantities placed on the market.

They then have their own unique identification number (UIN) or

2. Via the marketplaces on which they market products.

They can then continue their sales on these platforms only.

The regulatory framework (cf. R541-168) stipulates that marketplaces may transmit details of marketings by third-party retailers at Refashion's request.

If you are a marketplace, please note the following information:

A marketplace is defined as a digital platform, portal or similar system that facilitates remote sales or delivery of products on behalf of a third-party reseller.

Since January 1st, 2022, Article L. 541-10-9 of the Environmental Code (in French only), provides that marketplaces are in charge of the EPR obligations and declare the products of its third-party sellers that do not have an unique identification number (UIN).

The marketplace thus assumes the status of producer:

For quantities placed on the market under its brand;
For quantities placed on the market on behalf of third-party ressellers who do not have an UIN

To find out if your third-party resellers are already contributing to their quantities placed on the market, you can ask them for their unique identification number.

Third-party ressellers have two possibilities to meet their obligations:

1. Via Refashion by making the declaration of their annual quantities placed on the market.

They then have their own unique identification number (UIN) or

2. Via the marketplaces on which they market products.

They can then continue their sales on these platforms only.

The regulatory framework (cf. R541-168) stipulates that marketplaces may transmit details of marketings by third-party retailers at Refashion's request.

If you are a service provider/administrator, please note the following important information:

A service provider/administrator is not a marketer, their client companies are. Each of their companies must therefore be registered and declared to Refashion.
You can/should register the companies for which you are the service provider/administrator directly with Refashion (go to the "To regularize yourself" page); you do not have to register as a service provider/agent.
You must keep the POA of each producer at the disposal of Refashion.
Refashion is not a partner of any service provider/agent, they are independent and work on their own behalf.
Refashion does not certify any service provider/administrator. We only contract with the "marketer" company that join Refashion. Therefore, we do not provide any certification or contract.
Refashion does not support the creation of service provider/agent organizations in any way, and cannot provide any information in this regard, so please do not contact us in this regard. All membership information is on our website.

If you are a service provider/administrator, please note the following important information:

A service provider/administrator is not a marketer, their client companies are. Each of their companies must therefore be registered and declared to Refashion.
You can/should register the companies for which you are the service provider/administrator directly with Refashion (go to the "To regularize yourself" page); you do not have to register as a service provider/agent.
You must keep the POA of each producer at the disposal of Refashion.
Refashion is not a partner of any service provider/agent, they are independent and work on their own behalf.
Refashion does not certify any service provider/administrator. We only contract with the "marketer" company that join Refashion. Therefore, we do not provide any certification or contract.
Refashion does not support the creation of service provider/agent organizations in any way, and cannot provide any information in this regard, so please do not contact us in this regard. All membership information is on our website.

Products subject to the law

The CHF EPR sector concerns all clothing textiles, household linen and shoes:

Placed on the French market (including Guadeloupe, Martinique, Guyana, Reunion Island, Mayotte, Saint Pierre and Miquelon, Saint Martin)
Sold or donated (including the products donated during special professional/promotional events to collaborators and/or consumers)
To consumers (including sales to staff)
New/ offered (sold or donated) on the market for the first time, including upcycled products made from fabric off-cuts or dormant stocks (unsold items that have not contributed) or with a mixed composition (waste objectfs/recovered materials - second-hand textiles, footwear or household linen/ sold fabric off-cuts)

Clothes made of 100% leather or natural fur are not subject to this regulation. Apart from these products, all materials are concerned (cotton, polyester, silk, recycled or not, etc.).

An upcycled product made entirely (excluding ornaments or finishing elements) from used fabrics, materials, clothing textiles, household linen or footwear (second-hand, having already contributed to its initial marketing) is not subject to Textile EPR.

Download the non-exhautive list of products subject and excluded

The articles subject to the regulation were published in the Official Journal on August 21, 2008.

To illustrate the exclusions of the Textile Sector that fall within the scope of other EPR sectors, download our Glossary.

For all the products that do not concern our EPR system, please check this page (in French only: Fonctionnement des filières REP – Ademe) to see if an EPR system exists and can take care of the end-of-life of these products. To date, there is no EPR system for leather goods.

Need help?

If you have any questions, please consult the Q&A or complete the contact form

A dedicated hotline is a your disposal from Monday to Friday from 10am to 5pm: +33 (0) 1 89 16 94 06

If you have any questions, please consult the Q&A or complete the contact form

A dedicated hotline is a your disposal from Monday to Friday from 10am to 5pm: +33 (0) 1 89 16 94 06