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.

Scope of the TLC stream

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 Refashion sets 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.

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.

Filing process

Standard flow for a non-EU brand:

1. Authorized representative engaged in France (mandate signed electronically, same day).
2. Catalog prepared with categories (clothing/linen/footwear), unit counts, material breakdown, French sales estimate.
3. Dossier filed with Refashion (5-10 business days review).
4. IDU issued, published to SYDEREP within 5-10 business days.
5. Annual declaration filed by 28 February for prior year units.

Total: 2 to 3 weeks from mandate to live IDU.

Cost example

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

• Representative covering TLC + Packaging: €490 × 2 setup + €249 × 2 × 12 = €6,464 Year 1, €5,976 Year 2+.
• Refashion membership: ~€250/year.
• Citeo packaging membership: ~€150/year.
• Eco-contribution on TLC (~5,000 units, mid-price clothing): ~€1,500-€3,000/year.
• Packaging eco-contribution: ~€600-€1,200/year.
• Year 1 total: ~€9,000-€11,500 all-in.

For higher-volume brands (€2M+ French revenue), the eco-contribution scales but representative fees remain flat.

Why Refashion matters 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. Flat €490 setup + €249/month per stream — /pricing. Send your catalog summary to /contact for a written quote in 24 hours.