A practical look at how brands can use France’s Refashion scheme to get ahead of EU-wide textile EPR requirements.
First published: August 2026
The revised Waste Framework Directive entered into force on 16 October 2025. It requires all EU Member States to establish extended producer responsibility (EPR) schemes for textiles and footwear under common EU rules. Member States have 20 months to transpose the Directive into national law (i.e., by 17 June 2027) and 30 months to establish EPR schemes for textile and footwear products (i.e., by 17 April 2028). For brands and manufacturers, that means preparation should begin well before every national system is fully operational.
One of the most important developments is that textile EPR in Europe is not intended to remain a simple flat-fee model. The European Commission has stated that producer fees should be adjusted using sustainability criteria, including factors such as durability and recyclability, through an approach known as eco-modulation.
What will the EU textile EPR require?
Under the revised Waste Framework Directive, producers of textile and footwear products will pay a fee for each product they place on the market. Those fees are intended to finance the management of used and waste textiles, including collection, re-use, preparation for re-use, recycling and disposal. The Directive also clarifies that separately collected textiles are considered waste until they have been sorted, helping create a more uniform interpretation across the EU of what counts as waste versus used textiles.
For businesses, the practical consequence is that product responsibility will increasingly extend beyond the point of sale. Registration, reporting and financing obligations are expected to become more structured across the EU, while eco-modulation is likely to strengthen the link between product design and compliance cost. Preparation of EU Textile EPR should therefore include not only legal monitoring, but also stronger internal product data and documentation processes.
Learning from France’s Refashion scheme
France’s Refashion scheme is currently one of the clearest live examples of how eco-modulation can work in practice. Refashion applies eco-modulation through a system of financial bonuses and penalties, including bonuses linked to product durability, environmental certification, and the incorporation of recycled raw materials, as well as penalties linked to recyclability. It shows how an EPR system can move beyond basic collection financing and begin differentiating financial outcomes according to product attributes.
For EU-wide preparation, the French model is useful because it highlights the practical questions businesses may need to answer in future national systems:
- Which product references qualify?
- What supporting documents are accepted?
- How do penalties interact with bonuses?
- What role does third-party testing play?
The implemented policy under Refashion may not be copied exactly by every Member State, but it is a highly relevant signal for future readiness.
Refashion also introduced new recyclability penalties from 1 January 2025. According to its official guidance, these penalties apply in particular to products containing metalloplastic fibres and to products containing certain electrical or electronic components, subject to specified exclusions. Refashion also states that penalties may be cumulative, and that a product subject to a penalty cannot receive a bonus.
Even if other EU schemes do not adopt exactly the same criteria, the underlying principle is important. Product features that make collection, sorting or recycling more difficult may create additional compliance costs. Businesses should therefore identify potentially high-risk components early, especially where decorative effects, embedded electronics or complex material combinations are used.
A reliable TIC partner who is well-versed in these regulations and possesses technical expertise with the affected products can support this process through design review, component assessment and testing strategies aligned to likely circularity outcomes. That helps compliance teams speak the same language as product development and sourcing teams.
Traceability will be a key element in eco-modulation
Traceability is also likely to become more important as textile EPR develops. The EU’s new rules are designed not only to fund waste management, but also to support better sorting and a more credible circular system. Businesses that can clearly document material origin (such as cotton origin), recycled input verification, and the relationship between product references, suppliers and supporting records are likely to be better placed to support future claims and declarations. Refashion already reflects this logic through its supporting-document requirements, reference-based declarations and audit framework.
Preparing for EU Textile EPR through third-party testing
Many businesses will wait for detailed national implementing rules before taking action. That is understandable given the complexities and requirements within the current regulatory landscape, but it may limit flexibility if product portfolios, supplier arrangements and technical files have already been fixed by the time schemes go live. Early preparation can help brands build stronger internal readiness, including baseline durability programmes, documentation protocols, traceability controls and, where relevant, verification of recycled inputs.
The most effective preparation strategy is likely to depend on the product category and the fee criteria eventually adopted at a national level. For some products, durability may become the main focus. For others, recyclability barriers or recycled-content substantiation may matter more. The key is to align evidence, product design and supplier management as early as possible.
How can Eurofins Sustainability Services and the textiles expertise within Eurofins Softlines & Hardlines help you prepare for the EU Textile EPR?
Preparing products for the EU textile EPR requires expertise in regulatory compliance, textiles testing, verification, documentation discipline and practical support across the supply chain.
Eurofins Sustainability Services works with the global lab network and textiles expertise from Eurofins Softlines & Hardlines to provide end-to-end sustainability solutions for the textiles, garment, leather goods and footwear industries, from raw materials through to retail, helping businesses prepare for eco-modulation criteria and wider EPR obligations.
Our services include durability testing, physical testing, chemical testing, testing of recycled plastics, supply chain traceability and related verification support, all of which can strengthen product readiness as EPR schemes evolve across Europe.
For brands using France as an early benchmark, our ISO 17025-accredited global laboratory network and operational capacity can also readily support Refashion-related durability programmes at scale.
Contact us today to plan ahead for your strategy for EU EPR and eco-modulation with compliance and testing experts who are focused on your success.
