Preparing EU Textile EPR and Eco-Modulation: Learning from French Eco-Modulation
First published: April 2026
The European Union’s amended Waste Framework Directive, updated by Directive (EU) 2025/1892, which entered into force on 16 October 2025, introduces mandatory Extended Producer Responsibility (EPR) for textiles, textile-related products, and footwear across all EU Member States. This is one of the most significant regulatory shifts ever imposed on the fashion and textile industry. It directly affects the costs, competitiveness, and design strategies of every brand selling into the European market.
This article explains what EU textile EPR means in practice, how eco-modulation of EPR fees works, what fashion and textile brands can learn from the French Refashion model, and what steps companies should be taking now to prepare for textile recycling compliance.
If you are planning your strategy for EU textile EPR and eco-modulation, or looking for an eco-modulation rebate in France, please contact us directly here.
What is Extended Producer Responsibility (EPR) for textiles?
Extended Producer Responsibility (EPR) for textiles is a regulatory tool that makes producers, manufacturers, importers, and retailers financially and operationally accountable for the end-of-life management of the textile products they place on the market. Its purpose is to accelerate the transition toward a circular, low-impact textile economy across the EU.
Under EPR, producers are required to fund and manage the collection, sorting, reuse, recycling, and proper disposal of textiles sold within the EU. In practice, this means every company responsible for placing textiles, textile-related products, or footwear on the EU market must pay fees that finance national collection and waste-management systems. These fees vary based on each product’s environmental performance, in line with the principle of eco-modulation.
The polluter pays principle
The framework is grounded in the polluter pays principle: Producers whose products generate greater environmental impact through poor recyclability, use of hazardous substances, or low durability bear proportionally higher financial costs. This is not a symbolic measure. Under the EU textile EPR, the polluter-pays principle translates directly into quantifiable, product-level fee differentials that affect margins and pricing across every product category.
Directive (EU) 2025/1892 harmonises EPR requirements for textiles across the EU, obliging all Member States to establish national EPR schemes in accordance with common EU rules. Implementation is progressive, with national schemes required to be fully operational between 2025 and 2028.
Key changes introduced by Directive (EU) 2025/1892 to the EU Waste Framework Directive
The primary changes to the EU Waste Framework Directive 2008/98/EC are as follows:
- Mandatory national EPR schemes for textiles, textile-related and footwear
- Producers must pay fees for each textiles, textile-related and footwear placed on the EU market; fees finance collection, reuse, recycling, and end‑of‑life management
- Eco‑modulation of fees based on sustainability criteria (durability, recyclability, etc.)
- EU‑wide harmonised rules, but each Member State designs its own national scheme
Planning ahead for EU EPR? Contact us today to form your strategy together with Eurofins Sustainability Services.
What is Eco-Modulation and what does it mean to the fashion industry?
Eco-modulation is a system that adjusts EPR fees according to the sustainability and environmental performance of individual textile products. Rather than applying a uniform fee to all producers, the eco-modulation EPR system rewards products designed for durability, easy recyclability, and low environmental impact with reduced fees or financial bonuses. Conversely, items that are difficult to recycle or contain harmful substances attract higher fees or penalties.
Under the EU Directive, eco-modulation criteria must align with the standards established in the Ecodesign for Sustainable Products Regulation (ESPR). These criteria consider factors such as durability, recyclability, and the use of recycled content, creating a direct financial driver for brands to integrate circular and environmentally responsible design principles from the outset of product development.
For the fashion industry, eco-modulation transforms sustainability from a voluntary commitment into a quantifiable cost factor. To minimise eco-modulation EPR fees, companies need to align their products with the required sustainability criteria, a process that is far more effective and cost-efficient when addressed at the earliest stages of product design rather than retrospectively.
Eco-modulation in practice: The French Refashion model
While EU Member States are required to establish their national EPR schemes by mid-2028, France has long been a pioneer in extended producer responsibility for clothing, household linen, and footwear. In France, eco-modulation first appeared as a basic incentive mechanism in 2007. It became a legally reinforced system following the adoption of the AGEC Law in 2020, and by 2025–2026, the national Producer Responsibility Organisation (PRO) Refashion had further operationalised the framework by introducing detailed eco-modulation criteria based on durability, environmental certification, recycled content, and recyclability.
The textile eco-modulation system currently applied in France offers a valuable and concrete preview of what brands can expect as other EU Member States roll out their own EPR frameworks.
Under France’s eco-modulation model, products are subject to a structured system of bonuses and penalties. The framework consists of three bonus categories and one penalty category, each designed to encourage more sustainable textile production.
- Durability bonus: Products that demonstrate high physical durability through accredited laboratory testing qualify for a financial bonus. The bonus per product reference is EUR 1.05 or EUR 0.035* (depending on market volumes), multiplied by a factor specific to 11 eligible product categories, including tops, bottoms, outerwear, intimate wear, hosiery, footwear, and baby products such as clothing and shoes. To qualify, products must meet all required thresholds across durability criteria such as pilling resistance, seam strength, and colourfastness. All testing must be conducted by an ISO 17025-accredited laboratory.
- Environmental certification bonus: Finished products certified by one of eight recognised environmental labels, such as GOTS and EU Ecolabel, qualify for a bonus of EUR 0.03 to EUR 0.30* per item across clothing, household linen, and footwear categories. Critically, only finished-product certification qualifies. Raw-material certifications alone are not sufficient.
- Recycled content bonus: A financial incentive is granted for incorporating recycled raw materials:
- Up to EUR 1,000* per tonne of post-consumer textile waste (clothing, household linen, footwear) recycled from streams collected or financed by an approved PRO such as Refashion
- EUR 500* per tonne applies to materials from open-loop recycling of waste collected or financed by an approved eco-organisation (excluding food-grade plastic resins).
To qualify, recycled materials must meet two conditions:
- Local proximity requirement: Sorting, preparation, and recycling must occur within 1,000–1,500 km of the collection point
- Environmental compliance: Operators must apply environmental measures equivalent to those required for French-regulated facilities (ICPE)
Recyclability penalty: Introduced in January 2025, this penalty applies to products containing metalloplastic fibres (e.g., lurex) or electronic and electrical components (e.g., LEDs, heating elements). These components interfere with recycling processes. Penalties are applied as surcharges on the base eco-fee and are cumulative: if a product contains both metalloplastic fibres and electronic components, both penalties apply simultaneously. Any product subject to a penalty is rendered ineligible for all bonuses under the scheme.
*Based on current Refashion 2026 rates.
Looking for an eco-modulation rebate in France? Contact us now!
How can the fashion industry prepare for EU Textile EPR and Eco-modulation?
EU textile EPR has become a concrete regulatory reality. Fashion brands will soon be subject to binding obligations related to eco-modulation EPR fees, traceability, product durability, and circularity. Because compliance requires significant preparation time, brands cannot afford to wait until 2028, when national EPR systems are expected to be fully implemented.
Below are the key points companies should keep in mind to ensure they are ready:
- Audit product portfolios to anticipate future EPR fees: Assess each product line against eco-modulation criteria: durability, recyclability, hazardous substance content, and recycled material incorporation. Identify which products qualify for bonuses and which may incur penalties. This exercise helps forecast EPR fee exposure, prioritise product development decisions, and highlight high-impact categories early in the planning cycle.
- Test durability through accredited laboratories: Durability bonuses require verified testing performed by ISO 17025-accredited facilities. All thresholds must be met simultaneously, and testing must be performed on finished products. Incorporating durability testing into the product development cycle is significantly more efficient and cost-effective than attempting to adjust products after they have gone to market.
- Secure recognised environmental certifications: Certifications such as GOTS or EU Ecolabel, can unlock eco-modulation bonuses and strengthen brand positioning. Ensure certifications apply to finished products rather than only raw materials, and maintain up-to-date transaction and scope certificates for verification purposes.
- Understand the legislation and EU country‑specific obligations: Stay informed about new legal requirements in each market, including registration, reporting, and fee structures that will vary by Member State. Treat compliance not as a regulatory burden but as an opportunity for brand differentiation and leadership in sustainable fashion.
- Integrate eco‑design across all products: Brands should actively enhance product durability, improve recyclability, and increase the use of recycled content at the design stage. These measures directly reduce eco-modulation EPR fees and strengthen long-term textile recycling compliance. Eco-design decisions made early in the development process have the greatest financial and environmental leverage.
- Build robust traceability systems: Companies must be able to identify and document the origin, material composition, recycled content, and environmental certifications of all components used across their product range. Strong traceability is essential for accurate EPR fee calculation, compliance reporting, and alignment with Digital Product Passport (DPP) requirements under the ESPR.
- Prepare take‑back and recycling partnerships: Under EU EPR rules, brands are financially responsible for managing the end-of-life of their products. Companies should develop or join take-back schemes, whether in-store or online, to collaborate with collectors, sorters, and recyclers, and explore reuse programmes, repair services, and resale loops. These actions reduce long-term compliance costs and strengthen circular business models aligned with EU policy direction.
How does Eurofins Sustainability Services help you prepare for EU textile EPR and eco-modulation?
Navigating textile recycling compliance, eco-modulation criteria, and evolving EU regulation demands expert support backed by robust testing and verification. Eurofins Sustainability Services provides end-to-end sustainability solutions for textile and fashion brands, from raw materials through to retail. Our capabilities span durability testing, physical testing, chemical testing, testing of recycled plastics, supply chain traceability, and more. All are directly relevant to meeting eco-modulation criteria and broader EPR obligations.
Contact us today to plan ahead your strategy for EU EPR and eco-modulation.
Looking for an eco-modulation rebate in France?
Brands seeking a rebate under France’s Refashion scheme need accredited, high-capacity testing partners who understand the specific durability criteria that drive fee reductions.
Eurofins Softlines & Hardlines network of laboratories operates a global network of ISO 17025–accredited laboratories spanning North America, the EU, China, India, and broader Asia, providing full coverage across all Refashion durability test categories.
Our capabilities are designed to handle large seasonal volumes and fast-fashion items, ensuring that even brands with extensive collections can meet declaration windows without bottlenecks. In the past few years, we have already helped fashion brands secure rebates worth millions of euros, turning what many view as a regulatory cost into a measurable financial return.
