Companies and products subject to Extended Producer Responsibility (EPR)

Do you manufacture, sell or import clothing, household linen or footwear in France?

Find out if your company is subject to Extended Producer Responsibility (EPR) requirements in Clothing, Household linen and Footwear sector, Which products you need to declare? How to achieve compliance with the support of Refashion?

Which companies are subject to Extended Producer Responsibility (EPR)?

Do I have to declare?

Take the online test (2 min)

Do you manufacture, import, assemble or sell clothing, household linen or footwear to consumers in France? Then you are subject to Extended Producer Responsibility (EPR).

As a producer, brand or retailer, you are legally required to declare the products you place on the French market and to contribute financially to their end-of-life prevention and management.

In short, the producer, brand or retailer is the company invoicing French VAT for the first time on a clothing, household linen or footwear product intended for end consumers.

Specifically, you are subject to EPR if you are a producer, brand or retailer, i.e.:

Manufacturer or principal, selling products in France under your name or brand, whether manufactured in France or other countries;
Importer (wholesaler or retailer), you are the first one to import clothing, household linen and footwear products in France (including overseas departments and regions);
Private label distributor (multi-brand or licensed) directly importing product in France
Online seller or marketplace, even located in another country, working for yourself or other unregistered third-party sellers.

What products do you have to declare?

EPR applies to clothing, household linen and footwear (CHF). What you need to know: Products are subject to EPR even if they are given away rather than sold.

Products included (liable)

Tous les textiles, linge de maison et chaussures :

- Placed on the French market for the first time (including Guadeloupe, Martinique, French Guiana, Reunion Island, Mayotte, Saint-Pierre-et-Miquelon and Saint-Martin)

- Sold or donated (including donations for professional events or advertising aimed at employees or the public)

- Intended for end consumers (including sales to staff)

- New or supplied (sold or donated) for the first time, including upcycled products made from new materials (unsold dormant stocks, fabric offcuts) or of mixed composition (waste objects/reclaimed materials, second-hand CHFtextiles and footwear/unsold fabric offcuts).

- Clothing and accessories for animals, as bought and used by consumers

Products excluded

Clothing made from 100% leather or natural fur (all other materials are concerned).
Upcycled products made entirely from second-hand materials (excluding decorative or finishing details), since their contribution was made when they were first marketedplaced on the market.
Products intended exclusively for professional use

More information

Consultez la liste indicative des produits assujettis

Consultez notre glossaire illustré pour les cas spécifiques

Declaring my products and meeting legal requirements

Key points

You are subject to EPR if:

You are the first to place clothing, household linen or foortwear items on the French market
You are a seller or marketplace
Your products are placed on the market for end consumers

You are required to declare:

All your new or upcycled products made from
new or mixed materials
Your own sales + those of your unregistered
third-party vendors
Even if they are donated or given away to
employees

If you are a service provider/administrator

please note the following important information:

Un facilitateur n’est pas un metteur en marché : ce sont ses clients qui le sont, et qui doivent être enregistrés.

A service provider is not a producer, brand or retailer: but its client companies are, and they must be duly registered.
Service providers are required to register their client companies directly on Refashion extranet (via the extranet).
They keep the POA mandates or powers of attorney for each company.
Refashion does not certify or list service providers.
Refashion enters into contract only with the producer, brand or retailer.
We do not provide support service providers setting up their own business.

If you run a marketplace

please note the following information:

A marketplace is responsible:
- For its own-label sales ;
- For third-party sales without a UIN (Unique Identification Number).
As of 1 January 2022, and in compliance with Article L541-10-9, marketplaces are required to:
- Obtain the UIN of their third-party vendors or
- Declare products sold on the marketplace for them.
They must also be able to provide a list of products by seller to Refashion at any time.