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 the Extended Producer Responsibility (EPR) for textiles and footwear, which products to declare, and how to comply with Refashion.​

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

Do you manufacture, import, assemble or sell clothing, household linen or footwear for consumers on the French market? If so, you are considered a “marketer” and are subject to the EPR for the sector.

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

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

Check if you’re affected

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

Manufacturer or principal

Selling products on the French market 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 on the French market (including overseas departments and regions);

Private-label distributor (multi-brand or licensed)

Selling the items directly

Online seller or marketplace

 Even if based abroad, for your own sales and those of third-party sellers not registered with the system.

If you are :

A Marketplace

  1. A marketplace is responsible for :​
  • Declarations of its own products​
  • Declarations of its third-party sellers who are not registered​
  • Contacting the hotline to access a differentiated declaration of the products placed on the market by its third-party sellers​
  1. Since January 1, 2022, according to Article L541-10-9, marketplaces must obtain the UIN of their third-party sellers or declare their products placed on the market on their behalf.​
  2. They must also be able to provide product details per seller to Refashion at any time.

A third-party declarant (manager, facilitator)​ ​

Please note the following: a third-party declarant is not a marketer placing products on the market. It is their clients who are, and they must be registered to Refashion.​

register​

  • It must directly their clients on the member Extranet.​
  • It keep the Power of Attorney (POA) for each company. ​
  • Refashion neither certifies nor lists third-party declarants. ​
  • Refashion only contracts with the marketer placing products on the market and does not support the creation of facilitation entities.

Which products are subject to EPR?

All clothing, household linen, and footwear that are :

(This list is not exhaustive)

  • 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 in a professional or promotional context for employees or the public)
  • Intended for consumers (including sales to staff)
  • New or offered (sold or donated) for the first time, including upcycled products made from new materials (unsold dormant stocks, fabric offcuts) or with mixed composition (waste from objects/materials recovery, second-hand textiles and footwear/unsold fabric offcuts).

Examples of excluded products

  • 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 

Check the indicative list of liable products

Check the illustrated glossary for special cases​ ​

Declare my products and get compliant

Further information

Need help?

Do you have a question about your situation or your legal obligations?

Consult our FAQ or complete the contact form.

A dedicated hotline is open Monday to Friday from 9:00 am to 5:00 pm: +33 1 89 16 94 06