This information sourced from the French government or is not representative of the official regulations, it is to share information on existing methods for eco-modulated fees and penalties and for viewers to reflect on this in connection to GCN's Circular Rewards program.

2026 Refashion/ADEME figures and France's Extended Producer Responsibility (EPR) framework— REP TLC (Responsabilité Élargie du Producteur pour les Textiles d'habillement, Linge de maison et Chaussures - the Unique Identification Number (UIN / IDU) is ADEME (Agence de la transition écologique — the French Agency for Ecological Transition,

Re_Fashion https://pro.refashion.fr/en/

Current 2026 Refashion/ADEME figures, and France's TLC EPR system with a pay a per-product EPR eco-fee, with bonuses and penalties that change the amount.

The basic cost to a brand in 2026

For a brand selling clothing in France, the 2026 standard eco-contribution is generally only a few euro-cents per item, but it varies substantially by product.

Examples from the official 2026 Refashion scale:

Product

2026 EPR fee/item

Women's T-shirt/top €0.03

Men's T-shirt/top €0.04

Women's shirt €0.03

Men's shirt €0.05

Women's jumper €0.06

Men's jumper €0.08

Women's denim trousers €0.08

Men's denim trousers €0.11

Women's everyday trousers €0.07

Men's everyday trousers €0.08

Women's jacket €0.09

Men's jacket €0.11

Women's coat €0.16

Men's coat €0.17

notes

Refashion itself says that documentary evidence is required for eco-modulations.

For example:

Refashion financial criterion

Evidence needed

GCN data opportunity

Durability

ISO 17025 test report

Testing credential

Environmental certification

GOTS/OEKO-TEX/etc certificate

Certification credential

Recycled content

Quantity + traceability evidence

Verification credential

Recyclability

Product/component declaration

Assessment/declaration

Commercial practices

Relevant product/business data

Verified product data

This is exactly why your earlier idea of a UNTP Full Certification Reference is important.

The DPP could potentially contain:

Claim → Conformity Credential → Scheme → Version → Assessment → Assessor → Evidence → Validity → Product

and that evidence could subsequently be used by a producer/brand to substantiate an EPR eco-modulation claim.

These are the standard 2026 rates including the repair and reuse funds.

So, for example, a brand putting 100,000 men's T-shirts onto the French market would have a basic EPR contribution of approximately:

100,000 × €0.0396 = €3,960

before any applicable eco-modulation.

The official Refashion 2026 guide is here:

Refashion 2026 Eco-fee Guide

But this is where it gets interesting for GCN

The basic EPR fee is only part of the story.

Refashion has four eco-modulation mechanisms in 2026:

1. Durability bonus

2. Environmental certification bonus

3. Recycled raw-material bonus

4. Recyclability penalties (Refashion)

And this is already remarkably close to the data architecture you've been discussing for GCN.

1. Environmental certification

A qualifying finished product can receive a €0.30 or €0.03 bonus per item, depending on category and volumes.

The eligible labels currently include:

• Ecocert ERTS Level 2, OEKO-TEX MADE IN GREEN, bluesign, Fairtrade Textile, EU Ecolabel, Demeter, GOTS, Bioré

Only one certification bonus is granted even if a product has several qualifying labels. (Refashion)

So a qualifying GOTS T-shirt, for example, could potentially receive a €0.30/item bonus under the applicable conditions.

That's potentially much larger than the underlying EPR fee.

For a 100,000-unit product: 100,000 × €0.30 = €30,000

versus a basic men's T-shirt EPR contribution of: 100,000 × €0.0396 = €3,960

So the certification incentive can be economically significant relative to the underlying EPR charge.

2. Recycled material

There is an even more interesting incentive.

Refashion provides: €1,000/tonne

for qualifying recycled raw material derived from post-consumer TLC waste collected or supported by an approved PRO.

€500/tonne

for qualifying recycled material from open-loop recycling of waste collected or supported by an approved PRO.

There are conditions concerning proximity and the recycling installations. (Refashion)

So if a brand incorporates 10 tonnes of qualifying post-consumer recycled material:

10 × €1,000 = €10,000 potential bonus

Again, this is not simply a claim by the brand. Refashion requires documentary evidence/traceability.

3. Durability

The durability bonus is particularly interesting because it is evidence-based.

For 2026, the basic reference amount is:

€0.70 or €0.07, depending on the volume placed on the market,

multiplied by a factor specific to the relevant product category. (Refashion)

And the French ADEME description makes the evidence requirement very clear:

sustainability/durability bonus → test report from an ISO 17025 accredited laboratory. (Filières REP)

This is exactly the sort of relationship your GCN UNTP Conformity Credential structure should capture:

Durability claim
↓
Specified durability criteria
↓
Test method/version
↓
Test result
↓
ISO 17025 laboratory
↓
Test report / conformity credential

rather than simply:

"Durable = Yes"

4. Recyclability penalties

This is the other side of the system.

Since 2025, products can receive a 50% increase in their EPR contribution for certain recyclability problems.

The current penalties concern:

Metalloplastic fibres

and

Electrical/electronic components

There is an important exception for certain traceability/composition components, including RFID-type traceability where the conditions are met. (Filières REP)

And the penalties can be cumulative.

So, for example, if a product has a €0.10 base EPR fee and is subject to one 50% penalty:

€0.10 → €0.15

Two applicable penalties could potentially take it to:

€0.10 → €0.20

And a product subject to a penalty cannot also receive an eco-modulation bonus under the current rules. (Refashion)

There is a major development in 2026

This is particularly important given your earlier question about future ecomodulation.

French rules have now moved beyond simply rewarding:

"good material/product characteristics"

and are beginning to incorporate commercial/industrial practices.

The current French legal text introduces, from 1 September 2026, penalties related to durability linked to industrial and commercial practices.

For example, where the relevant D score ≤ 0.8, penalties are specified by product type and increase over time. (Légifrance)

For example:

Product

2026–27 penalty

2030+ penalty

T-shirt/polo

€2

€3.50

Shirt

€6

€8.25

Jeans

€9

€17.25

Trousers

€7

€9.25

Jacket/coat

€12

€19.50

Dress

€7

€9.25

These are penalties, not the ordinary EPR fee. (Légifrance)

This is a very important development because it demonstrates France moving toward substantially stronger financial differentiation based on product/business characteristics.

What does this mean in percentage terms?

The original recyclability penalty is particularly easy to understand.

If a men's T-shirt has a 2026 standard EPR fee of €0.0396:

50% penalty = €0.0198

So:

€0.0396 → €0.0594

for one penalty.

But compare that with the certification incentive:

€0.30 bonus

The certification incentive is therefore about 7.6× the basic EPR fee for that particular men's T-shirt.

A product-level financial incentive/penalty system attached to the EPR contribution.

The DPP could potentially contain:

Claim → Conformity Credential → Scheme → Version → Assessment → Assessor → Evidence → Validity → Product

and that evidence could subsequently be used by a producer/brand to substantiate an EPR eco-modulation claim.

NOTE. ADEME generates the UIN/IDU; Refashion is the approved PRO through which the marketer registers, declares volumes and pays the EPR contribution.

Refashion confirms that the UIN is generated by ADEME and appears in the company's Refashion member profile. (Refashion)

So: Brand/Marketer → Refashion → EPR declaration/payment → ADEME-generated UIN/IDU (the identifier proving the marketer's EPR registration/compliance status.)

Refashion — Eco-fees
Refashion — Eco-modulations 2026
ADEME — French TLC EPR scheme

Bottom line

For a normal French clothing brand in 2026, the basic EPR cost is typically cents per garment, e.g. roughly €0.02–€0.20+ per item depending on product. But the financial exposure/incentive can be considerably larger once eco-modulation is included: €0.30/item certification bonuses, €500–€1,000/t recycled-material bonuses, 50% recyclability penalties, and now much larger product-specific durability/business-practice penalties.

This is strong evidence that verifiable product-level data and conformity evidence are already becoming financially valuable to brands under an EU Member State's EPR system, rather than DPP data being purely a future regulatory information exercise.