TLC Authorized Representative in France with Refashion

A company that places new clothing textiles, household linen or footwear on the French market without being established in France now has two separate boxes to tick: join Refashion, the only approved eco-organization for the TLC scheme, and appoint an EPR authorized representative established in France.

The second box is no longer just a contractual option. French law no. 2026-602 of 8 July 2026, known as the “fast fashion” or “ultra-express fashion” law, created article L. 541-10-9-1 of the Environmental Code, which requires this representative for any producer subject to EPR that is not established in France.

Refashion has told its members that TLC producers not established in France will need to be ready to provide the identity of their French representative and the corresponding written mandate, in particular for the 2027 reporting campaign.

This article explains what Refashion is, when a TLC authorized representative is actually required, what that representative does day to day, and how Ekovio can take on this role for your company.

Summarize this article with:

🎯 In brief: Refashion and the TLC representative requirement

• Refashion is the only approved eco-organization for the scheme covering clothing textiles, household linen and footwear (TLC).
• Since 10 July 2026, any producer subject to EPR that is not established in France must appoint a French representative by written mandate, under article L. 541-10-9-1 of the Environmental Code created by the 8 July 2026 law.
• The representative is subrogated to the EPR obligations covered by its mandate: it acts on the producer’s behalf and assumes those obligations.
• An existing Refashion membership is not enough on its own if your company still has no establishment in France.
• The requirement is deemed satisfied where an online marketplace or platform established in France already ensures compliance with the producer’s EPR obligations.

🔍 How we verified this information

The representative requirement described here stems from article L. 541-10-9-1 of the Environmental Code, created by law no. 2026-602 of 8 July 2026 and applicable to producers not established in France since 10 July 2026. The TLC-specific timeline, in particular the 2027 reporting campaign deadline, reflects the communication Refashion sent to its members in August 2026. The subrogation mechanism is set out in article L. 541-10-27 of the same code. Prices shown reflect Ekovio’s published rates at the time of writing; see the Pricing page for the current schedule. Because Refashion is the only approved eco-organization for this scheme, there is no comparison between eco-organizations to make here.

🏢 What are Refashion and the TLC scheme?

Refashion, formerly Eco-TLC, is the single eco-organization approved by the French state for the EPR scheme covering clothing textiles, household linen and footwear. On behalf of producers, it organizes prevention and end-of-life management: a network of drop-off points, contracted sorting centers, a repair fund, and modulation of the eco-contribution based on recycled content, durability and end-of-life sortability.

All manufacturers, importers and distributors that place new clothing textiles, household linen or footwear for consumers on the French market are covered. The liable company is the one that issues the first invoice with French VAT to an end consumer. Unlike the household packaging scheme, which has several approved eco-organizations, TLC offers no choice: joining Refashion is the only route, short of setting up an approved individual system, which is very rare in practice.

⚖️ Do you need an authorized representative to join Refashion?

Since 10 July 2026, article L. 541-10-9-1 of the Environmental Code requires a representative established in France whenever a producer subject to EPR is not itself established in France. This requirement, introduced by the 8 July 2026 fast fashion law, applies to companies established elsewhere in the European Union just as much as to those established outside it, and it covers the TLC scheme along with the other French EPR schemes.

The representative must be a natural or legal person established in France, appointed by a written mandate that defines the scope of the obligations covered. Once the mandate is accepted, the representative is responsible for ensuring the producer’s EPR obligations are met and assumes, on the producer’s behalf, all the obligations within scope. In practice, a company not established in France that wants to join Refashion must therefore, in most cases, rely on a TLC authorized representative to formalize its membership and follow up its obligations.

This requirement already existed in an optional form in the Refashion membership contract: it was possible to appoint a representative to ensure EPR compliance. The 8 July 2026 law turns that option into an obligation for members not established in France.

📅 What Refashion expects from members not established in France

In its communication to members, Refashion states that the option to appoint a representative, previously provided for in the contract, becomes a requirement for members not established in France. These members must prepare to meet this obligation, in particular for the 2027 reporting campaign, by providing the identity of their representative established in France and the corresponding written mandate, in line with the conditions set out in the membership contract.

The membership contract between Refashion and its members will also be amended to bring it into line with the new law. Refashion has said it will come back to members with further details on this point.

📋 What your TLC representative does with Refashion

The role goes well beyond signing a mandate. It usually covers:

• Joining Refashion in the company’s name and obtaining the Unique Identifier.
• The annual declaration of the quantities and categories of clothing, household linen and footwear placed on the market.
• Tracking the calculation and payment of the eco-contributions owed to Refashion, including modulation bonuses and penalties.
• Updating the declared information when the product range or volumes change.
• Routine exchanges with Refashion on the company’s EPR compliance, including the sorting and Triman labelling requirements.

The exact scope of the mandate must be defined precisely. A company can hand all of these tasks to its representative or keep some of them in-house. As the Environmental Code provides, the representative is subrogated to the obligations it accepts: its appointment is not a formality, it is a genuine regulatory compliance mandate. For the legal background to this mechanism, see our article on subrogation and the French EPR representative.

💶 How much does a TLC authorized representative cost?

The cost of representation is separate from the eco-contributions paid to Refashion, which depend on declared volumes and on the modulation applied to your products. At Ekovio, representative pricing is per action rather than a fixed subscription:

Action	Price	What it covers
Registration or contract transfer	€149.99	Initial setup of your representation with Refashion, whether a new membership or the transfer of an existing contract to Ekovio
Declaration	€99.99	Each declaration filed with Refashion on your company’s behalf
Termination	€49.99	Ending the representation mandate

These amounts are in addition to the eco-contributions owed to Refashion and, where applicable, the penalty on industrial and commercial practices introduced for ultra-express fashion. Full Ekovio pricing details are on our Pricing page.

✅ The steps to TLC compliance with Refashion

Getting into compliance usually follows these steps:

1. Check whether the company is a producer for TLC EPR purposes, meaning it makes the first placing on the French market of new clothing, household linen or footwear to consumers.
2. Determine whether the company is established in France or not.
3. If not established in France, appoint a TLC authorized representative by written mandate, or confirm that a marketplace established in France already ensures this compliance.
4. Join Refashion and obtain a Unique Identifier.
5. Declare the volumes placed on the market, apply the sorting and Triman labelling, and pay the corresponding eco-contributions.
6. Provide Refashion with the representative’s identity and the written mandate, ahead of the 2027 reporting campaign.
7. Maintain compliance over time, including when the range, volumes or applied modulation change.

A company that was already a Refashion member before 10 July 2026 still needs to check whether its situation has to be updated in light of the representative requirement.

🔁 Refashion is the only approved eco-organization: what follows from that

For TLC, there is no eco-organization to choose and no option to switch later: Refashion is the sole approved body. The representation mandate is therefore not about running a competitive tender, but about the quality of the follow-up: accurate declarations, correct positioning on the bonus-malus scale, and handling the new penalty that applies to certain ultra-express fashion products. That is also what sets TLC apart from schemes like packaging or furniture, where a representative can support a trade-off between several eco-organizations.

🔤 Authorized representative or full EPR mandate for the TLC scheme?

“Authorized representative” and “EPR representative” describe the same regulatory function: an entity established in France that ensures a producer not established there meets its EPR obligations. The exact wording varies by scheme and by eco-organization, and in French the role is called “Représentant Autorisé” or “mandataire REP”.

For schemes such as packaging, Ekovio offers a distinctly named authorized representative service. For the TLC scheme with Refashion, there is no separate authorized representative product: the function sits within the TLC EPR mandate. Its scope can be limited to regulatory representation alone when your team already handles its declarations, or extended to full compliance management with Refashion. In other words, the authorized representative role is part of the wider EPR mandate, not sold on its own for this scheme.

🤝 Ekovio, your TLC authorized representative for Refashion

Ekovio can act as the EPR representative for your Refashion membership, either in that role alone alongside a company that already manages its own data and declarations, or as part of broader management of TLC EPR compliance covering membership, declarations, labelling and eco-contribution tracking. The exact scope of the engagement is set contractually, based on your company’s organization and needs.

Start your free trial with Ekovio to organize your representation with Refashion.

❓ Frequently asked questions about the TLC representative and Refashion

Does a textile producer established in the EU but not in France need a TLC representative?

Potentially, yes. Being established in the European Union is not the same as being established in France. If the company is a producer for TLC EPR purposes and is not established in France, the representative requirement in article L. 541-10-9-1 applies, unless a marketplace established in France already ensures its EPR compliance.

Do I have to go through Refashion for the TLC scheme?

In almost all cases, yes. Refashion is the only approved eco-organization for the TLC scheme. The only theoretical alternative is an individual system approved by the public authorities, an option that is very rarely used.

Is my current Refashion membership enough if I am not established in France?

No, not on its own. An existing membership and a Unique Identifier do not show that the representative requirement is met. Your situation must be checked against the rule in force since 10 July 2026, and your representative’s identity will have to be provided to Refashion, in particular for the 2027 reporting campaign.

Is Ekovio affiliated with Refashion?

No. Ekovio is an independent provider that supports companies with their EPR compliance, including their relationship with Refashion, without being affiliated with the eco-organization.

Can I keep managing my declarations while Ekovio handles the representation?

Yes. Ekovio can act only as the TLC authorized representative, with the company keeping operational control of its data and declarations. The scope is set contractually.

What if I sell only through a marketplace?

If a marketplace or online platform established in France already ensures compliance with your TLC EPR obligations, the obligation to appoint a representative is deemed satisfied. Still, check exactly what the platform covers, as it does not always extend to all of your sales or product categories.

Organize your representation with Refashion

A company not established in France that places textiles, household linen or footwear on the French market has two things to check: its Refashion membership, since Refashion is the only approved eco-organization for the TLC scheme, and its obligation to appoint an EPR representative established in France under article L. 541-10-9-1. Ekovio can act as your representative with Refashion, either alone or as part of broader management of your TLC EPR compliance.

Start your free trial with Ekovio to set up your TLC authorized representative with Refashion.