This new eco-modulation related to the recyclability of Clothing, Household Linen, and Footwear (CHF) establishes two types of penalties:
1. Penalty for the presence of metal-plastif fibers: You can find the exact definition in our following article What is a metal-plastic fiber?
There is no minimum percentage to reach to be concerned by the penalty. As soon as the product contains metal-plastic or metallized fibers/yarns, it is concerned by the penalty, even if this is not indicated on the product composition.
Only internal disruptors to recycling are concerned; external disruptors are not. To know more about this, please refer to the best practice guides on textiles and footwear design for recycling.
For example, for clothing textile and household linen: the penalty only applies to fabrics (main material, secondary materials, linings), and components if they are non-removable (internal disruptors). The penalty does not apply to accessories or supplies (external disruptors). All-over embroidery and knitting threads are concerned (internal disruptors), while placed embroidery is not concerned (external disruptors) except if they are repeated on the greatest part of the product, as it is then an internal disruptor.
Logos and brand labels are not concerned (external disruptors).
Rhinestones and sequins are not concerned.
For footwear: textile uppers, elastic… are concerned (internal disruptors). Shoelaces with lurex are not concerned (they can be removed, as they are external disruptors).
2. Penalty for the presence of electrical or electronic components (EEE): (excluding component(s) whose function is to inform about traceability and/or product composition information, and which do not contain batteries or accumulators).
Examples (non-exhaustive): LED lights, heating devices, pedometers, etc.
Exclusion example: RFID chips.
The penalty amount is specified by product line in the corresponding classification system. It applies as soon as a metal-plastic fiber and/or an electrical or electronic device is present in the product.
Please note : a product concerned by a penalty cannot qualify for a bonus.
To identify your products subject to penalties, we recommend consulting your product managers, who can provide precise details on the composition of your marketed items.
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Step 1: Pre-registration of relevant products in year N:
- Complete the usual form dedicated to eco-modulations.
- No supporting documentation are required.
- It is your responsibility to declare products subject to penalties.
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Step 2: Declaration in year N+1 of actual quantities placed into the market in year N:
- Declare the actual quantities placed into the market subject to penalties.
- A checkbox is integrated directly into your declaration, by checking it, you certify the accuracy of the information provided for products subject to penalties.
- Please note that Refashion may conduct audits to certify the accuracy of declarations if necessary.