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How to identify and declare penalties?

  • Updated
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:
    A metal-plastic fiber (also known as metallized fiber) is a synthetic fiber with a metallic appearance. It may consist of one or more metallic filaments (e.g., aluminum) coated with a layer of plastic film (e.g., polyester) and reinforced with other fibers (e.g., polyamide). It is often used in fabrics to create shiny or textured effects.
    Examples (non-exhaustive): Lurex®.

As soon as the product contains metal-plastic or metallized fibers, it is concerned, even if this is not indicated on the product composition.

Only internal disruptors to recycling are concerned; external disruptors are not.

For example, for clothing textile and household linen: the penalty only applies to fabrics (including main material, secondary materials, linings), and components if they are non-removable (internal disruptors). It does not apply to accessories/supplies (external disruptors). All-over embroidery and knitting threads are concerned (internal disruptors), while placed embroidery is not concerned (external disruptors).

  1. 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. 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.
 
To declare penalties, a two-step procedure must be followed, similar to that used for other eco-modulations:
  1. Step 1: Pre-declaration of relevant products in 2025:
    • Complete the usual form dedicated to eco-modulations.
    • No supporting documentation are required.
    • It is your responsibility to declare products subject to penalties.
  2. Step 2: Declaration of actual quantities placed into the market in 2026:
    • Declare the actual quantities placed into the market subject to penalties.
    • A declaration of honor will be required to confirm the accuracy of your statement.
    • Please note that Refashion may conduct audits to certify the accuracy of declarations if necessary.