This change was decided by the Ministry of the Environment (letter dated April 27, 2026). It aims to strengthen incentives to improve the recyclability of TLC products. Refashion is implementing this decision in accordance with its certification.
What is changing in practice: only the EM4 penalty rate is being modified; its amount is doubled, rising from 50% to 100% of the eco-contribution amount for the product in question.
The criteria triggering the penalty, however, remain strictly unchanged.
The increase takes effect on July 1, 2026. All penalties calculated on products placed on the market on or after this date will be subject to the new rate.
The penalty is calculated per product line by applying a percentage to the eco-contribution amount for that product.
Taking the example of a pullover containing metallic-plastic fibres, subject to the EM4 penalty.
You placed 50,000 units of this product on the market in 2026, broken down as follows:
- 25,000 units between 1 January and 30 June 2026
- 25,000 units between 1 July and 31 December 2026
The amount of the eco-fee for this pullover is €0.0614 on the product line item.
Calculation of the EM4 penalty:
Before 1 July, the penalty is equal to 50% of the eco-fee, i.e. €0.0307 per unit. From 1 July, the penalty increases to 100% of the eco-fee, i.e. €0.0614 per unit.
| Period | Number of products | Rate | Penalty per unit | Amount |
| Jan. 1 – June 30, 2026 | 25 000 | 50% | €0,0307 | €767,50 |
| July 1 – Dec. 31, 2026 | 25 000 | 100% | €0,0614 | €1 535,00 |
| Total EM4 for 2026 | €2 302,50 |
Key takeaway: only products placed on the market from 1 July 2026 are subject to the new rate. Products declared before this date remain calculated at the previous rate of 50%.