Could you tell me the recyclability statement to be displayed on my product: "mostly recyclable product", "fully recyclable product" or "product recyclable into a product of the same nature"?
To date, after study and experimentation of various calculation methodologies, in the state of the downstream sector, the cumulative application of the five criteria mentioned in the Decree (https://bit.ly/3FsuANF) does not allow for regulatory justification of affixing to clothing, household linen and footwear (CLF) products one of the mentions “produit majoritairement recyclable”, “produit entièrement recyclable” or “produit recyclable en un produit de même nature”.
Therefore, you do not need to include any information about recyclability on the "product sheet on environmental qualities and characteristics". This applies to all products subject to EPR for CLF. For more information, consult the list of products subject to and excluded from our EPR, which can be downloaded from this page: http://bit.ly/3VdjuSp.
Since its inception, the EPR sector for CLF has been oriented towards the reuse of these products, giving priority to reuse over recycling. The rate of reuse, close to 60% of the waste collected, is about twice the rate of recycling. The affixing of one of these mentions on the recyclability could thus mislead the consumer on the future of their used products.
In case of control by the DGCCRF (General Directorate for Competition Policy, Consumer Affairs and Fraud Control), the attached note is proof. The non-respect of the recommendation made by Refashion exposes you to the sanctions: an administrative fine of up to €3,000 for a natural person and €15,000 for a legal person.
The evolutions upstream and downstream of the Textile industry are constant. In this perspective, Refashion will periodically re-evaluate the recyclability of the products of the Textile Sector.
Regarding bonus and penalties, information will be communicated to you as soon as possible (January 2023), as it is linked to our request for re-accreditation, underway with the public authorities.
Finally, for your questions concerning any other subject related to Article 13 (traceability, incorporation of recycled materials, plastic microfibers, etc.), please refer directly to the FAQ published by the Ministry of Ecological Transition: http://bit.ly/3ESzJys or contact your professional federation.
Refashion dedicates a page to the AGEC law: https://bit.ly/3urgAgX