2026 Textile Eco-Modulation Guide: What Brands Need to Prepare for Now
Benjamin THOMAS
February 26, 2026
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The Refashion 2026 eco-modulations are a practical tool for guiding the eco-design of textiles, home linens, and footwear. The concept is simple: reward the most environmentally responsible products with incentives, and penalize those that are difficult to recycle. For brands, the stakes are therefore not just financial; they are also operational, administrative, and strategic.
All TLC distributors subject to the Extended Producer Responsibility (EPR) scheme must pay an eco-contribution to Refashion. Eco-adjustments are then applied to this framework, in the form of incentives or penalties, to encourage eco-design initiatives.
The specifications for the TLC sector include incentives related to sustainability, environmental labels, and the use of recycled materials, as well as penalties related to recyclability.
In 2026, there will be three optional incentives and one mandatory penalty system:
The Refashion 2026 guide does not introduce a complete overhaul of the system, but several practical changes deserve the attention of brands. Among the main changes: a new Excel pre-declaration form with mandatory lists, details on sharing test results across multiple product references, clarification on products marketed in batches, an update to the operating conditions for elasticity tests, changes to GOTS documentation requirements, and an increase in penalty fees, aligned with the rise in the eco-contribution.
In other words, 2026 is not a year of business as usual. Even though the main categories of eco-modifications remain the same, the rules of evidence and reporting requirements are changing. For brands, this means they need to review their processes for data collection, product qualification, and engagement with suppliers.
The “sustainability” premium rewards the physical durability of products, as assessed through laboratory testing. The regulatory framework sets a reference amount of €0.70 per unit for the first 100,000 units placed on the market per category, then €0.07 for each additional unit, with a multiplier factor applied based on the product category. Refashion notes that the categories and factors used for 2026 remain the same as those for 2025.
To be accepted, tests must be conducted by an ISO 17025-accredited laboratory. Guide 2026 also provides useful details regarding multi-color variants: all relevant color variants must be clearly listed, one or more test reports must be provided, and photos of all colors must be included. Refashion has also clarified the rules for sharing test results across variants, which can have a direct impact on the cost and organization of testing.
The “label” bonus remains available to finished products certified under one of the 8 labels listed by Refashion:
The finished product must be certified: certification of the raw material alone is not sufficient. The reference amount specified in the specifications is €0.30 per unit for the first 100,000 units, and €0.03 for each additional unit, again with a multiplier factor applied by category.
The 2026 compliance checklist primarily concerns GOTS. Refashion has updated the required documentation, including a photo of the finished product labeled as GOTS, the Scope Certificate covering the relevant production period, and the Transaction Certificate specifying the product references. In certain cases of “contract manufacturing,” additional documents are required, such as a sworn statement from the contract manufacturer and a traceability summary table showing the relationship between yarns, fabric/knit, and the finished product.
The recycled materials incentive applies to products that incorporate raw materials derived from recycling, subject to strict criteria. The specifications distinguish between two levels: €1,000 per ton for materials derived from the recycling of post-consumer TLC waste collected or supported by an approved eco-organization in the sector, and €500 per ton for materials derived from open-loop recycling of waste collected or supported by another approved eco-organization, excluding food-grade plastic resin.
This premium does not apply to materials derived from production waste, unsold products, or the recycling of food-grade resin. It is also based on a proximity criterion: traceability must demonstrate that the sorting, preparation for recycling, recycling, and incorporation stages take place within a maximum radius of 1,500 km from the collection point, or, failing that, within a radius of 1,000 km from the sorting center located in France, depending on the cases specified by Refashion.
Effective January 1, 2025, products containing certain recycling inhibitors are subject to penalties. In 2026, this applies to two scenarios: the presence of metal-plastic fibers or threads, and the presence of electrical or electronic components. Both penalties may apply to the same product. However, a product subject to a penalty is not eligible for a bonus.
The process consists of three steps.
First, in 2026, brands must pre-register their products that are eligible for incentives or subject to penalties, and submit the supporting documentation for the incentives.
Then, in 2027, they report the actual quantities placed on the market for the previously declared product lines.
Finally, following an inspection or audit, Refashion will pay out bonuses or charge penalties starting in the second quarter of 2027.
The real issue for 2026 isn’t just whether a product qualifies for a bonus. It’s about organizing product data, supporting documentation, and internal governance early enough to avoid oversights, rejected applications, or unexpected penalties.
In practical terms, this means:
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