A balance scale weighing eco-contributions against recycled packaging and natural-fibre textiles — environmental accountability in fashion

Citeo and Refashion: Millions in Eco-Contributions, But What Environmental Results?

Eco-contributions are meant to finance a circular economy. But when businesses pay hundreds of millions of euros into extended producer responsibility schemes, what environmental outcomes should they expect in return?

France's extended producer responsibility (EPR) system requires companies placing products on the market to contribute to their end-of-life management. Citeo operates in the household packaging and paper sector, while Refashion is the approved eco-organisation for clothing, household linen and footwear. The principle is essential. Yet the figures published by these organisations — and recent regulatory intervention — deserve closer scrutiny.

Citeo: significant funding, uneven recycling outcomes

On its packaging and paper sector page, Citeo displays €1.5 billion in eco-contributions supporting the three Rs: reduce, reuse and recycle. This is the organisation's published headline figure, not a claim that €1.5 billion was collected in a particular financial year.

Citeo's June 2026 recycling update, covering 2025, reports a 73% overall packaging recycling rate. However, outcomes vary sharply by material: 88% for glass, 83% for paper and cardboard, 43% for aluminium and just 30% for plastic packaging. The same Citeo sector page cites only 1.5% of household packaging being reused.

There are genuine achievements here, but the contrast raises an important question: how can funding translate more quickly into prevention, reuse and better-performing recycling streams? Recycling progress must not obscure the importance of avoiding unnecessary packaging in the first place.

When a minimum contribution weakens the incentive to reduce waste

For small companies, the way contributions are calculated matters as much as the headline totals. Citeo explains that an initial invoice of €110 excluding VAT is issued upon joining, and our exchanges with the organisation concerning 2026 addressed the minimum contribution applicable to small producers.

ERVERTE Paris has questioned what happens when a small brand submits detailed packaging data, including materials, weights and eco-design characteristics, but its calculated contribution remains below the minimum. In that situation, an eco-modulation can be reflected in the theoretical calculation without lowering the amount ultimately paid.

This is not proof that the minimum is unlawful. Article R.541-119 of France's Environmental Code expressly allows fixed contributions for producers placing small quantities of products on the market. It also requires eco-organisations to periodically ensure those contributions cover the relevant costs. For small, low-volume brands, the question is one of proportionality and transparency: how is the threshold justified, and does it preserve a meaningful financial reward for better packaging?

In the correspondence shared with the environmental administration in October 2026, ERVERTE Paris requested clarification on that periodic verification, the calculation methodology and the representation of very small producers in tariff discussions. The objective is to improve the scheme, not to reject producer responsibility.

Further information: Citeo's membership and billing FAQ.

Refashion: €162.7 million in 2025 contributions, collection down 6%

Refashion's 2025 activity report records €162.7 million in eco-contributions paid by producers, with approximately 3.6 billion new items of clothing, household linen and footwear placed on the market, representing an estimated 917,604 tonnes.

At the same time, the organisation reports that textile and footwear collection fell by 6% in 2025, to around 272,000 tonnes. Refashion attributes this difficult period to a crisis in outlets for used textiles, disruption among operators and wider economic pressures. It also reports new collection points and ongoing support for the sector. Those contextual factors matter: a fall in collection cannot simply be attributed to one eco-organisation alone.

Nor should collection be confused with recycling. An item collected may later be reused, sorted, recycled or processed in another way. Public reporting should make these outcomes easy to follow separately.

Source: Refashion's 2025 collection results.

A €170,000 administrative fine and renewed government intervention

The questions about Refashion go beyond performance indicators. On 28 October 2026, France's Ministry for the Ecological Transition publicly called on Refashion to meet its obligations to take back textile waste collected by social-economy operators.

According to the ministry's press release, an administrative fine of €170,000 was notified on 13 April 2026 for breaches of those take-back obligations. Following further reports of collection failures, a formal reminder of the law was sent on 26 October 2026, ahead of any potential compliance notice.

These are officially documented regulatory concerns, not allegations of misappropriation of contributions. The government had already announced a reform of the textile EPR sector in April 2026, including stronger outcome-based requirements and a planned audit of Refashion.

When organisations collect mandatory contributions from businesses, the public deserves clear answers about obligations, spending, operational delivery and measurable impacts.

What should change for smaller, responsible brands?

For ERVERTE Paris, environmental responsibility begins at the design stage: carefully selected natural fibres, manufacturing close to home where feasible, fewer unnecessary materials and products designed for longer use. These choices do not automatically entitle a brand to exemptions under EPR rules; eligibility depends on the specific criteria of each programme.

Nevertheless, a credible system should make it easier to understand which improvements count, how bonuses and penalties affect the final invoice, and whether minimum payments remove the incentive for the smallest producers.

We believe the discussion should focus on transparent costs, proportionate contributions, meaningful eco-design incentives, independently verifiable material flows and consistent enforcement. It is possible to support EPR while asking tougher questions about its outcomes.

Measure the impact, not just the money collected

Producer responsibility is indispensable. Yet success cannot be measured by the total amount of money collected or the number of organisations enrolled. It must be assessed through waste genuinely prevented, products reused, materials actually recycled and environmental harm reduced.

The central question is not only how much businesses pay. It is what measurable environmental improvement those payments deliver.

At ERVERTE Paris, we believe transparency and accountability should apply across the entire value chain — from the brand designing a garment to the organisation entrusted with managing its end of life.

Data and official documents consulted as of 5 November 2026. Figures refer to different programmes, measures and reporting periods and should not be read as directly comparable cost-efficiency ratios.

Explore our approach: Discover ERVERTE Paris.

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