Download the AGEC Compliance Checklist for Handbag Importers

What is AGEC?

France's Anti-Waste for a Circular Economy law (Loi Anti-Gaspillage pour une Économie Circulaire) is one of the EU's most ambitious extended producer responsibility frameworks. Enacted in 2020 and phased through 2025, it applies to many textile, leather, and accessory products placed on the French market, including imported handbags.

Non-compliance risks include customs holds at Le Havre, DGCCRF sanctions, public correction orders, and exclusion from French retail channels. DGCCRF surveillance of imported leather goods has increased significantly in recent years.

1. Refashion EPR (Extended Producer Responsibility)

Under AGEC, brands placing relevant products on the French market must:

• Register with Refashion — the accredited Producer Responsibility Organisation for clothing, household linen and footwear, and the main body handling textile and related EPR obligations — and obtain a unique producer identifier.
• Declare annually the quantities and total weight of products placed on the French market (by category).
• Pay eco-contributions, which can be eco-modulated based on material composition, recycled content, durability and other criteria.
• Submit declarations via the Refashion portal.

2. Consumer Information Requirements (Article 13)

AGEC Article 13 requires information on environmental qualities and characteristics (recycled content, presence of hazardous substances, etc.).

Note on recyclability: According to current Refashion guidance, specific recyclability information does not currently need to be displayed to consumers for clothing, textiles and footwear categories because a reliable methodology and database are still under development. We prepare detailed component-level material data to support your Article 13 obligations and future Digital Product Passport (DPP) requirements.

3. Hazardous Substance Reporting & REACH Compliance

AGEC reinforces disclosure obligations for Substances of Very High Concern (SVHC) under REACH. For handbags, key areas include:

• Azo dyes — restricted under REACH Annex XVII. Common in coloured leathers and synthetic linings.
• Chromium VI — restricted to <3 mg/kg in leather goods (ISO 17075).
• Phthalates — restricted in synthetic leathers and PVC components (REACH Annex XVII entry 51).
• Formaldehyde — restricted in leather goods (ISO 17226).
• Dimethylfumarate (DMF) — banned in all consumer goods in the EU. Anti-mould sachets are a common source.
• PFAS / PFCs — water-repellent treatments may contain restricted perfluorinated compounds, with tightening rules in 2026+.

4. Documentation Requirements for Smooth Clearance

We recommend the following documents accompany every shipment to France:

• Material Composition Map — per-SKU: outer shell, lining, hardware, thread, adhesive, packaging
• REACH Batch Test Reports — azo dyes, Cr VI, phthalates, formaldehyde, DMF, etc.
• SVHC Declaration
• EPR Data Sheet — formatted for Refashion annual declaration
• Supplier Audit Reports — BSCI/SMETA where applicable
• Certificate of Origin
• AQL Inspection Report with photos
• Packaging Recyclability Statement — separate from product requirements

5. Compliance Timeline (Typical for Importers)

6. Common Pitfalls to Avoid

• Relying on one-time certificates instead of batch-specific reports. French customs expect documentation tied to each shipment.
• Neglecting separate packaging compliance. A compliant handbag shipped in non-compliant packaging is a non-compliant shipment.
• Missing annual Refashion declaration deadlines. Late declarations incur penalties even if the eco-contribution was paid on time.
• Inconsistent origin claims vs. documentation. If your origin claim doesn't match your AGEC dossier, DGCCRF will flag both issues simultaneously.

Based on current Refashion guidance and AGEC requirements (as amended). This is not legal advice — consult Refashion or a qualified French regulatory advisor for your specific situation. Requirements can evolve; we recommend verifying the latest guidance directly with Refashion (pro.refashion.fr) and consulting a French regulatory expert for your specific products and volumes.