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Fédération de la Haute Couture et de la Mode

FHCM

Créée en 1973, la Fédération de la Haute Couture et de la Mode (FHCM) représente plus d'une centaine de marques françaises, européennes et internationales et est le porte-parole de l'industrie de la mode créative et du luxe.

Lobbying Activity

Response to Circular Economy Act

6 Nov 2025

Founded in 1973, the Fédération de la Haute Couture et de la Mode (« the FHCM » or « the Federation ») represents over a hundred of the most recognised French and international fashion Houses, covering creative designers and high-end segments of the fashion industry. As a professional organization, the Fédération acts as an institutional interlocutor with public authorities at national and European level, supporting the development and competitiveness of its members. The Fédération welcomes the European Commissions ambition to advance circularity through the forthcoming New Circular Economy Act and values the great opportunity to contribute to this consultation. This new framework is closely intertwined with the Commissions ongoing work on eco-design requirements to be defined in the delegated act on textiles in 2027. While the FHCM supports the Commissions ambition to foster circularity, remove barriers to the production of recycled materials and stimulate the market for high-quality secondary raw materials, its members invite the Commission to approach the development of this Act with a nuanced understanding of the specificities of the creative industries, which form a major and distinct segment of the textile sector. 1. Sector specificities and technical limitations in the use of recycled fibres. Creative and luxury fashion operates with small production volumes and exceptionally demanding quality standards. Although technological progress continues, fully recycled fibres rarely meet the mechanical, functional or aesthetic properties required by the sector. The limited availability of high-qualityr recycled materials therefore remains a key obstacle. The FHCM calls for a proportionate and flexible framework reflecting material diversity and creative processes. We therefore propose that recycled-content thresholds be designed at material level, rather than at product level, and introduced gradually, in line with technological maturity. The EU should also support investment in advanced sorting, dismantling and fibre-recycling technologiesespecially for noble and natural fibres. 2.Call for clarification of Article 25 (ESPR) and recognition of pre-consumer materials as eligible recycled input. Article 25 of the ESPR, by equating recycling with destruction, generates legal and operational uncertainty. The Fédération respectfully recalls that under the EU Waste Framework Directive (2008/98/EC), recycling is distinct from recovery or disposal and is ranked higher in the waste hierarchy. High-quality recycling operations should therefore not be considered destruction, particularly where they generate valuable secondary raw materials and support EU circularity goals. In addition, the current prohibition on the destruction of unsold goods indirectly excludes certain pre-consumer materials from eligible recycled inputs. The Fédération invites the Commission to clarify that traceable, high-quality pre-consumer wasteparticularly production offcutsmay be recognised as eligible feedstock for recycled content. This clarification could therefore align with international standards (ISO 14021; Textile Exchange GRS-202-V2.0) to ensure consistency, quality and traceability across markets. 3.Promoting a circular model rooted in quality and creativity. Circularity in creative fashion extends beyond recycling. The sector already embodies a sustainable model based on durability, reparability and product longevity. Its circular economy is built on quality, craftsmanship and innovationvalues sustained by a unique ecosystem of Houses, SMEs, ateliers and artisans. The Fédération underlines that maintaining excellence and identity is essential for consumer trust, and therefore central to circularity itself. European policies should thus take into consideration the relevance of a value-based vision of circularity.
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Response to Derogations to the prohibition of the destruction of unsold Apparel and Footwear

1 Aug 2025

Founded in 1973, the Fédération de la Haute Couture et de la Mode (the Federation or the FHCM) represents over a hundred of the most recognized French and other international brands. Having actively contributed to the discussions leading to the ESPR and this Draft Delegated Regulation, including through the Ecodesign Forum process, the FHCM remains fully committed in pursuing the ESPRs objectives for a more sustainable economy. We welcome this proposal with great interest, as it represents significant progress and reflects elements previously raised in our positions. While supporting the goal of preventing the destruction of unsold goods and as previously indicated, the FHCM stresses that the assimilation of recycling to destruction in the ESPR and the consecutive ban on the recycling of unsold textiles and shoes is particularly problematic for our sector. Our sector produces unique goods whose specific characteristics must be carefully considered to avoid compromising their appeal or economic viability. These products are defined by high levels of creativity, limited production volumes, strong brand identity, and substantial intellectual property value. For many Houses mostly based in France and producing predominantly in Europethese derogations are not optional but essential safeguards. The FHCM welcomes the Commissions proposal to include derogation (c) in the DDR and firmly supports its retention in the final delegated regulation. Nevertheless, the FHCM requests the removal of the proportionality requirement in cases of counterfeiting and the establishment of a legal presumption that destruction is an appropriate and proportionate measure for counterfeit goods. The Federation also supports the Commissions decision to retain derogation (d), which reflects input provided during previous consultations and addresses contractual realities within the creative fashion sector. We also firmly underline the relevance of derogation (e), which recognises the technical impossibility of removing certain labels, logos, or design elements from creative fashion products without compromising their integrity or quality. This derogation is essential, as fashion Houses face significant risks of parallel trade and counterfeiting. Many such products involve complex materials and techniquessuch as embroidery, engraving, embossing, or woven patternsthat make removal infeasible or risk damaging the product itself. Finally, the FHCM regrets that the DDR does not include a specific derogation for high-quality recycling, despite our repeated advocacy and supporting arguments. HQR may constitute a powerful lever to advance circularity objectives. Certain creative fashion unsold products do not fall within the scope of the current drafted derogations - (c), (d), (e) - particularly when they lack visible intellectual property elements (e.g. detachable labels, absence of logos or registered design rights), yet their valuable components can still be recovered through high-quality recycling rather than being sent to landfill. Unlike conventional recycling methods, which often result in the degradation of fibre quality and material structure, high-quality recycling relies on advanced industrial processes that ensure superior performance, traceability, and environmental benefits, fully aligned with the circular economy principles of the ESPR. While recycling is considered by ESPR as a form of destruction and therefore prohibited, the Fédération would encourage the Commission to opt for a distinct regulatory approach regarding high-quality recycling activities (HQR) in a specific derogation (g) . Finally, the Fédération wishes to raise several concerns regarding the proposed verification processes and retention obligations under Article 3 of the DDR and respectfully proposes aligning the retention period for technical documentation with a five-year limitation period.
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Response to Sustainable products - disclosure of information on unsold consumer products

10 Jul 2025

Founded in 1973, the Fédération de la Haute Couture et de la Mode (the Federation or the FHCM) represents over a hundred of the most recognized French and other international brands. As a founding member of the European Fashion Alliance, which contributes as an expert to the Ecodesign Forum, the FHCM welcomed with great interest the public consultation. Although we fully support the objectives pursued by the ESPR, we would like to highlight with this position paper the key issues arising from this IR regarding the specific nature, activities, and operational realities of the creative and luxury fashion sector, to ensure the effective implementation of the regulation. We would like to thank the Commission for putting forward a proposal to postpone the deadlines, giving companies more time to get prepared. However, we must also stress that, unfortunately, this proposal introduces new challenges and creates additional concerns for our sector. The FHCM fears that maintaining the obligation to report starting in 2026 in a free format would not serve the intended purposes of Article 24 of the ESPR and would impose unnecessary complexity and costs on businesses. Moreover, even if the reporting in a consolidated format is delayed to 2027, based on 2026 data, it will still be of limited relevance for the textiles and shoes sector, given its misalignment with the ban on the destruction of unsold goods, which is expected to enter into force in July 2026. In line with the European Commissions ongoing initiatives to enhance regulatory clarity and reduce administrative complexity, the FHCM respectfully requests a postponement of the application of the reporting obligation to 2028, based on 2027 data. For the sake of clarity and given the time of the year the IR will likely be adopted, we would like to insist that only a delay of the reporting obligation itself as opposed to a delay of some, or all the IR provisions would address our concerns. Such postponement would make sense, as it would align with the new application timelines of the Corporate Sustainability Reporting Directive (CSRD) for a significant number of companies subject to the reporting obligation. The FHCM regrets that the column initially foreseen for providing detailed justifications regarding the reasons for discarding doesnt appear in the IR. In our view, this change raises issues for the sector in terms of precision and justification for the treatment of unsold products, particularly given that operators may be required to report in a detailed format starting from 2027. The FHCM therefore strongly advises for the addition of a dedicated explanations column, as initially proposed in the European Commissions working document, to facilitate operators ability to provide justifications. The Federation also advocates that parent companies should be allowed to disclose information relating to their subsidiaries in an aggregated format, without the obligation to break down data for each individual subsidiary. The FHCM supports the Commissions decision to adopt a low level of granularity, in most cases based on the 2-digit Combined Nomenclature (CN) code, as this approach aligns with our previous requests. However, the FHCM regrets the choice of 4-digit CN codes for certain product categories in the draft, that targets directly the creative fashion products as it follows: CN code 4203, CN code 4303, CN code 6307.A 4-digit classification seems not suitable for the specificities of the creative and fashion industry, as it could compromise the confidentiality of strategic and commercially sensitive data and heighten the risk of competitive distortion for businesses . Therefore, the Federation requests the exclusion of these codes from Annex II and advocates for the application of the 2-digit aggregation level. The Federation remains at the disposal of the European Commission to provide further expertise and insights.
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Meeting with Dan Nica (Member of the European Parliament)

20 Jun 2025 · Conference The New Challenges for Fashion and Textiles in Europe: Regula4ons, Compe44veness, Sustainability, Trade

Meeting with Jessika Roswall (Commissioner) and

2 Jun 2025 · Textiles

Response to Revision of EU rules on textile labelling

29 Sept 2023

Feedback of the Fédération de la Haute Couture et de la Mode is attached.
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