Destruction ban
The destruction ban covers consumer returns too.
Since 19 July 2026, large companies in the EU may no longer destroy unsold clothing, clothing accessories or footwear. Products a consumer has returned fall explicitly within scope. For every item, you need to be able to substantiate where it went.
What the regulation says
Four points, with the reference alongside.
The rules sit in the Ecodesign for Sustainable Products Regulation. Each point below carries its place in the text, so you can read it for yourself.
Since 19 July 2026, for large companies
The ban on destroying unsold consumer products covers clothing, clothing accessories and footwear. For medium-sized companies it starts on 19 July 2030. Micro and small companies are exempt.
Consumer returns are in scope
Alongside stock surplus and dead inventory, the regulation counts as unsold consumer products the items a consumer has returned under their right of withdrawal, or within a longer withdrawal period the seller offers itself.
Recycling and incineration count as destruction
Destruction means intentionally damaging a product or discarding it as waste. Recycling, other recovery including energy recovery, and disposal all sit inside that. The carve-out is narrow: discarding for the sole purpose of delivering the product for preparation for re-use or for remanufacturing.
An annual disclosure comes with it
Since 19 July 2025, large companies disclose each year how many unsold consumer products they discarded: number and weight, the reasons, and which treatment route the items took. That obligation reaches wider than the ban, because it covers all categories of consumer products and not only textiles.
What is left
The list is short, and the question is asked per item.
The regulation publishes no list of permitted destinations. It prohibits destruction and describes what falls outside that definition. What remains is narrow.
Does not count as destruction
- Sale or transfer to a new consumer
- Delivery for preparation for re-use
- Delivery for remanufacturing
Counts as destruction
- Recycling
- Incineration, including with energy recovery
- Landfill and other disposal
- Intentional damaging
An annual total is not substantiation. The question you need to answer is about a single item: where did this piece go, and along which route.
Regulation (EU) 2024/1781, Article 2(36) and Article 25What gets recorded
Forwarding leaves a record behind for every return.
A Forward moves from one consumer to the next. To carry that out, the process records what was sent, by whom, to whom and when, whether you need it for reporting or not. That is the same information required to show, per item, where it went.
- Item
- SKU, description and quantity, as submitted with the return request.
- Weight
- Per item, from your own product data. Alongside the count, this is the unit the disclosure is expressed in.
- CN code
- The combined nomenclature code the item falls under, which is what the reporting breakdown is built on.
- Sender to recipient
- Which consumer sent it and which consumer received it, with no stop at the warehouse in between.
- Carrier
- The carrier and the tracking details of the shipment.
- Timestamps per step
- Registration, label creation, drop-off and arrival.
- Condition on arrival
- The recipient's confirmation that the item arrived, and in what condition.
- Item
- SKU, description and quantity.
- Weight
- Per item, from your product data.
- CN code
- The code the reporting breaks down on.
- Sender to recipient
- Which consumer sent it, which received it.
- Carrier
- Carrier and tracking details.
- Timestamps per step
- Registration, label, drop-off, arrival.
- Condition on arrival
- The recipient's confirmation.
This covers the returns that run through Forwarding. For the rest of your unsold stock, your own records remain the source.
Export
Pulled per period, in the layout the disclosure follows.
You pull the record for whatever period you need, usually your financial year. The breakdown follows the prescribed format, so it lines up with the reporting you already produce instead of sitting beside it.
- Per period
- Start and end date of your choosing, matching the financial year you report on.
- Broken down by CN code
- The implementing regulation delimits the disclosure by the first two digits of the CN code, and by four digits for the product groups it names separately. Forwarding records the code per item, so both levels can be derived.
- Counts and weight
- Per code, the number of items and the weight, the two units the disclosure is expressed in.
- In the field structure of the prescribed format
- The same layout as the format set out in the implementing regulation, which applies to financial years from 2 March 2027.
Note the distinction: the Article 24 disclosure covers discarded products. An item that reaches a new consumer through Forwarding has not been discarded. This export therefore documents the route those items did take, in the same layout as the disclosure.
Cost
Every other measure around this regulation is a cost line.
Holding stock, sorting, standing up a second-hand channel, building a recording layer: they are all outlays to be able to show that you are not destroying. Of that set, Forwarding is the only measure that lowers the cost of a return rather than raising it, and leaves the evidence behind while doing so. What you end up with is not a separate compliance project but a return flow that documents itself.
Frequently asked questions
Who falls under the ban, and when?
Large companies since 19 July 2026. Medium-sized companies from 19 July 2030. Micro and small companies are exempt. That sits in Article 25 of Regulation (EU) 2024/1781. The Article 24 disclosure obligation does not run on the same clock: it has applied to large companies since 19 July 2025, and it covers all categories of consumer products.
Does recycling count as destruction?
Yes. Destruction means intentionally damaging a product or discarding it as waste. Recycling, other recovery including energy recovery, and disposal all sit inside that. Only discarding for the sole purpose of delivery for preparation for re-use or for remanufacturing falls outside the definition. See Article 2(36) and Article 25.
Are consumer returns unsold consumer products?
Yes. Article 2(37) names, alongside stock surplus and dead inventory, the products a consumer has returned under their right of withdrawal, or within a longer withdrawal period the seller offers itself. A return you subsequently discard is therefore the destruction of an unsold consumer product.
Are there exemptions to the ban?
Yes, and they are bounded. The delegated regulation on exemptions covers cases such as danger to health or safety, damage or defects that make repair unworkable, infringement of intellectual property rights, and products offered for donation without being taken up. Anyone relying on an exemption has to substantiate it and keep that substantiation.
What do you get if you start today?
From the first Forward, a record per item, exportable over any period you choose. It does not work retroactively: returns already handled before you start are not in it.
Does this make our brand compliant?
No. This covers the returns that run through Forwarding, not your entire stock. For your other unsold products you need your own route and your own substantiation. What we provide is the record for the part that goes through us.
Sources
- Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products)
- Article 2(36) and 2(37) (definitions), Article 24 (disclosure), Article 25 and Annex VII (prohibition on destruction).
- Implementing Regulation (EU) 2026/2
- The format for disclosing discarded unsold consumer products, applying from 2 March 2027.
- Delegated Regulation (EU) 2026/296
- The bounded exemptions to the destruction ban and the substantiation they require.
This is general information about the regulation and not legal advice.
Last updated: August 2026
Further reading
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