Check the company and the goods.
ESPR is a framework with several obligations. The unsold clothing destruction ban has its own scope under Article 25 of Regulation (EU) 2024/1781.
Covered products
Annex VII lists apparel, clothing accessories and footwear by commodity code. It does not mean every category of unsold goods is covered by this ban.
Company size
The ban applies to large enterprises from 19 July 2026 and medium-sized enterprises from 19 July 2030. Micro and small enterprises are exempt; they cannot be used to circumvent the ban.
Specific derogations
Delegated Regulation (EU) 2026/296 sets conditions for exceptions. Damaged or unsold goods are not automatically eligible: the applicable conditions and evidence must be checked.
Keep usable goods in circulation.
The European Commission identifies sale, donation and preparation for reuse as alternatives to destruction. The appropriate route depends on the actual goods and legal requirements.
Sale
For saleable stock, review a commercial purchase with a defined lot and agreed resale restrictions.
Donation or reuse
Assess whether donation, repair, refurbishment or another reuse route is appropriate for the products.
Exceptions
Where destruction is being considered, check the specific derogation, evidence and waste-treatment requirements with your compliance team.
BenefitStock reviews purchases of new, known-brand footwear and apparel from 1,000 units. A purchase is a commercial transaction; it does not certify ESPR compliance.
A sale and compliance are separate decisions.
Article 24 addresses disclosure of discarded unsold consumer products. That obligation is separate from the Article 25 destruction ban. An NDA does not override statutory disclosure duties.
Assess your duties
Your legal or compliance team should establish company size, product scope, disclosure requirements and any applicable exception.
Keep the transaction record
Retain the actual purchase agreement, stock list, payment and collection records relevant to your transaction. Do not treat a sale document as a compliance certificate.
Explore a stock sale
Start with category, known brands, quantity and location. We arrange a mutual NDA before a detailed list and review whether a purchase is suitable.
FAQ
Questions before you sell
Does selling to BenefitStock make us ESPR compliant?
No. A stock sale does not certify compliance with ESPR or other product, waste or reporting rules. Your legal or compliance team must assess your obligations.
Does the ban cover all unsold goods?
No. Article 25 currently refers to the product groups and commodity codes in Annex VII. Check the actual goods against that list.
Are small businesses covered from July 2026?
Article 25 exempts micro and small enterprises and applies to medium-sized enterprises from 19 July 2030. Anti-circumvention rules still apply.
Do you buy damaged goods because they cannot be destroyed?
The regulation does not make goods commercially suitable for us. Our buying focus remains new, known-brand footwear and apparel; condition and the right to sell need review.