On the same day, the EU’s central Digital Product Passport (DPP) registry becomes operational. Together, these mark the arrival of Europe’s “circular compliance cliff”, a shift the European Commission confirmed on February *, ****, when it adopted the enabling delegated and implementing acts. The rule ends the era of quiet write-offs.
Overstock destruction, once the cheapest disposal route, now becomes a documented, reportable liability. For apparel brands, that permanently raises the strategic cost of over-ordering across a *,***-store European estate.
Cost and supply chain analysis
The ban removes the cheapest disposal route. Under the ESPR, “destruction” is defined broadly. It includes incineration for energy and direct-to-recycling shredding. Both are now prohibited for covered unsold goods, unless a narrow derogation applies. Only reuse, donation, repair and remanufacturing remain safely above the line. That mechanically forces brands into more expensive channels: sorting, resale contracts, donation logistics or fibre-to-fibre recycling.
