JX Apparel Group
JX Apparel Group
Large companies selling into the EU have been prohibited from destroying unsold apparel, clothing accessories and footwear since 19 July 2026 — against a European backdrop in which an estimated 264,000 to 594,000 tonnes of textiles are destroyed every year before anyone wears them.
The prohibition sits in Article 25 of Regulation (EU) 2024/1781 and it does not bind everyone. Micro and small enterprises are outside it, medium-sized enterprises are phased in on 19 July 2030, and only large companies are caught today. That distinction is the first thing a contemporary outerwear label needs to settle, because the threshold most widely quoted in secondary coverage is the wrong one — and getting it wrong sends a brand into compliance spending four years early or, worse, leaves a genuinely large one exposed.
A coat that never sold can no longer be shredded, landfilled or burned for energy by a large company selling into the EU. Annex VII does the scoping work, and it does it by customs code rather than by product description: CN 61 and CN 62 between them cover every knitted and every woven article of apparel, which means every wool overcoat, every quilted parka and every tailored blazer.
The provision that catches brands out is not Article 25 but Article 2(34), which defines destruction as intentional damaging or discarding as waste, with exactly one exception — discarding for the sole purpose of preparing the product for reuse, including refurbishment or remanufacturing. Everything else that ends a garment's life as a saleable item falls inside the definition.
That is a narrower escape hatch than most operational recycling programmes assume. Sending a season's unsold outerwear to a fibre recycler is a legitimate waste-hierarchy outcome, but it is not preparation for reuse, and the regulation does not treat it as one. Brands already working through EU textile EPR obligations for coat brands are dealing with the post-consumer end of the same policy programme; this provision reaches stock that never left the warehouse.
Only one route out of a warehouse is not destruction: preparing the garment for reuse.
| Metric | Value | Source |
|---|---|---|
| Destruction ban: operative provision and application date | Article 25(1) — from 19 July 2026 the destruction of unsold consumer products listed in Annex VII is prohibited | EUR-Lex — Regulation (EU) 2024/1781, Article 25(1) |
| Commission confirmation that the prohibition is operative | Large companies across the EU have been prohibited from destroying unsold clothes, clothing accessories and footwear since 19 July 2026 | European Commission, DG Environment (17 July 2026) |
| Annex VII category 1 — apparel and clothing accessories, by CN code | CN 4203 (leather apparel and accessories), CN 61 (knitted or crocheted apparel and accessories), CN 62 (apparel and accessories not knitted or crocheted), CN 6504 and CN 6505 (hats and other headgear) | EUR-Lex — Regulation (EU) 2024/1781, Annex VII |
| Annex VII category 2 — footwear, by CN code | CN 6401, 6402, 6403, 6404 and 6405 — waterproof, rubber or plastic, leather-upper, textile-upper and other footwear | EUR-Lex — Regulation (EU) 2024/1781, Annex VII |
| Legal definition of "destruction" | Article 2(34) — intentional damaging or discarding of a product as waste, excepting only discarding for the sole purpose of delivering it for preparing for reuse, including refurbishment or remanufacturing | EUR-Lex — Regulation (EU) 2024/1781, Article 2, point (34) |
ESPR is Regulation (EU) 2024/1781, adopted 13 June 2024, published in the Official Journal on 28 June 2024 and in force from 18 July 2024 under Article 80. The destruction ban is one provision inside a much larger framework regulation.
The single most expensive misreading in circulation puts the trigger at 50 employees or EUR 10 million of turnover. That is the ceiling of the small-enterprise class under Commission Recommendation 2003/361/EC. A brand that grows past it does not become bound by the ban — it becomes medium-sized, and medium-sized enterprises are phased in on 19 July 2030.
ESPR itself never defines a large enterprise. The word does not appear in the regulation. Large is the residual: whatever is not micro, small or medium under 2003/361/EC. So the operative test runs the other way round — a company stays outside today's obligation while it employs fewer than 250 people and either turnover stays at or below EUR 50 million or the balance sheet total stays at or below EUR 43 million.
A contemporary outerwear label doing EUR 15–30 million with 40 staff is therefore almost certainly medium, not large, and has a four-year runway rather than a live prohibition. That runway is worth using, because the exemption underneath it is conditional: the Commission retains the power to extend the ban to micro and small enterprises where it finds larger companies routing unsold stock through them.
Crossing 50 employees makes a brand medium-sized. It does not make the ban apply.
| Metric | Value | Source |
|---|---|---|
| Enterprise-size carve-outs written into the prohibition | Micro and small enterprises: exempt. Medium-sized enterprises: bound from 19 July 2030 | EUR-Lex — Regulation (EU) 2024/1781, Article 25(1) |
| Where ESPR's size classes come from, and what it never defines | SME, small and micro definitions are those of Article 2(1)–(3) of the Annex to Commission Recommendation 2003/361/EC; ESPR contains no definition of a "large enterprise" at all | EUR-Lex — Regulation (EU) 2024/1781, Article 2 definitions and footnote 58 |
| Micro-enterprise ceiling | Fewer than 10 staff, and turnover or balance sheet total at or below EUR 2 million | European Commission, DG GROW — SME definition |
| Small-enterprise ceiling — the figure routinely misquoted as the ban's trigger | Fewer than 50 staff, and turnover or balance sheet total at or below EUR 10 million | European Commission, DG GROW — SME definition |
| Medium-enterprise ceiling | Fewer than 250 staff, and turnover at or below EUR 50 million or balance sheet total at or below EUR 43 million | European Commission, DG GROW — SME definition |
| The SME category ceiling, which is what makes a company "large" for ESPR purposes | An enterprise is an SME while it employs fewer than 250 persons and has turnover not exceeding EUR 50 million and/or a balance sheet total not exceeding EUR 43 million; exceeding that combined test makes it large, and therefore bound today | European Commission — User Guide to the SME Definition |
| Durability of the micro and small exemption | Current-state exemption, not a permanent carve-out — the Commission may bring micro and small enterprises inside the prohibition by delegated act where there is sufficient evidence they are being used to circumvent it | European Commission, DG Environment (17 July 2026) |
| National-authority restatement of the size thresholds (Germany) | The German Federal Environment Ministry applies the ban from 19 July 2026 to companies with at least 250 employees, or above EUR 50 million turnover and EUR 43 million balance sheet total | Bundesministerium für Umwelt, Naturschutz und nukleare Sicherheit |
The size test is applied at enterprise level under Recommendation 2003/361/EC, which aggregates linked and partner enterprises — a small brand inside a larger group may be assessed on the group's figures rather than its own.
Article 24 and Article 25 are separate obligations with separate start dates, and most secondary coverage collapses them into one. The prohibition runs from 19 July 2026. The disclosure duty runs from the regulation's entry into force on 18 July 2024, which means a calendar-year large company's first disclosure covers financial year 2025.
A third date sits between them. The standardised template published in Implementing Regulation C(2026) 660 becomes mandatory in February 2027. The duty to publish already exists; the common format is what arrives then. Disclosures made before that point are still owed — they simply are not yet on a prescribed form.
The publication channel is prescriptive in one direction only: at minimum, a clearly visible, easily accessible page on the company's own website. Companies already producing sustainability reporting under Articles 19a or 29a of Directive 2013/34/EU may fold the same information into that report instead.
The disclosure clock started in July 2024. The destruction clock started in July 2026. They are not the same obligation.
| Metric | Value | Source |
|---|---|---|
| Article 24(1) — the four things that must be disclosed | (a) number and weight discarded per year, differentiated by product type or category; (b) reasons for discarding, including any Article 25(5) derogation relied on; (c) proportion sent to preparing for reuse, recycling, other recovery and disposal; (d) measures taken and planned to prevent destruction | EUR-Lex — Regulation (EU) 2024/1781, Article 24(1) |
| Publication channel, frequency and the CSRD alternative | Annually, in a clear and visible manner at least on an easily accessible page of the operator's website; companies subject to Article 19a or 29a of Directive 2013/34/EU may instead include it in their sustainability reporting. Does not apply to micro and small enterprises | EUR-Lex — Regulation (EU) 2024/1781, Article 24(1) |
| First financial year covered by the disclosure duty | The first full financial year after ESPR's entry into force on 18 July 2024 — for a calendar-year company, FY2025 | European Commission — Implementing Regulation C(2026) 660 final, act text |
| Commission's own statement of which obligation is already running | The ban and derogations apply to large companies from 19 July 2026 and medium companies from 2030; the disclosure rules already apply to large companies and reach medium companies in 2030 | European Commission, DG Environment (9 February 2026) |
| Publication deadline relative to financial year-end (standardised-format phase) | Within 12 months after the end of the financial year concerned | European Commission — Implementing Regulation C(2026) 660 final, act text |
| Date the standardised disclosure format becomes mandatory | February 2027 — Article 7 fixes application at 12 months after the regulation's own entry into force | European Commission, DG Environment (9 February 2026) |
| Date the disclosure obligation reaches medium-sized enterprises | 19 July 2030 — the same date as the destruction-ban phase-in; there is no separate February 2030 disclosure date | European Commission — Implementing Regulation C(2026) 660 final, act text |
| Date both supplementing acts were adopted | 9 February 2026 — Delegated Regulation C(2026) 659 (derogations) and Implementing Regulation C(2026) 660 (disclosure format) | European Commission, DG Environment (9 February 2026) |
Disclosure and destruction are also scoped differently. Article 24 disclosure covers the 44 product categories in Annex II of the Implementing Regulation, a cross-sector list; the Article 25 prohibition covers only ESPR Annex VII — apparel, clothing accessories and footwear.
The Commission's template settles a question the base regulation leaves open. In Annex I, the operator reports percentages across preparing for reuse, recycling, other recovery, disposal, total destruction and unknown — and a footnote states that destruction is the sum of recycling, other recovery and disposal.
That is counter-intuitive and it matters commercially. A brand that routes 3,000 unsold coats to a fibre recycler and reports it as a circular outcome will find the same tonnage sitting in its published destruction percentage. Only preparing for reuse, including refurbishment and remanufacturing, keeps the volume out of that figure.
Annex II sets the reporting granularity at four-digit CN code across 44 product categories, of which apparel is a small part — the list runs from soap and tyres to mattresses, monitors and nappies. Components, intermediate products and goods not primarily intended for consumers are outside it, which excludes fabric rolls and trims sitting in a factory's warehouse.
Send unsold coats to a fibre recycler and the Commission's own form counts it as destruction.
| Metric | Value | Source |
|---|---|---|
| What the Implementing Regulation requires operators to report | Number and weight discarded in the previous financial year, reasons for discarding, applicable derogations, proportion sent to each waste-treatment operation, and prevention measures taken and planned — reported by product category at four-digit CN level | European Commission — Implementing Regulation C(2026) 660 final, act text |
| Annex I — the actual fields on the disclosure form | Product category (CN code); description; number of units discarded; total weight discarded (kg); whether packaging is included in that weight; reason for discarding; and percentages for preparing for reuse, recycling, other recovery, disposal, total destruction and unknown | European Commission — Implementing Regulation C(2026) 660 final, Annexes I and II |
| How the form defines total destruction | Destruction is the sum of recycling, other recovery and disposal; percentages are calculated on the weight of discarded unsold consumer products | European Commission — Implementing Regulation C(2026) 660 final, Annexes I and II |
| Number of product categories in the disclosure scope | 44 CN-code categories in Annex II — not the "50+" figure that circulates in secondary summaries | European Commission — Implementing Regulation C(2026) 660 final, Annexes I and II |
| Breadth of the disclosure list versus the destruction ban | Annex II spans soap and detergents (3401–3402), tyres (4011), luggage (4202), leather and furskin apparel (4203, 4303), household textiles (6301–6307), appliances, computers, phones, audio-video equipment, lighting, cameras, furniture and mattresses (9401–9404), toys (9503–9504) and sanitary articles (9619) — while the destruction ban covers only ESPR Annex VII | European Commission — Implementing Regulation C(2026) 660 final, Annexes I and II |
Annex II excludes components, intermediate products and goods not primarily intended for consumers. Deadstock fabric, interlining and trims held at a factory are outside the disclosure categories — but finished coats a brand owns and writes off are inside them.
Two lists are in circulation and they are not the same list. ESPR Article 25(5) sets out seven grounds on which the Commission may permit destruction. The adopted Delegated Regulation elaborates those into ten specific, checkable circumstances lettered (a) to (j) in its Article 2. Anyone quoting a single number without saying which instrument it comes from is merging two documents.
Every ground is conditional on documentation. Article 3 requires the operator to keep the supporting records for five years after destruction and to put them in front of a competent authority, electronically, within 30 days of a request. A derogation a brand cannot evidence is a derogation it does not have. The record-keeping discipline is the same discipline that produces the GPSR technical documentation a China factory must supply, and the two files are worth building on one system rather than two.
The donation ground is the one most often misdescribed. It is a last resort, available only when none of grounds (a) to (g) applies, and it offers two alternative routes — a direct offer to at least three suitable social-economy entities in the EU, or publication on an accessible page of the operator's own website for at least eight weeks. France shows what supervision of this kind looks like in practice: its AGEC ban has run since January 2022, and the DGCCRF's first combined control campaign checked around 600 establishments, 113 of them in textiles.
A derogation you cannot evidence within 30 days is not a derogation.
| Metric | Value | Source |
|---|---|---|
| Statutory derogation grounds in the base regulation | Seven grounds under Article 25(5): (a) health, hygiene and safety; (b) damage not cost-effectively repairable; (c) unfitness for intended purpose; (d) non-acceptance of products offered for donation; (e) unsuitability for preparing for reuse or remanufacturing; (f) unsaleability due to IP infringement or counterfeiting; (g) destruction is the least environmentally damaging option | EUR-Lex — Regulation (EU) 2024/1781, Article 25(5) |
| Operative derogations in the adopted Delegated Regulation | Ten circumstances, (a) to (j): dangerous product; non-compliant with law; IP infringement; expired protective licence; technically unsuitable for reuse or remanufacturing; unacceptable due to damage, deterioration or contamination; design or manufacturing defect; unaccepted after donation offer; unplaceable after receipt by a social-economy entity; unplaceable after preparation for reuse by a waste treatment operator | European Commission — Delegated Regulation C(2026) 659 final |
| Donation derogation — the two alternative routes | Available only where none of grounds (a) to (g) applies, and requires either a direct offer to at least three suitable social-economy entities located in the Union, or publication on an easily accessible page of the operator's own website for at least eight weeks — with the product not accepted in either case | European Commission — Delegated Regulation C(2026) 659 final |
| Retention period for derogation documentation | Five years after the product was destroyed | European Commission — Delegated Regulation C(2026) 659 final |
| Window to produce that documentation on request | 30 days from receipt of the competent authority's request, in electronic form | European Commission — Delegated Regulation C(2026) 659 final |
| France: national ban on destroying unsold non-food goods, in force since | 1 January 2022 for product categories already covered by extended producer responsibility, which includes clothing and textiles | Ministère de la Transition écologique — archived press release |
| France: administrative fine ceiling per infringement | Up to EUR 3,000 for an individual and EUR 15,000 for a legal entity | Cabinet Gossement Avocats, quoting Article L.541-15-8 du code de l'environnement |
| France: first DGCCRF control campaign on the unsold-goods destruction ban | About 600 establishments checked in 2024 (471 food, 113 textile), results published 17 November 2025; 5% drew corrective or punitive action — two criminal referrals, 21 compliance injunctions and around 100 warnings | DGCCRF results, reported by actu-environnement and the Fédération Nationale des Marchés de France |
ESPR does not set penalty levels. Enforcement and sanctions sit with member-state market surveillance authorities, which is why the only concrete fine figures available are national ones. Any single EU-wide percentage-of-turnover penalty attributed to this ban is a conflation with other legislation. The DGCCRF campaign figures are press reporting of an authority campaign rather than the authority's own release.
The ban redirects volume rather than eliminating it, and the receiving infrastructure is smaller than the flow. Europe puts roughly six million tonnes of new textiles on the market each year. Sorting capacity across the continent was estimated at 560,000 tonnes for 2025 and recycling capacity at 1.3 million tonnes — and of everything that reaches recycling, only 16,000 to 25,000 tonnes comes back out as new clothing.
Against that, the European Environment Agency's modelled estimate puts destruction of unsold textiles at 264,000 to 594,000 tonnes a year. The upper end of that range alone is close to the whole continent's annual sorting capacity.
For a brand, the practical consequence is that donation and resale routes need to be arranged before a season ends, not after. Social-economy entities decline stock they cannot move, and the derogation clock in Article 2(h) only starts once an offer has actually been made. Where recycled-content claims sit alongside the disposition record, the GRS and BSCI certifications held by the factory are the audited scaffolding those claims rest on.
One widely repeated figure about where used textiles end up needs a caveat attached to it. The EU Strategy for Sustainable and Circular Textiles, COM(2022) 141, is cited across EU-facing sources for a 2022 baseline of up to 2.1 million tonnes a year separately collected for recycling or resale — about 38% of the textiles placed on the EU market, leaving roughly 62% believed to go into mixed waste streams. Those three numbers could not be confirmed against the Commission document itself: eur-lex.europa.eu was unreachable throughout the research for this article, so the figure is reproduced here as indicative of the scale of the collection gap, not as a verified measurement, and it is deliberately kept out of this page's key takeaways, chart and summary table.
Europe can sort about 560,000 tonnes of textiles a year. The high estimate for unsold destruction alone is 594,000.
Capacity figures are 2025 estimates from a survey of around 30 European operators; destruction figures are a modelled range, not a measured total. The chart compares annual flow against annual capacity and is not a waste-fate breakdown.
| Metric | Value | Source |
|---|---|---|
| Share of textiles placed on the EU market destroyed before use | An estimated 4–9%, or 264,000–594,000 tonnes a year (modelled estimate, built on 2020 consumption data) | EEA / ETC CE Report 2024/4 |
| Greenhouse-gas cost attributed to that destruction | Up to 5.6 million tonnes CO2-equivalent a year — explicitly the upper-bound scenario, combining the highest destruction share with the highest emissions factor | EEA / ETC CE Report 2024/4 |
| Germany: returned items discarded each year | Nearly 20 million returned items discarded annually | European Commission, DG Environment (9 February 2026) |
| European sorting and recycling capacity | About 560,000 tonnes a year of textile sorting capacity and 1.3 million tonnes a year of post-consumer textile recycling capacity (2025 estimates) | IVL Swedish Environmental Research Institute |
| Volume placed on the European market versus what returns as new clothing | Six million tonnes of new textiles placed on the European market each year; only around 16,000–25,000 tonnes of what goes to recycling becomes new clothes, and about 1% of clothes produced are made from recycled textiles | IVL Swedish Environmental Research Institute |
| Collection and fibre-to-fibre recycling rates for used clothing | Less than half of used clothes are collected for reuse or recycling; only 1% are recycled into new clothes | European Parliament (Members' Research Service), "Textiles and the environment", 4 May 2022 |
| Post-consumer textile collection volume relative to the EU market — unverified, see caveat above | Up to 2.1 million tonnes a year separately collected for recycling or resale, about 38% of textiles placed on the EU market, with roughly 62% believed to go into mixed waste streams (2022 baseline) | European Commission — EU Strategy for Sustainable and Circular Textiles, COM(2022) 141 final |
Every EEA figure in this section is a modelled estimate rather than a measured audit. The COM(2022) 141 row could not be confirmed against the primary document during research and is retained only with the caveat set out above. The European Parliament briefing names no underlying study for its collection and recycling rates.
Article 24(1)(d) asks for measures taken and planned to prevent destruction. That field is where production discipline becomes a compliance asset rather than an operations preference — and it is answered with records, not intentions.
A Jiaxing coat factory already generates most of what the answer needs. Cut tickets give units cut per style and colour; packing lists give units shipped; the gap between them is the cut-to-ship ratio, which a factory-audit study across eight Delhi-region plants put at 95–99%. Marker efficiency and end-of-roll reports give fabric overage. Reject and second-quality logs give the volumes that never reached the brand at all. Asking for those five records as standing deliverables costs nothing and produces an evidence trail that pre-dates any authority request.
Order quantity is the other half. The literature average for unsold textile stock is 21%, and roughly a fifth of that is destroyed. A 200-piece-per-style-per-colour minimum with a 15–25 day bulk reorder after PP approval lets a brand buy into demand rather than pre-buying a season it may later have to justify discarding — which is why how coat order minimums actually stack is a compliance question as much as a costing one. Nothing about that is a workaround; it simply reduces the number of coats that ever enter the disclosure table.
The cheapest compliance record is the one your factory already prints: units cut versus units shipped.
| Metric | Value | Source |
|---|---|---|
| Prevention duty that production planning answers | Operators must disclose measures taken and planned to prevent the destruction of unsold consumer products — a qualitative duty, with no numeric target | Freshfields Bruckhaus Deringer LLP |
| Average share of textile products that go unsold, and how much of it is destroyed | 21% of textile products go unsold on average, and around one fifth of that unsold stock ends up destroyed | EEA / ETC CE Report 2024/4 |
| Average return rate for clothing bought online in Europe | About 20% — one in every five garments sold online is returned | EEA / ETC CE Report 2024/4 |
| Share of returned online clothing that ends up destroyed | 22–43%, on average about one third | EEA / ETC CE Report 2024/4 |
| US online return rate, for directional comparison | 19.3% of US online sales estimated to be returned in 2025 | National Retail Federation and Happy Returns, 2025 Retail Returns Landscape |
| Cut-to-ship ratio observed in factory audits | 95–99%, with six of eight audited factories at 96–97% | Methods Apparel Consultancy India / OGTC, reported by Apparel Resources |
| Fabric discarded in the cut-and-sew process | 10–15% of fabric, on a widely cited older estimate that a 2024 academic review suggests understates the true current figure | Bren School of Environmental Science & Management, UC Santa Barbara |
Five records a brand can ask its factory to supply as standing deliverables, each mapping to a field on the Commission's disclosure form: cut tickets showing units cut per style and colour; packing lists showing units shipped; marker efficiency and end-of-roll fabric reports; deadstock and leftover fabric records; and reject and second-quality quantities with their disposition. None requires new systems — they are outputs a garment factory already produces for its own costing. The 95–99% cut-to-ship range is a consultancy figure reported in trade press, not a peer-reviewed measurement, and the US return rate is an all-category retailer-survey estimate with no EU compliance weight.
| Metric | Value | Source |
|---|---|---|
| Destruction ban in force for large companies | Since 19 July 2026 (ESPR Article 25(1)) | EUR-Lex — Regulation (EU) 2024/1781, Article 25(1) |
| Medium-sized enterprise phase-in | 19 July 2030 | EUR-Lex — Regulation (EU) 2024/1781, Article 25(1) |
| Micro and small enterprises | Exempt from the ban and from the Article 24 disclosure duty, subject to Commission power to extend the ban by delegated act | European Commission, DG Environment (17 July 2026) |
| Small-enterprise ceiling (routinely misquoted as the ban trigger) | Fewer than 50 staff and turnover or balance sheet at or below EUR 10 million | European Commission, DG GROW — SME definition |
| Medium-enterprise ceiling | Fewer than 250 staff and turnover at or below EUR 50 million or balance sheet at or below EUR 43 million | European Commission, DG GROW — SME definition |
| Threshold at which a company becomes "large" and is bound today | Beyond the SME test: 250 or more staff, or turnover above EUR 50 million and balance sheet above EUR 43 million | European Commission — User Guide to the SME Definition |
| Product scope of the ban | ESPR Annex VII: CN 4203, 61, 62, 6504, 6505 (apparel and accessories) and CN 6401–6405 (footwear) | EUR-Lex — Regulation (EU) 2024/1781, Annex VII |
| Legal definition of destruction | Article 2(34): intentional damaging or discarding as waste, excepting only discarding for preparing for reuse | EUR-Lex — Regulation (EU) 2024/1781, Article 2, point (34) |
| How the disclosure form calculates destruction | Total destruction = recycling + other recovery + disposal; only preparing for reuse is excluded | European Commission — Implementing Regulation C(2026) 660 final, Annexes I and II |
| Disclosure content required by Article 24(1) | Number and weight discarded; reasons and derogations relied on; proportions by waste-treatment route; prevention measures taken and planned | EUR-Lex — Regulation (EU) 2024/1781, Article 24(1) |
| First financial year covered by the disclosure duty | First full financial year after entry into force on 18 July 2024 — FY2025 for calendar-year companies | European Commission — Implementing Regulation C(2026) 660 final, act text |
| Standardised disclosure format becomes mandatory | February 2027 | European Commission, DG Environment (9 February 2026) |
| Product categories in the disclosure scope | 44 CN-code categories (Annex II, Implementing Regulation C(2026) 660) | European Commission — Implementing Regulation C(2026) 660 final, Annexes I and II |
| Derogation grounds in the base regulation vs the delegated act | 7 statutory grounds (a)–(g) under ESPR Article 25(5); 10 operative circumstances (a)–(j) under Article 2 of Delegated Regulation C(2026) 659 | European Commission — Delegated Regulation C(2026) 659 final |
| Documentation retention and production window | 5 years after destruction; produced electronically within 30 days of an authority's request | European Commission — Delegated Regulation C(2026) 659 final |
| France: national destruction ban and first control campaign | In force since 1 January 2022; around 600 establishments checked in 2024 (113 textile), 5% drew corrective or punitive action | DGCCRF results, reported by actu-environnement and the Fédération Nationale des Marchés de France |
| Textiles destroyed before use in Europe | An estimated 4–9%, or 264,000–594,000 tonnes a year (modelled) | EEA / ETC CE Report 2024/4 |
| European textile sorting and recycling capacity | 560,000 tonnes sorting and 1.3 million tonnes recycling capacity (2025 estimates); 16,000–25,000 tonnes becomes new clothes | IVL Swedish Environmental Research Institute |
Every figure in this reference was traced to a primary document and read in that document, not taken from a search summary. The legal provisions come from the consolidated text of Regulation (EU) 2024/1781 and from the two acts adopted on 9 February 2026 — Commission Delegated Regulation C(2026) 659 on derogations and Commission Implementing Regulation C(2026) 660 on the disclosure format — both downloaded as adopted-text PDFs from the European Commission's own document store and read in full, including their annexes. Enterprise-size thresholds come from the Commission's own implementation of Recommendation 2003/361/EC and from its User Guide to the SME Definition. Volume estimates come from the European Environment Agency's ETC CE Report 2024/4 and are modelled figures built on 2020 consumption data, labelled as such wherever they appear. Eight candidate figures were dropped during verification because the source named for them did not contain them, or because a primary source contradicted them.
Primary legal texts and institutional sources (Tier 1)
Professional analysis and academic sources (Tier 2)
Reported and consensus sources (Tier 3)
Last updated: September 2026. Reviewed quarterly. The European Environment Agency figures (4–9% destroyed, 264,000–594,000 tonnes, 20% return rate, 22–43% of returns destroyed, 21% unsold, up to 5.6 million tonnes CO2-equivalent) come from ETC CE Report 2024/4, published 4 March 2024 and built on 2020 consumption data; they are modelled and literature-average estimates, not measured audits. The 5.6 million tonnes CO2-equivalent figure is the upper bound of that modelled range. Enterprise-size thresholds derive from Commission Recommendation 2003/361/EC, which remains the operative definition incorporated by ESPR. The 10–15% cut-and-sew fabric waste range traces back through a 2005 paper to a 1997 textbook estimate, and the 2024 UC Santa Barbara report carrying it states that its own expert interviews suggest the current figure is higher. IVL's sorting and recycling capacity numbers were published in 2023 as estimates for 2025. US return figures are 2025 retailer-survey estimates covering all retail categories and are used only as directional contrast. This page will be revised when Delegated Regulation C(2026) 659 and Implementing Regulation C(2026) 660 appear in the Official Journal with final numbering and a fixed application date.
Written by
Ray Wang
Women's outerwear manufacturing specialist with 13 years of experience producing wool, cashmere, and down coats for fashion brands across Europe and North America at JX Apparel Group in Jiaxing, China.
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