In short
- Two conditions, and both have to be true: the product sits in Annex VII, and your enterprise is large.
- Micro and small enterprises are excluded. Medium-sized enterprises come into scope on 19 July 2030.
- The prohibition is on destroying. The separate annual disclosure duty is triggered by discarding, which is a wider act.
Two conditions decide it and both have to be true. First, the goods are unsold consumer products listed in Annex VII to Regulation (EU) 2024/1781, which for this sector means apparel, clothing accessories and footwear. Second, your enterprise is large. Since 19 July 2026 a large enterprise may not destroy those goods. Micro and small enterprises are excluded outright and medium-sized enterprises come into scope on 19 July 2030. If you sell clothing or shoes in the EU and you write off stock, run the size test today, because the prohibition is already live.
The wording that matters is short. Article 25 says: "From 19 July 2026, the destruction of unsold consumer products as listed in Annex VII shall be prohibited." Everything else on this page is about who that sentence reaches.
What exactly is the product test?
Annex VII, category one, and it is defined by customs codes rather than by how you describe your range.
The category is "Apparel and clothing accessories", and our verified record of its coverage is Combined Nomenclature heading 4203, chapters 61 and 62, and headings 6504 and 6505, together with footwear. Those are the same codes that already appear on your import and export declarations, which makes the check unusually easy: pull the codes your customs agent uses for your top-selling lines and compare.
Two honest caveats. Our fact base records the codes and does not gloss them, so if a product sits on a boundary, for example a bag, a belt or a technical accessory, the classification your own declarations use is a better guide than any summary, including this one. And Annex VII contains categories beyond apparel that we have not verified, so if you sell outside clothing and footwear, do not read a no from this page.
What exactly is the size test?
Enterprise size, assessed under the EU size categories, and it produces four different answers.
| Your enterprise | Position on the destruction ban | What that means today |
|---|---|---|
| Micro | Excluded | The prohibition does not reach you, and no end date to that exclusion is recorded |
| Small | Excluded | Same as above |
| Medium-sized | In scope from 19 July 2030 | Out today, in later, with a fixed date to plan against |
| Large | In scope now, since 19 July 2026 | The prohibition has already applied for more than a year |
One thing we cannot give you from our own verified file: the numeric thresholds separating small from medium from large. The regulation points at the standard EU definition of enterprise size and our fact base does not record those figures, so read them from that definition rather than from a summary page. The one size test we do hold verbatim comes from the neighbouring textiles producer responsibility directive, which speaks of enterprises employing fewer than 10 persons whose annual turnover and annual balance sheet do not exceed EUR 2 million. That is a micro test in a different instrument and it is not the ESPR threshold, so treat it as a landmark rather than an answer.
The practical trap is group structure. Whether size is measured at your operating company or across a group changes the answer for a lot of mid-sized brands, and it is exactly the kind of question that deserves ten minutes with the definition itself rather than a guess.
If the ban does not reach you, does anything else?
Possibly. There is a second obligation next door and it is triggered by a different act.
Article 24 of the same regulation requires economic operators that discard unsold consumer products to disclose, annually and on an easily accessible page of their own website, what they discarded and what happened to it. The size exclusions are the same: not micro, not small, and medium-sized enterprises from 19 July 2030.
The difference in trigger is worth noticing. The prohibition bites on destruction. The disclosure bites on discarding, which is the wider act. A large enterprise that never destroys a garment but does write stock off and move it out of inventory should read Article 24 carefully rather than assume the whole topic is closed.
What if you genuinely do not destroy anything?
Then you comply, and you still have a records problem.
Most brands do not personally destroy stock. They hand it to a clearance broker, a returns processor or a waste contractor, and what happens after that is contractual rather than observed. If somebody in your chain shreds or incinerates goods you owned, saying you did not know is not a strong position and it is not evidence of anything.
The useful first step is not legal. It is to ask each disposal counterparty, in writing, what treatment route your goods actually took last year, by weight. That question is usually harder to answer than people expect, and the answer is the foundation for both the prohibition and the disclosure.
What are we not able to tell you here?
Four things, and we would rather name them than hedge.
Our verified file does not record penalties or the enforcing authority for these articles, so we do not state either. It does not record how returned, damaged, recalled or counterfeit goods are treated, which is the most common follow-up question in this sector. It does not record whether specific treatment routes such as fibre recycling count as destruction. And it records no first publication date and no fixed annual date for the Article 24 disclosure. On all four, go to the regulation itself or to a lawyer, and do not accept a confident answer from a summary page that has not shown you its source.
What do you do if you are in scope?
Three moves, in this order, and none of them is a software purchase.
Stop the flow first. Identify every route by which unsold goods currently leave your business and confirm what happens at the end of each one. Until that map exists, nothing else is reliable.
Fix the contracts. A clause requiring your disposal partners to report treatment route by weight, and to exclude destruction for Annex VII goods, does more compliance work than any internal policy.
Build the record. The annual disclosure runs on units, weights, types and treatment routes. Those numbers come from stock and waste records, not from a sustainability system, and the first year is always the hard one.
What do you do if you are out of scope?
Legally, nothing. Commercially, two things are still worth doing.
If you are medium-sized, 19 July 2030 is a real date and the work above takes longer than the compliance itself. If you are micro or small, the exclusion is genuine and you should not let a supplier questionnaire talk you into treating it otherwise.
What does reach a smaller brand is the commercial layer: retailers and wholesale customers collecting value chain data for their own reporting, and increasingly asking for it in a standard format such as the VSME standard. Where those requests become disproportionate, our note on the value chain cap on ESG questions is the boundary to know. And if the same conversation turns into a claim on a swing tag, the rule with teeth is the environmental claims regime rather than this one, which is what our EmpCo claims checklist is for.
Where does Hedgehog fit, and where does it not?
Not on this rule, and we will not pretend otherwise.
This is a disposal prohibition plus a website disclosure of items, weights and treatment routes. It is not a greenhouse gas obligation and carbon accounting software does not discharge it. What the Hedgehog platform does is the organisational footprint that customers and claims regimes ask for, with over 20,000 emission factors and the option to add your own supplier-specific data. The platform page reports 5,000+ users and a free account needs no sales call.
The published limitation to weigh: a Mid-Market reviewer on G2 in June 2026 rated the platform 5 out of 5 and said they would like more integrations with other software in future, and Hedgehog itself says it has few integrations today. If your intention was to pipe stock and waste data straight out of an ERP, that is worth checking before you assume it. Where the work is defining boundaries and defending numbers, carbon footprint consulting is the right door.
Sources: Regulation (EU) 2024/1781, Articles 24 and 25 and Annex VII, the Hedgehog regulation fact base, and the Hedgehog platform page. Verified 28 August 2026.
Facts on this page were last verified on 2026-09-17.
