Summary

Until recently, what happened to fashion products after they were sold—or worse, never sold—was largely left to the discretion of brands and retailers. But this is changing rapidly. Across the EU, governments are tightening the rules around what happens to products at the end of their life, from how waste is collected and sorted, to how unsold stock is handled, and what data must be reported.

"Fashion brands have focused for years on trend, margin, and speed. Now, what happens to products after the sale, or without a sale, is a compliance issue. We have to change our mindset from not only focusing on what goes into the retail pipeline, but also what comes out the other end."

To be less abstract, here are the key themes brands need to start thinking about:

Products- All textile items will soon fall under mandatory take-back and recycling schemes. Brands must prove that their products are durable, repairable, and recyclable—and in some cases, penalised if they aren’t.

Waste- Disposal and destruction of unsold stock is no longer a silent choice. In some countries, it’s restricted or outright banned.

Reporting- Detailed data on volumes sold, collected, reused, recycled, or destroyed must be disclosed. In many cases, this includes publishing re-use and export rates.

This represents a systemic shift. It’s not just about designing for the first user, but also about planning for the product’s entire lifecycle. Your business model, logistics, and data systems are scrutinised from design to disposal. You should be looking to:

• Map Your Inventory Risk- Track your textile volume sold into each EU market and prepare for EPR fees on textile items.
• Think about Volumes- Many EU ESG legislations aim to reduce the volume of textile waste. Assess how your buying practices may increase compliance obligations.
• Sales Practices – Do you sell to retailers with Sale-or-Return contracts? How effective are your overstock and outlet strategies at diverting products from waste?

Legislations concerning End-of-Life

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Discover more Topics

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Stop

The destruction of unsold goods and prepare to demonstrate the product pathways to prove you do not destroy any goods.

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Start

Producer responsibility schemes for fashion are going mainstream. Brands will pay fees based on the volume and sustainability profile of their products placed on each national market.

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Continue

Build alignment with circularity strategies and transparency frameworks, such as digital product records, to streamline compliance across borders.

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Author

Bente Bauer

Founder & Director 2BPolicy

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Each Member State is implementing these rules at its own pace. What’s legally acceptable in one country might be banned in another. Stay alert and flexible.

What Should you be doing?

Brands

To remain compliant and competitive, brands must build end-of-life into product development and inventory management. Here’s how:

1. Understand the regulations
2. Adapt your buying & excess stock strategy – What used to go to landfill or incineration may now need alternative, verifiable end uses.
3. Collaborate on take-back – Engage with local Producer Responsibility Organisations and logistics providers to enable collection and sorting.
4. Design for reuse – Prioritise materials and finishes that enable second life use and make garments easier to sort and process at end-of-life.
5. Measure & report – Track what you sell, what comes back, and where it ends up. Transparency is no longer optional—it’s a requirement.

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Manufacturers

Manufacturers are can enable brands’ end-of-life compliance, especially for tracking materials,  enabling sorting, and supporting take-back:

• Prepare for product traceability – Be ready to support brands with their EPR reporting
• Report to your customers – Share data on rejections and B-quality items
• Suppliers – Understand EPR obligations and the possible Eco-modulated design requirements.

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