ESPR Article 26 Record-Keeping: Unsold Textile Volumes That Show Up in CSRD

The ban is also a record‑keeping duty

Article 26 of the European Sustainable Products Regulation (ESPR) does more than prohibit the destruction of unsold consumer products. It creates a parallel obligation: every brand that places textiles, clothing, accessories or footwear on the market must keep a verifiable record of what happens to those items once they leave the sales channel. The regulation treats the record‑keeping requirement as a core compliance element because the data will be inspected by national authorities and will feed directly into the Corporate Sustainability Reporting Directive (CSRD) disclosures. In practice, this means that the same system used to track inventory must also capture the final disposition of each unsold lot.

Who must keep records from which date

The scope is defined by company size. Large enterprises – those employing more than 250 people or generating a turnover above €150 million – are subject to the ESPR obligations from 19 July 2026. Small‑ and medium‑sized enterprises (SMEs) have a one‑year grace period and must comply from 19 July 2027. All of these entities, regardless of whether they manufacture or simply distribute, must record the fate of every unsold textile, clothing, accessory or footwear item that falls under Annex II of the regulation.

What to log per unsold unit or lot

For each unsold unit or batch, the record must contain at least the following elements:

• Product identifier – SKU, style number, or any internal reference that uniquely ties the record to the physical item.
• Date of unsold status – the exact day the product left the sales channel (e.g., end‑of‑season clearance, store return, online stock‑out).
• Quantity – number of pieces and total weight (kilograms or tonnes) of the lot.
• Disposition method – one of the defined alternatives: donation, resale, repair, recycling for material recovery, or prohibited “destruction” (physical destruction, disposal, incineration, or rendering the product unusable).
• Partner details – name, VAT or registration number, and location of the third‑party organization that received the product (charity, reseller, recycler, etc.).
• Documentation reference – invoice, donation receipt, recycling certificate, or transport note that proves the action was carried out.

These data points must be stored in a format that allows auditors to trace a product from sale‑ready inventory to its final outcome without gaps.

Annual volume and weight disclosure

Each reporting year, the brand must aggregate the records and disclose two key metrics in its CSRD sustainability report:

1. The total volume (number of units) of unsold textiles, clothing, accessories and footwear that entered the ESPR‑covered pathway during the year.
2. The total weight of those items, broken down by the disposition method used (e.g., 12 % donated, 45 % recycled, 30 % resold, 13 % other).

The disclosure must be presented in a clear table or chart, accompanied by a brief narrative explaining any significant changes compared with the previous year (new donation partners, shifts toward repair, etc.). Because the CSRD requires third‑party verification, the underlying records must be accessible to auditors and regulators upon request.

Why the chosen alternative appears in the CSRD report

CSRD aims to provide stakeholders with transparent information on a company’s environmental impact and circular‑economy performance. By reporting the specific alternative chosen for each unsold lot, the brand demonstrates compliance with the ESPR’s circular‑product objectives and shows progress toward waste reduction targets. For example, a higher share of recycling indicates material recovery, while increased donation rates reflect social responsibility. The breakdown also allows investors and NGOs to assess whether the company is merely shifting waste downstream or genuinely closing loops in its supply chain.

How KadmilOS fits in

KadmilOS is built to meet the dual demands of ESPR record‑keeping and CSRD reporting. The platform integrates with ERP and warehouse‑management systems to capture the required product identifiers, dates and quantities automatically. It then enriches each record with disposition data from partner APIs (charity registries, certified recyclers, resale platforms) and stores the supporting documentation in a tamper‑evident repository. KadmilOS generates the annual volume‑and‑weight tables required by CSRD, complete with drill‑down capabilities for auditors. By centralising all data, the solution reduces manual entry, eliminates duplication, and ensures that every unsold textile lot is traceable from stockroom to final outcome.

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