---
title: "ESPR unsold goods disclosure FAQ"
canonical_url: "https://www.sorena.io/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq/unsold-goods-disclosure"
source_url: "https://www.sorena.io/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq/unsold-goods-disclosure"
author: "Sorena AI"
description: "Standalone FAQ on the ESPR Article 24 duty to disclose discarded unsold consumer products, its relationship to the destruction ban, records, and source limits."
published_at: "2026-05-09"
updated_at: "2026-05-09"
keywords:
  - "ESPR"
  - "Regulation (EU) 2024/1781"
  - "Article 24"
  - "unsold consumer products"
  - "destruction of unsold goods"
---
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---

# ESPR unsold goods disclosure FAQ

Standalone FAQ on the ESPR Article 24 duty to disclose discarded unsold consumer products, its relationship to the destruction ban, records, and source limits.

*FAQ* *ESPR* *EU*

## ESPR unsold goods disclosure what Article 24 requires

ESPR Article 24 requires covered economic operators to publish annual information when they discard unsold consumer products directly or have them discarded on their behalf.

The disclosure file should separate the Article 24 reporting duty from the Article 25 destruction ban and avoid unsupported assumptions about product categories, exemptions, penalties, or national rules.

Under Regulation (EU) 2024/1781, unsold-goods disclosure is a specific public transparency duty for discarded unsold consumer products. It is not the same thing as the ban on destroying certain unsold products, and it should not be expanded beyond the products, operators, dates, evidence, and source text that ESPR actually supports. Timings in this page are source-linked; verify current legal source language before implementation decisions.

## What must be disclosed under ESPR Article 24?

Article 24 applies to economic operators that discard unsold consumer products directly or have those products discarded on their behalf. The disclosed information must cover the number and weight of discarded unsold consumer products per year, differentiated by product type or category.

The disclosure must also explain the reasons for discarding, identify any relevant Article 25(5) derogation where applicable, show the proportion delivered to preparing for reuse, refurbishment, remanufacturing, recycling, other recovery including energy recovery, or disposal, and describe measures taken or planned to prevent destruction.

- Publish the Article 24 information annually for the preceding financial year.
- Make the information clear, visible, and available at least on an easily accessible page of the operator's website.
- Treat the first disclosure as covering discarded unsold consumer products from the first full financial year during which ESPR is in force.
- Do not apply the Article 24 paragraph to micro and small enterprises; medium-sized enterprises are covered from 19 July 2030.

Sources for this answer:

- [Regulation (EU) 2024/1781, Article 24](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Grounds the Article 24 disclosure trigger, data fields, website-publication duty, annual timing, and micro, small, and medium-sized enterprise caveats.
- [European Commission - Ecodesign for Sustainable Products Regulation](https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_en?ref=sorena.io) - Commission overview confirming that large and eventually medium-sized companies must disclose annual website information such as number, weight, and reasons for discarded unsold consumer products.

## How does disclosure relate to the destruction ban?

Disclosure and prohibition are linked but separate. Article 24 requires publication of information about discarded unsold consumer products. Article 25 prohibits destruction only for unsold consumer products listed in Annex VII, and the initial Annex VII list covers apparel and clothing accessories plus footwear commodity-code entries.

Article 25 also says economic operators not subject to the prohibition must not destroy unsold consumer products supplied to them for the purpose of circumventing the prohibition. Article 25 lets the Commission amend Annex VII and set derogations, but this FAQ should not turn those powers into ungrounded current exemptions or extra product bans.

- Use Article 24 records to support disclosure even where the product is outside the current Annex VII prohibition list.
- Use Article 25 and Annex VII to decide whether a destruction-ban analysis is also needed.
- Do not state that all discarded unsold products are banned from destruction.
- Do not infer national penalties or enforcement practice from the Article 24 disclosure text.

Sources for this answer:

- [Regulation (EU) 2024/1781, Articles 24 and 25](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Supports the distinction between the Article 24 disclosure duty and Article 25 prohibition for Annex VII products, including the anti-circumvention rule.
- [Regulation (EU) 2024/1781, Annex VII](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Grounds the current Annex VII product groups as apparel and clothing accessories and footwear, with commodity-code descriptions in the ESPR text.
- [European Commission - New law to make products on the EU market more sustainable](https://commission.europa.eu/news-and-media/news/new-law-make-products-eu-market-more-sustainable-2024-07-19_en?ref=sorena.io) - Commission news summary explaining that ESPR bans destruction of unsold textiles and footwear and opens a path to similar bans in other sectors if evidence supports them.

## Which product and operator caveats matter most?

The first caveat is the product label. Article 24 is about unsold consumer products that are discarded; it is not a general disclosure rule for every inventory adjustment, write-down, component, intermediate input, return, or waste stream unless the facts fit that wording.

The second caveat is the operator size and role. Article 24 addresses economic operators that discard the products or have them discarded on their behalf. Micro and small enterprises are outside Article 24(1), while medium-sized enterprises enter the Article 24(1) duty from 19 July 2030. Article 25 separately allows delegated acts to apply the disclosure obligation or destruction prohibition to micro and small enterprises where evidence shows they could be used to circumvent those rules.

- Classify whether the item is an unsold consumer product before counting it in the Article 24 disclosure.
- Identify whether the economic operator discarded the product directly or through a third party acting on its behalf.
- Track enterprise-size assumptions separately from product-category assumptions.
- Keep group, marketplace, distributor, and supplier narratives out of the disclosure unless the source record shows the operator's actual role in the discard decision.

Sources for this answer:

- [Regulation (EU) 2024/1781, Article 24](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Grounds the economic-operator trigger, unsold consumer product framing, enterprise-size exclusions, and medium-sized enterprise timing.
- [Regulation (EU) 2024/1781, Article 25](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Supports the narrow caveat that delegated acts may apply Article 24 or Article 25 duties to micro and small enterprises where circumvention evidence is sufficient.

## What records and evidence should support publication?

Article 24 requires more than a public web page. If the Commission or a competent national authority asks, the operator must provide the information and documentation necessary to demonstrate delivery and reception of the discarded products disclosed under Article 24(1)(c), and where relevant the information needed to demonstrate an Article 25(5) derogation.

The evidence file should therefore tie the public disclosure back to product counts, product weight, product type or category, discard reasons, recipient or treatment route, waste-hierarchy activity, planned prevention measures, and any claimed derogation. Article 24 says that requested documentation must be provided in paper or electronic form within 30 days of receiving the request.

- Retain source data for the number and weight disclosed per product type or category.
- Keep records showing why products were discarded and which prevention measures were taken or planned.
- Preserve delivery and reception evidence for preparing for reuse, refurbishment, remanufacturing, recycling, recovery, energy recovery, or disposal routes.
- Keep derogation evidence separate and cite Article 25(5) only where the facts actually support one of the listed reasons.
- Archive the exact website disclosure text and publication location for each annual cycle.

Sources for this answer:

- [Regulation (EU) 2024/1781, Article 24](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Grounds the documentation request duty, delivery and reception evidence, derogation support, paper or electronic format, and 30-day response period.
- [European Commission - Ecodesign for Sustainable Products Regulation](https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_en?ref=sorena.io) - Commission overview supports the public website disclosure expectation and summarizes the disclosed fields as number, weight, and reasons for discarded products.

## Primary sources

- [Regulation (EU) 2024/1781 (ESPR)](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Primary legal source for Article 24 disclosure, Article 25 destruction prohibition, Article 26 consolidated Commission information, and Annex VII product entries.
  - Quote: "Disclosure of information on unsold consumer products"
- [European Commission - Ecodesign for Sustainable Products Regulation](https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_en?ref=sorena.io) - Commission overview used for the public-facing summary of ESPR unsold-goods measures and links to related ESPR materials.
  - Quote: "Rules to address destruction of unsold consumer products"
- [European Commission - New law to make products on the EU market more sustainable](https://commission.europa.eu/news-and-media/news/new-law-make-products-eu-market-more-sustainable-2024-07-19_en?ref=sorena.io) - Commission news summary used to cross-check the high-level relationship between disclosure duties and the ban on destroying unsold textiles and footwear.
  - Quote: "Companies will also be required to publicly disclose"

## Topic Guides

- [ESPR and DPP connection: delegated acts, identifiers, and access](/artifacts/eu/ecodesign-for-sustainable-products-regulation/espr-and-dpp-connection.md): How ESPR connects ecodesign information requirements to Digital Product Passports, including delegated acts, data carriers, identifiers, access rights, registry, and architecture choices.
- [ESPR Applicability Test for Products and DPP Readiness](/artifacts/eu/ecodesign-for-sustainable-products-regulation/applicability-test.md): A source-linked ESPR applicability test for physical product scope, exclusions, delegated-act dependency, economic operator triage, DPP readiness, unsold goods, and evidence.
- [ESPR compliance checklist for delegated acts and DPP readiness](/artifacts/eu/ecodesign-for-sustainable-products-regulation/checklist.md): A source-linked ESPR checklist for monitoring delegated acts, mapping product requirements, preparing technical documentation, and building DPP and unsold-goods evidence.
- [ESPR compliance program operating model](/artifacts/eu/ecodesign-for-sustainable-products-regulation/compliance-program-operating-model.md): Build an ESPR operating model for product-group intake, delegated-act monitoring, supplier evidence, DPP governance, release gates, and authority response.
- [ESPR compliance: delegated acts, DPP and evidence](/artifacts/eu/ecodesign-for-sustainable-products-regulation/compliance.md): Practical ESPR compliance guidance for mapping product delegated acts, Digital Product Passport dependencies, unsold goods duties, technical documentation, standards, and market-surveillance evidence.
- [ESPR deadlines and compliance calendar](/artifacts/eu/ecodesign-for-sustainable-products-regulation/deadlines-and-compliance-calendar.md): Source-linked ESPR calendar for framework dates, delegated-act dependency, working-plan monitoring, unsold-goods disclosure, and DPP readiness limits.
- [ESPR delegated act intake by product group](/artifacts/eu/ecodesign-for-sustainable-products-regulation/delegated-act-intake-by-product-group.md): A grounded intake checklist for tracking ESPR delegated acts by product group, covering product identification, DPP data, ecodesign requirements, conformity evidence, and source limits.
- [ESPR delegated act intake workflow](/artifacts/eu/ecodesign-for-sustainable-products-regulation/delegated-act-intake-workflow.md): A source-grounded intake workflow for ESPR delegated acts: trigger checks, product-group scope, requirement extraction, DPP impacts, release gates, owners, and evidence outputs.
- [ESPR delegated acts FAQ: product rules, DPP impact, and monitoring](/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq/delegated-acts.md): Standalone FAQ on ESPR delegated acts, why product-group duties depend on them, what teams should monitor, and how they shape Digital Product Passport information.
- [ESPR delegated acts watchlist for product and DPP teams](/artifacts/eu/ecodesign-for-sustainable-products-regulation/espr-delegated-acts-watchlist.md): Track ESPR delegated-act priorities without inventing dates: product groups, source status, likely requirement types, DPP impact, evidence owners, and open source gaps.
- [ESPR destruction ban and unsold goods FAQ](/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq/destruction-ban.md): What ESPR says about preventing destruction of unsold consumer products, annual disclosure, the Annex VII apparel and footwear ban, and grounded derogation evidence.
- [ESPR destruction of unsold goods: disclosure, ban scope, and records](/artifacts/eu/ecodesign-for-sustainable-products-regulation/destruction-of-unsold-goods.md): Source-linked ESPR guide to unsold consumer product disclosure, destruction-ban scope, records, derogations, and national enforcement limits.
- [ESPR DPP information mapping workflow](/artifacts/eu/ecodesign-for-sustainable-products-regulation/dpp-information-mapping-workflow.md): Map ESPR delegated-act information requirements into DPP data elements, source systems, access levels, identifiers, carriers, validation evidence, and unresolved design decisions.
- [ESPR durability, repairability, and recyclability evidence](/artifacts/eu/ecodesign-for-sustainable-products-regulation/durability-repairability-and-recyclability-evidence.md): Build ESPR evidence for durability, repairability, and recyclability without inventing product-group tests before the applicable delegated act is known.
- [ESPR Ecodesign Evidence Checklist](/artifacts/eu/ecodesign-for-sustainable-products-regulation/ecodesign-evidence-checklist.md): Checklist for collecting ESPR ecodesign evidence from delegated acts, technical documentation, supplier substantiation, DPP mapping, standards, and market surveillance records.
- [ESPR ecodesign requirement types: performance, information, and DPP links](/artifacts/eu/ecodesign-for-sustainable-products-regulation/ecodesign-requirement-types.md): Source-grounded guide to ESPR ecodesign requirement types, product parameters, delegated-act dependency, DPP links, and evidence implications.
- [ESPR FAQ: scope, delegated acts, DPP, unsold goods](/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq.md): Standalone ESPR FAQ answers on product scope, delegated acts, Digital Product Passports, unsold goods, product priorities, standards, surveillance, and source limits.
- [ESPR harmonised standards and common specifications](/artifacts/eu/ecodesign-for-sustainable-products-regulation/standards-and-common-specifications.md): How ESPR uses harmonised standards, common specifications, delegated acts, and DPP standards evidence without inventing product-specific requirements.
- [ESPR Information Requirements to DPP Mapping](/artifacts/eu/ecodesign-for-sustainable-products-regulation/information-requirements-to-dpp-mapping.md): Map ESPR information requirements into Digital Product Passport data classes, source systems, access rules, carrier choices, validation checks, and evidence records.
- [ESPR Information Requirements, Labels, and Disclosure](/artifacts/eu/ecodesign-for-sustainable-products-regulation/information-requirements-labeling-and-disclosure.md): Grounded ESPR guide to delegated-act information requirements, product labels, digital product passport access, data carriers, and unsold-goods disclosure.
- [ESPR market surveillance FAQ: evidence, DPP data, and authority requests](/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq/market-surveillance.md): Standalone FAQ on ESPR market surveillance: technical documentation, conformity evidence, DPP data, authority response, delegated-act limits, and national penalties.
- [ESPR market surveillance technical documentation checklist](/artifacts/eu/ecodesign-for-sustainable-products-regulation/market-surveillance-technical-documentation.md): Source-grounded ESPR checklist for technical documentation, conformity evidence, DPP records, and responses to market surveillance authority requests.
- [ESPR penalties and fines: Member State rules and evidence](/artifacts/eu/ecodesign-for-sustainable-products-regulation/penalties-and-fines.md): A conservative ESPR penalties guide explaining Article 74, why fine amounts depend on Member State law, and which conformity and market-surveillance evidence matters.
- [ESPR Product Priorities and Delegated Acts Tracker](/artifacts/eu/ecodesign-for-sustainable-products-regulation/product-priorities-and-delegated-acts-tracker.md): Track ESPR priority product groups, source status, delegated-act progress, expected DPP impact, owners, evidence, and source gaps without treating preliminary studies as binding obligations.
- [ESPR product priorities FAQ: working plan and delegated acts](/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq/product-priorities.md): Standalone FAQ on ESPR product priorities, the Commission working plan, delegated-act dependency, monitoring points, and limits of preliminary source material.
- [ESPR requirements: delegated acts, ecodesign, DPP, and evidence](/artifacts/eu/ecodesign-for-sustainable-products-regulation/requirements.md): ESPR requirements explained as a framework for delegated acts, ecodesign performance and information rules, Digital Product Passports, unsold goods, technical documentation, and market surveillance.
- [ESPR unsold goods disclosure tracker](/artifacts/eu/ecodesign-for-sustainable-products-regulation/unsold-goods-disclosure-tracker.md): Track ESPR unsold consumer product disclosure fields, website publication evidence, destruction-ban status, owners, and unresolved source gaps.
- [ESPR vs Batteries Regulation Comparison](/artifacts/eu/ecodesign-for-sustainable-products-regulation/espr-vs-batteries-regulation.md): Compare ESPR delegated-act planning with the Batteries Regulation product-specific regime, including DPP overlap, battery passport evidence, timing limits, and source boundaries.
- [ESPR vs Ecodesign Directive](/artifacts/eu/ecodesign-for-sustainable-products-regulation/espr-vs-ecodesign-directive.md): Compare ESPR with the earlier Ecodesign Directive across scope, legal form, delegated acts, DPP requirements, unsold goods, transition rules, and evidence.
- [ESPR vs GPSR: Sustainability vs Product Safety](/artifacts/eu/ecodesign-for-sustainable-products-regulation/espr-vs-gpsr.md): A source-limited comparison of ESPR sustainability and product-information requirements against GPSR product-safety context, with evidence and DPP reuse limits.
- [ESPR vs PPWR Comparison](/artifacts/eu/ecodesign-for-sustainable-products-regulation/espr-vs-ppwr.md): Compare ESPR product ecodesign and Digital Product Passport work with the separate PPWR packaging regime, using only source-linked ESPR and packaging-boundary claims.
- [ESPR vs REACH and RoHS Comparison](/artifacts/eu/ecodesign-for-sustainable-products-regulation/espr-vs-reach-and-rohs.md): Compare ESPR ecodesign, sustainability, information, and digital product passport requirements with source-limited REACH and RoHS substance-control context.
- [EU ESPR DPP obligations FAQ](/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq/dpp-obligations.md): Standalone FAQ on Digital Product Passport obligations under ESPR, covering delegated acts, identifiers, carriers, access rights, data governance, and supplier evidence limits.
- [Timeline for ESPR: practical implementation guide](/artifacts/eu/ecodesign-for-sustainable-products-regulation/timeline.md): Practical ESPR guidance for Timeline, with source-linked decisions, owners, evidence records, and implementation steps.
- [What ESPR is and why it matters](/artifacts/eu/ecodesign-for-sustainable-products-regulation/what-is-espr-and-why-it-matters.md): A grounded explainer of the EU Ecodesign for Sustainable Products Regulation, including scope, delegated acts, DPPs, unsold goods, and enforcement limits.
- [Which products are in scope of the EU ESPR?](/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq/products-in-scope.md): Standalone FAQ on ESPR product scope, excluded products, delegated-act dependency, working-plan monitoring, and the digital product passport link.

*Recommended next step*

*Placement: after evidence section*

## Build an ESPR unsold-goods evidence file

Map discarded unsold consumer products to Article 24 disclosure fields, Article 25 ban checks, and retained delivery, reception, and derogation evidence before publishing the annual website disclosure.

- [Open Research Copilot](/solutions/research-copilot.md): Answer ESPR implementation questions with cited source material.
- [Discuss ESPR implementation](/contact.md): Review unsold-goods scope, public disclosure fields, and evidence records with Sorena.


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