The unsold stock ban is already in force, and it runs on passport data

While most of the digital product passport (DPP) conversation is about future dates, one obligation under the same regulation is already live and it has been since 19 July 2026.

Large companies may no longer destroy unsold textiles and footwear in the EU. And once a year, on their own website, they have to disclose what they discarded and why.

What the destruction ban actually bans

Article 22 of the Ecodesign Regulation prohibits the destruction of unsold consumer products where a delegated act says so, and textiles and footwear were the first category named. The prohibition applies to large companies from 19 July 2026 and extends to medium enterprises from 19 July 2030. Small companies are outside it.

Alongside the prohibition sits a disclosure duty. Companies must publish annually, on a freely accessible website, information on the products they discarded, the quantities, the reasons, and what happened to them afterward.

Why this belongs in a passport conversation

Two, and the commercial weight sits in the second.

The first is that both obligations demand the same underlying thing: product data you are willing to stand behind in public. A disclosure that says "we discarded this many units of these products for these reasons" requires knowing what those products were at a level of granularity many companies only have in a warehouse system, not in a product record.

The second is that the disclosure is public and annual. Unlike a passport, which is queried by an authority or a buyer, this one is posted on your own website for anyone to read, including journalists, competitors and NGOs. If the underlying record only gets assembled at reporting time, the disclosure becomes an annual scramble against a deadline that repeats forever.

The pattern worth noticing

This is what the DPP looks like as a management problem rather than a compliance one. The regulation does not ask for a report. It asks for a company that can answer questions about its products continuously.

A record assembled once a year for a filing is a snapshot, and snapshots are wrong by the time anyone reads them. A record kept current at the source answers the disclosure duty, the passport requirement and the next obligation after that, without a separate project each time.

What to check before this year's disclosure

Check whether you are in scope, which turns on company size and on the delegated act for your product category. If you are, look at where the disclosure numbers come from today and how many people touch them before publication, since that count is a good proxy for how fragile the process is. And treat this year's disclosure as the test case for the passport: the data pipeline that makes one reliable is the same one that makes the other possible.

Sources

• Regulation (EU) 2024/1781 (ESPR), Article 22: prohibition on destroying unsold consumer products
• and the associated disclosure duty. In force for large companies from 19 July 2026, extended to
• medium enterprises from 19 July 2030.