Find where your unsold and returns programmes would fail the ESPR Article 25 evidence standard from 19 July 2026.
A retrospective analysis of where your unsold and returns programmes would fail the ESPR Article 25 evidence standard from 19 July 2026, applied at the level a market surveillance authority would require, and what operational changes are needed before that date.
Being compliant and being able to prove it are not the same thing. From 19 July 2026, both are required.
Most programmes will fail not because the legal intent is wrong, but because the operational processes were never designed to produce evidence at the level the standard requires.
Identify exactly which disposal routes lack defensible evidence
Map what the standard actually requires for each route type
Receive a structured pathway to close the gap before July
Four stages. Typically four weeks.
Data availability is the primary variable. We can work with your logistics partners directly to reduce your internal burden.
45 minutes. No data required.
We establish whether the Compliance Exposure Analysis is appropriate for your operation: business status, product categories, disposal routes, approximate volume, and current documentation maturity. Scope, timing, and fee are confirmed at the end of the call.
WHAT GETS CONFIRMED
Categories in scope
Current documentation and system capability
Scope tier and fee
Economic Operator status confirmation
Your operational data. Any format.
Where data is held internally or with your logistics provider or 3PL, send them as they are. No integration needed to start.
TYPICAL DATA INPUTS
Disposal channel records by category
Returns volume by reason code
Relevant cost and handling records
Partner and routing records
Import documentation and IOR records
ESPR standard applied to your data. No input required.
Each disposal route is tested against the ESPR derogation framework: ground eligibility, documentation sufficiency, and evidence gaps by category and volume. Sustainability disclosure alignment is mapped in parallel. Findings are held for the structured session.
WHAT THE ASSESSMENT COVERS
Documentation reviewed against statutory standard
Applicable derogation ground confirmed per route
Evidence gaps identified by category and volume
Partner and route exposure points mapped
Sustainability disclosure alignment checked
Structured session plus written pack.
Findings are delivered in a 1:1 virtual session. The written pack is issued the same day. Four documents, each addressed to a different function within your business.
FINDINGS PACK INCLUDES
ESPR Exposure Assessment
Forward Compliance Pathway Map
Commercial Implications Statement
Route, Partner and Economic Operator Exposure Map
Applies to all economic operators within the EU market, including Importers of Record and Merchants of Record. For group structures, consolidated figures apply, not subsidiary standalone accounts. Scope is confirmed if you exceed any two of the three criteria above.
Four structured deliverables. Delivered in a findings session with a written pack.
ESPR Exposure Assessment
A route-by-route assessment of your current unsold and returns programme against the ESPR evidence standard. Identifies which routes are defensible, which carry exposure, and where routes end in destruction, the assessment identifies which derogation ground applies and whether the documentation to substantiate it exists. Structured to be audit-admissible from the point of issue.
Forward Compliance Pathway Map
For each route where exposure is identified, a documented pathway to a defensible position. Sequenced by priority and deadline proximity. Structured to satisfy both the ESPR evidence requirement and your sustainability disclosure obligations. The forward plan your compliance and sustainability functions need.
Commercial Implications Statement
The quantified cost of your current exposure and the cost of remediation by route. Identifies where future routing optimisation recovers margin beyond the compliance requirement. The business case your finance function needs to act.
Route, Partner and Economic Operator Exposure Map
A partner-by-partner and entity-by-entity view of where current disposal instructions, grading standards, and documentation controls fall short of the ESPR requirement. Identifies process changes required by channel, the partners who need to be brought into compliance, and where economic operator liability sits within your logistics structure. Includes the donation pathway evidence trail and damaged stock assessment records required under the applicable derogation grounds from 19 July 2026.
One dataset. Three decisions.
For your Compliance team
The analysis produces an audit-admissible evidence trail for ESPR compliance. The same output satisfies your sustainability disclosure obligations: disposal routes, product outflows, and circular economy indicators structured to disclosure standard. One exercise closes both requirements.
For your Finance team
The analysis quantifies the cost differential between your current disposal routes and compliant alternatives. That differential is the business case for implementation, not an estimate, but a number built from your own operational data. Decision-support, not a compliance receipt.
For your Operations team
The analysis maps the process changes required at each disposal route: which partners need updated operating instructions, where documentation needs to start at point of issue, and which steps in your logistics structure carry operator liability. A route-by-route brief for the teams closest to the process.
Find where your current programme would fall short from July
This analysis is also available for importers of record and merchants of record operating as the economic operator under the ESPR prohibition.
Frequently Asked Questions
Who is in scope for ESPR Article 25?
What data do we need to provide?
Our disposal records are held by our logistics provider. Can you still run the analysis?
How does this relate to our CSRD reporting obligations?
We are an importer of record or merchant of record. Are we the economic operator?
What happens after the analysis?
We are not an EU-based brand. Does Article 25 apply to us?
What is the difference between this and the Recovery Analysis?
What your current programme can and cannot defend from July
What you receive:
ESPR Exposure Assessment
Future Justification Pathway Map
Commercial Implications Statement
Partner and Route Exposure Map
