Authority record

Destruction of unsold products under an ESPR exception

Record ID: ML-B027-20260925
Economic operator: Norte & Co (fictional demo brand)
Company ID: To be added — required in the disclosure (K08)
Date of decision: 25 September 2026
Legal framework: ESPR Regulation (EU) 2024/1781, Article 25 and Annex VII; Delegated Regulation (EU) 2026/296

1. Products concerned

Batch: B027
Description: cotton shirts — “Cotton tees from supplier under forced-labour import hold”
Fibre composition: cotton 100%
Number of units: 900
Weight: 180 kg
Condition: new
Location: Seville, Spain
CN code: To be added — required in the disclosure (K08)

2. Treatment

Treatment route: Recycling
Disclosure category: Recycling
Waste treatment operator: FibraViva Reciclagem · intake@fibraviva.example.com
Waste hierarchy: Recycling chosen — ranks above disposal.

3. Exception relied on

Exception: (b) Non-compliant with other law
Legal basis: Delegated Regulation (EU) 2026/296, Article 2, point (b) — Allowed reason (b): Non-compliant with other law (D-b)The product breaks other Union or national law (for example forced-labour rules), and destruction is required by that law or is the proportionate corrective action.

4. Evidence

Manager’s evidence: Warehouse note: “Cotton tees from supplier under forced-labour import hold”. Facts: legal issue: non-compliant. Evidence on file: Legal self-assessment LA-0922 (forced labour rules).
Automatic assessment: Rule LEGAL: recommended recycle. (b) Non-compliant with other law. Mostly one fibre (100% cotton), suitable for recycling into new textile fibre.Exception indicated by the rule: b
Declined offers: None logged

5. Record keeping

Keep this record and its evidence for 5 years, until at least 25 September 2031. Provide it to the authorities within 30 days of a request (K06).

6. Notice to the waste treatment operator

To: FibraViva Reciclagem <intake@fibraviva.example.com>
Re: B027, 900 units, 180 kg of unsold cotton shirts

These unsold products are handed over for recycling under the exception in Delegated Regulation (EU) 2026/296: (b) Non-compliant with other law. Norte & Co record ML-B027-20260925.
Keep this record for 5 years.