This Black Friday will be the first since new EU restrictions on destroying unsold clothing came into effect for large businesses. For UK fashion retailers selling into Europe, the challenge extends beyond processing returns. Getting products back across the border, inspecting them and deciding whether to restock, refurbish or resell them can determine how much value is ultimately recovered. In some cases, delays and additional transport costs could make a difference of around €50 on a single returned item, according to illustrative financial calculations.
For fashion retailers, Black Friday is traditionally a period of increased sales, heavy discounting and pressure on fulfilment operations. But the final financial outcome of the shopping season also depends on what happens to the products customers send back. Not every returned item can immediately be put back on sale. Some garments can be resold at full price, while others require cleaning, re-tagging or minor repairs. Others may only be suitable for discounted resale or liquidation. The decision depends on the product’s condition, the time remaining in the selling season and the total cost of making it available for sale again. For UK retailers selling across European borders, there is an additional consideration: whether it makes financial sense to transport each returned item back to the UK or assess alternative recovery options closer to the customer.
New EU rules add another consideration for UK fashion businesses
Since 19 July 2026, the EU’s Ecodesign for Sustainable Products Regulation (ESPR) has prohibited large enterprises from destroying unsold apparel, clothing accessories and footwear, subject to specified exceptions. The prohibition is scheduled to extend to medium-sized enterprises from 19 July 2030, while micro and small enterprises are exempt. Importantly, products returned by consumers can fall within the regulation’s definition of unsold consumer products. For UK fashion businesses operating within the EU, including those managing returned or unsold stock through European operations, the rules may therefore affect how that inventory is handled. Their application depends on the business’s circumstances and whether the relevant activities fall within the regulation’s scope. The restrictions do not mean that every returned garment must be resold. Exceptions are available, including for dangerous, damaged or contaminated products where repair or refurbishment is technically unfeasible or not cost-effective. Businesses relying on these exceptions must retain appropriate supporting documentation.
There are also disclosure obligations concerning discarded unsold consumer products, including their quantity, weight, reasons for disposal and waste treatment. A standardised reporting format under the EU implementing rules is due to apply from 2 March 2027. For retailers managing inventory across several countries, product condition, recovery options and regulatory requirements are becoming increasingly interconnected.
“Returns are no longer just a logistics issue. They affect profitability, inventory management and regulatory compliance. Retailers need to know not only how many products are coming back, but what condition they are in, how much value can still be recovered and which recovery option makes the most financial sense,” says Paweł Zakielarz, CEO of ShopReturns, a cross-border e-commerce returns specialist providing local return addresses across European markets, alongside quantity and quality inspections of returned goods.
A €120 coat: how delays and cross-border transport can change the outcome
For seasonal fashion, the speed at which a returned product becomes available for resale can significantly affect its commercial value. Consider a coat originally priced at €120, with ten weeks of the selling season remaining. In an illustrative financial scenario, inspecting the coat and returning it to sale locally within a few days generates an estimated net recovery of €95.17. If the same coat is shipped back to the retailer’s home market and becomes available for resale five weeks later, the estimated net recovery falls to €45.09. That represents a difference of approximately €50 on a single item. The calculation reflects a combination of additional transport costs, a larger seasonal discount and a reduced likelihood of selling the product before the season ends. These figures are based on illustrative assumptions rather than actual retailer performance data or market benchmarks. They demonstrate how the economics of a return can change depending on timing, location and resale conditions. The challenge is particularly relevant to cross-border retailers deciding whether returned products should travel back to a central warehouse or be assessed for potential resale closer to where they were returned. For lower-priced fashion products, the calculation can be even more demanding. Take a €35 top with just two weeks of seasonal demand remaining. Processing and restocking it locally produces an estimated net recovery of €7.22. Sending the same product individually back across a border and making it available for sale after the season has ended produces a negative net recovery of €1.21. Liquidating the item locally, by comparison, generates an estimated €1.30. The figures illustrate why automatically returning every product to a central warehouse may not always be the most economical decision.
“In cross-border e-commerce, retailers often focus on how much it costs to return a parcel, but overlook what the product will actually be worth by the time it is ready to sell again. Those are two different calculations. A garment that reaches the warehouse several weeks later may already require a much bigger discount or have missed its selling season altogether. The question is not always how cheaply you can move a parcel, but how quickly you can decide what to do with what’s inside,” explains CEO ShopReturns.
Refurbishment or liquidation? The cheapest option is not always the most profitable
Speed is only one part of the equation. Retailers also need to assess whether a returned product is worth refurbishing before resale. Missing labels, damaged packaging, creasing or minor cosmetic defects may require relatively inexpensive preparation. Visibly worn clothing and footwear can require more substantial work before being offered through an appropriate resale channel. Consider a pair of boots originally priced at €90, returned in a worn condition. In an illustrative scenario, cleaning the boots, replacing the insoles and preparing them for discounted resale generates an estimated net recovery of €27.26. Selling the same boots as they are through a marketplace produces an estimated €21.75, while liquidation generates €5.70. Under the assumptions used in the model, refurbishment remains the more profitable option until its cost exceeds approximately €12 per pair. Again, these are illustrative calculations, not measured industry averages. The examples highlight why the original retail price should not be the only factor determining what happens to returned stock. Product condition, refurbishment costs, available resale channels and the probability of finding another buyer all affect the final financial result. For international retailers, the location of the returned product can also influence which option is commercially viable.
The real Black Friday balance sheet emerges after the returns
Black Friday falls on 27 November this year, but products purchased during the promotional period may not be returned until December or January. By then, some collections may have entered further markdowns, leaving retailers with less time to recover value from seasonal inventory. For UK fashion brands selling into European markets, this creates an operational question: how quickly can a returned product be inspected, assessed and directed towards the most appropriate recovery option? Depending on its condition and expected resale value, the answer may be immediate restocking, refurbishment, discounted resale or liquidation. Donation, recycling and destruction also require consideration of the relevant legal and tax rules. Reliable records of returned product condition are particularly important when goods are damaged, require refurbishment or cannot be resold.
“Black Friday can deliver strong sales figures, but that does not mean every transaction will ultimately be profitable. Some products will come back in December or January, when their commercial value may already be significantly lower. Retailers need to look beyond the cost of processing a return and consider how much value they can realistically recover. That can make a substantial difference to the final financial outcome of the season,” Zakielarz adds.
As EU rules place greater emphasis on the treatment of unsold products, and cross-border retailers continue to manage returns across multiple markets, reverse logistics is becoming more closely connected to inventory economics. For fashion businesses, the question is no longer simply how efficiently a return can be transported. It is whether the product can be assessed and directed towards the most commercially appropriate outcome before further value is lost.
Black Friday may drive sales volumes, but the profitability of the season will also depend on how much value retailers retain from the products their customers send back.