The fashion brands we serve absorb the cost of returns as a line on the management pack. Returned, damaged and unsold garments move through one of two routes: jobber clearance at under 7% of original cost, or disposal. Neither route produces a per-garment audit trail, and neither recovers a meaningful share of the value sitting in the stock.
From 19 July 2026, disposal of unsold goods becomes unlawful for large EU enterprises under Article 25 of Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation. The same Regulation requires those enterprises to disclose the volume and disposition of the unsold products they destroy, in a standardised format set by Implementing Regulation (EU) 2026/2 that applies from 2 March 2027. The category that has absorbed returns waste as cost is the same category the new rules will publish. The operations seat has to put an answer in place before 19 July 2026.
This report sets out what an answer could look like. The Opera team has modelled returns recovery economics across 260 European mid-to-premium fashion brands against a single recovery framework, grounded in our pilot box-test data. The aggregate modelled annual gross recoverable value at a conservative 10% capture rate is £276 million. The full addressable surface, at 100% capture, is £2.76 billion.
These numbers are modelled. They scale and vary with each brand's actual return volume and product mix, and they sit before each brand's own reconditioning and handling costs. They are shared as operator intelligence to set the order of magnitude, not as asserted commitments.
Garment returns recovery is a real operational category, separate from returns management software and from branded resale storefronts. It has not existed in published industry data because no operator has measured it at sector scale before now. The first touch is a box test at one of Opera's five European recovery nodes. The conversation starts at hello@operagarmentsolutions.com.
— Joanna Lambert