ESG in e-commerce: logistics, returns and packaging
E-commerce carbon footprint: steering the three ESG cost centres of online retail (delivery, returns, packaging) with management data, EPR schemes and the ban on destroying unsold goods.
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ESG & CSRD reporting in France | SME and mid-cap supportExpert note: This article was written by our chartered accountancy firm. Information is current as of 2026. For a personalised review of your situation, contact us.
Quick answer. An e-commerce footprint concentrates on three cost centres: last-mile delivery, product returns and packaging. These flows are also regulated: EPR schemes and a modulated eco-contribution, plus the ban on destroying non-food unsold goods. Steering them means crossing logistics data with management data, rather than settling for a general speech about sustainability.
Online retail has a particular environmental profile. Where a physical shop concentrates its impacts on the local store and its energy, e-commerce spreads them across a logistics chain made of individual deliveries, frequent returns and multiple packages. Three texts now frame these flows: the AGEC law (law no. 2020-105 of 10 February 2020), the extended producer responsibility (EPR) schemes, and the ban on destroying non-food unsold goods set out in article L. 541-15-8 of the environmental code. This article describes the three ESG cost centres specific to online retail and how to steer them with the right indicators, relying on data the company already holds.
The three ESG cost centres specific to online retail#
Analysing an e-commerce carbon footprint brings out three dominant centres: downstream transport (delivery to the customer), product returns and packaging. These three flows share one trait: they can be steered from management data already available, namely order volumes, return rates and tonnes of packaging placed on the market.
It is precisely this crossover between ESG data and management data that enables action. An online retailer needs no major project to start: they need to connect figures they already handle, and read them through a footprint lens. This lens overlaps with a first carbon footprint by scopes, where downstream transport and packaging fall under scope 3.
Scope 3 boundaries: what is in, what is out#
Under the GHG Protocol, emissions split into three scopes: scope 1 (direct combustion, for instance company-owned vehicles), scope 2 (purchased electricity and energy) and scope 3 (all indirect value-chain emissions, upstream and downstream). For an e-commerce, most of the footprint sits in scope 3, and it pays to set the boundaries of the calculation from the outset; otherwise a first footprint stays vague and hard to compare year on year.
In practice, the priority perimeter of an e-commerce covers three families of scope 3 emissions: downstream transport, that is last-mile delivery to the customer; returns logistics, return transport and reconditioning included; and packaging, from its production to its end of life. These are the three centres we prioritise, because they are both material and steerable from management data.
Conversely, some scope 3 items often stay outside a first footprint, either because they are not material for a resale activity or because the data is hard to make reliable: the upstream manufacturing of the resold products (which can be dominant for a brand, but then calls for dedicated supplier work), employee commuting, or the use of the product by the end customer. Setting this boundary is not cosmetic: it is what makes the footprint credible, reproducible and useful for steering, rather than a global, non-actionable figure.
Delivery and the last mile#
Last-mile transport is often the most emitting centre of the chain, because it multiplies individual trips to scattered addresses. Several levers exist: densifying rounds, offering pick-up points, adjusting free-shipping thresholds to limit split deliveries, and choosing carriers committed to lower-emitting fleets.
Each lever affects carbon, but also cost. Raising a free-delivery threshold can cut the number of parcels, and thus the footprint, while improving the margin. It is the textbook case of a trade-off where the ESG stake and the management stake point the same way. Conversely, systematic express delivery, promoted commercially, degrades both. The indicator to track is not the number of orders, but the number of parcels shipped, which can be far higher when one order leaves in several packages.
Returns: the most costly and carbon-heavy centre#
Returns are the most costly specificity of online retail, especially in fashion and footwear, where the return rate frequently exceeds 20 to 30 %. Each return mobilises extra transport, reconditioning and sometimes disposal. Cutting the return rate, through better product description, size guides or faithful photos, acts both on carbon and on the bottom line.
The accounting treatment of returns also deserves its own attention, which we detail in our article on the accounting treatment of returns and refunds. A return does not only cancel a sale: it changes the stock, triggers a credit note and, on the ESG side, adds an already-incurred transport footprint. The key is to measure the return rate by range and make it a steering indicator, on a par with the margin.
Packaging: EPR, eco-contribution and eco-modulation#
Packaging is both a carbon centre and a regulatory one. Under the household-packaging EPR scheme, the company pays an eco-contribution to an eco-organisation, calculated on the tonnage placed on the market. This contribution is modulated. Since the AGEC law and the Climate and Resilience law, the former bonus-penalty system has evolved into a scheme of subsidies and penalties, provided for in IX of article L. 541-10 of the environmental code: a subsidy can reduce, or even cancel, the contribution for the most virtuous packaging, while a penalty can exceed the initial amount for packaging that contains recycling disruptors.
Two developments deserve attention in 2026. First, an order of 5 September 2025 sets, from 1 January 2026, a modulation linked to incorporating recycled plastic material: eco-designing packaging therefore produces a measurable gain. Second, a new EPR scheme dedicated to professional packaging (industrial and commercial) was created by decree no. 2025-1081 of 17 November 2025; its rollout schedule spreads across 2026 (the full-application date is to be confirmed against the implementing texts). This scheme widens the scope beyond household packaging alone and can concern B2B online retailers: it is wise to check now whether your activity falls within its scope.
| ESG centre | Main lever | Management benefit | Indicator to track |
|---|---|---|---|
| Delivery | Pick-up points, free-shipping thresholds, dense rounds | Fewer parcels, better margin | Number of parcels shipped |
| Returns | Product description, size guides, faithful photos | Lower return rate, protected result | Return rate by range |
| Packaging | Eco-design, recycled material | Eco-contribution eased by the subsidy | Tonnage placed on the market |
Our view: three cost centres before they are three ESG centres#
In e-commerce files, the frequent mistake is to treat ESG as a communication topic, disconnected from steering. Our conviction: the three centres (delivery, returns, packaging) are first of all cost centres. Optimising them for environmental reasons also improves the margin, which makes the approach sustainable over time, where a purely declarative effort runs out of steam at the first budget trade-off.
An online retailer that tracks its return rate, parcel count and packaging tonnage already holds the essentials for a credible first carbon footprint, without any major extra project. The data exists; it mainly needs to be connected to the cost price and the income statement. That is the purpose of our sector support e-commerce accountant.
The underestimated risk: destroying unsold goods by reflex#
The most overlooked risk concerns unsold goods. The destruction of new non-food unsold goods is banned (article L. 541-15-8 of the environmental code): they must first be reused or donated. Entry into force was phased. It has applied since 1 January 2022 to products already covered by an EPR scheme and to certain categories, then to all non-food products since 1 January 2024. A breach exposes the business to an administrative fine of up to 3,000 euros for a natural person and 15,000 euros for a legal person.
An online retailer that destroys dormant stock, out of a year-end simplifying reflex, therefore faces this sanction, on top of the carbon impact and the loss of value. Good practice is to organise donation or clearance channels in advance, and to record these outflows in the accounts, rather than handling unsold goods in a rush at the close.
A common case: a return rate that eats the margin#
A fashion e-commerce records a return rate of 30 %. On 10,000 orders a month, about 3,000 come back. Estimating each return at 8 euros of transport and reconditioning, the centre represents nearly 24,000 euros a month, an annual cost of around 288,000 euros. By working on size guides and photos to bring the return rate down to 24 %, the company cuts the return volume by a fifth, a saving of around 57,000 euros a year, while lowering its transport footprint.
This figure is indicative and depends on the average basket, the delivery zone and the carrier; it mainly illustrates a principle. The ESG lever and the margin lever merge: acting on the return rate protects the result even before serving the sustainability narrative. On this type of file, we rebuild the full cost of a return, often underestimated, then track it by range to target the most problematic items.
In practice: where the accountant steps in#
On an e-commerce file, the accountant ties ESG to the figures:
- Measurement: building the indicators (return rate by range, parcel count, packaging tonnage) from existing management data.
- Eco-contribution: folding the cost of EPR schemes and the effect of the subsidy or penalty into the cost price, so as not to reason outside the EPR.
- Unsold goods: securing the accounting treatment and traceability of donations, in line with the destruction ban and its possible tax angle (corporate-giving tax reduction, under conditions).
- Carbon footprint: laying the basis for a first footprint by scopes, downstream transport and packaging falling under scope 3.
- Reporting: structuring these indicators if the company enters a sustainability approach, in connection with EPR and the eco-contribution of producers and importers.
This is the aim of our CSR and CSRD sustainability reporting offer and, for costed steering, of outsourced CFO support.
Points to watch in 2026#
- Professional-packaging EPR: the new scheme (decree no. 2025-1081 of 17 November 2025) is rolling out in 2026; check whether your B2B activity falls within its scope and from which date the obligation applies to you (the full-application date is to be confirmed against the implementing texts).
- Eco-modulation: packaging that is more recyclable or that incorporates recycled material lowers the eco-contribution through a subsidy; conversely, a recycling disruptor triggers a penalty. This gain or extra cost can be quantified.
- Unsold goods: organise donation channels; destroying non-food unsold goods is banned, on pain of an administrative fine.
- Indicators tied to management: track return rate, parcels and tonnage as steering indicators, not just communication.
- Full cost of a return: do not limit it to transport; include reconditioning and any loss of value.
Frequently asked questions
What are the main ESG cost centres of an e-commerce?+
Three dominate: last-mile delivery, product returns and packaging. They share one trait: they can be steered from data the company already holds, such as order volumes, return rates and packaging tonnage. They are also, above all, cost centres.
How can delivery emissions be reduced?+
By densifying rounds, offering pick-up points, adjusting free-delivery thresholds to limit split parcels and choosing lower-emitting carriers. Several of these levers also improve the margin, because they cut the number of parcels shipped, the real indicator to track.
What are packaging EPR and the eco-contribution?+
Extended producer responsibility requires the company to fund the end of life of its packaging through an eco-contribution paid to an eco-organisation, calculated on the tonnage placed on the market. This contribution is modulated: a subsidy rewards recyclability and recycled material, a penalty sanctions recycling disruptors.
Can non-food unsold goods still be destroyed?+
No. The destruction of new non-food unsold goods is banned by article L. 541-15-8 of the environmental code: they must first be reused or donated. The ban has applied since 1 January 2022 to products already under an EPR scheme, then to all non-food products since 1 January 2024, on pain of an administrative fine.
Do returns really weigh on the footprint?+
Yes. Each return adds transport, reconditioning and sometimes disposal. Cutting the return rate, through better product information, acts both on carbon and on the result. In fashion, where the return rate often exceeds 20 to 30 %, this centre can represent several points of margin.
Where to start an e-commerce carbon footprint?+
By connecting already-available management data (parcels, return rate, packaging tonnage) to a scopes logic, downstream transport and packaging falling under scope 3. Set the boundary first: keep delivery, returns logistics and packaging; the upstream manufacturing of resold products and employee commuting usually stay outside a first footprint. That is enough for a credible, reproducible result, before refining and, where relevant, feeding a sustainability report.
Key takeaways#
- An e-commerce ESG footprint concentrates on delivery, returns and packaging.
- These three centres are first of all cost centres: optimising them for the environment also improves the margin.
- Packaging EPR imposes an eco-contribution modulated by subsidies and penalties; a professional-packaging scheme is rolling out in 2026 (decree no. 2025-1081 of 17 November 2025).
- The destruction of non-food unsold goods is banned (article L. 541-15-8 of the environmental code), with an administrative fine at stake.
- The accountant ties these indicators to management data and the carbon footprint.
Article written by Hayot Expertise, registered with the Ordre des experts-comptables d'Île-de-France. This article is for information only; a decision specific to your situation requires reviewing your activity, your documents and the regulations in force.

Article written by Samuel HAYOT
Chartered Accountant, registered with the Institute of Chartered Accountants. Certified Pennylane trainer.
Regulated French accounting and audit firm based in Paris 8, built to support companies across France with a digital and decision-oriented approach.
Sources
Official and operational sources cited for this page.
- Légifrance, Loi n° 2020-105 du 10 février 2020 (AGEC)
- Légifrance, article L. 541-15-8 du code de l'environnement (interdiction de destruction des invendus non alimentaires)
- economie.gouv.fr, interdiction de destruction des invendus non alimentaires
- ADEME, modulations des éco-contributions (filières REP)
- ADEME, Bilan GES : méthode et périmètre des scopes 1, 2 et 3
- Légifrance, arrêté du 5 septembre 2025 (modulation incorporation de matières plastiques recyclées)
- Légifrance, décret n° 2025-1081 du 17 novembre 2025 (REP emballages professionnels)
This topic is part of our service ESG & CSRD reporting in France | SME and mid-cap support
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