Possibly? I’m not sure anyone’s ever considered it before, since prior to this EU regulation there was nothing directing innovation in this space. I might well be the first to come up with the idea :)

Corporations regularly price goods higher than demand in order to delay lowering prices or create artificial scarcity — see gas stations, rental collusion companies, and Prada bags, for example. Charities don’t have to sell clothes received at all to ‘pay’ the donator in tax credits. This law is about forcing corporations to one way or another deliver 100% of their finished goods to end users rather than diverting a massive fraction of that to waste streams, and charities can use clothes up to a point.