Textile sector’s sharp rebuke: accuses UNEP of flawed used-textile guidelines

A coalition of representatives from the global textiles collection, reuse, and recycling sectors — joined by policymakers and academic experts — has issued an open letter to the United Nations Environment Programme (UNEP), raising serious concerns about the integrity, methodology, and practical implications of UNEP’s Circularity and Used Textile Trade Project.

While acknowledging UNEP’s ambition to drive sustainability and circularity in the textile sector, the signatories warn that the project’s current approach risks unintended harm. The proposed global guidelines to distinguish used textiles from textile waste, they argue, lack sufficient rigour, transparency, and stakeholder inclusion. If adopted in their present form, these guidelines could adversely affect millions of livelihoods in the second-hand clothing trade and hinder meaningful circular economy outcomes.

“We are concerned that the project’s findings may not fully reflect the realities of the global textile trade,” said Alan Wheeler, CEO, Textile Recycling Association, UK. “UNEP’s willingness to adopt unverified findings betrays its stated commitment to impartiality and undermines public trust. We demand that UNEP correct its course, commission truly independent research, and reconsider its guidelines.”

“What we have seen throughout this consultation process is not the objective inquiry that we expect from a UN programme,” said Jeffren Boakye Abrokwah, Chairman, GUCDA. “The Circularity and Used Textiles Trade project could reshape national trade policies that affect the livelihoods of millions of people around the world. In Ghana, for example, UNEP’s research partner is an NGO with a pre-existing waste advocacy campaign that is financially supported by the ultra-fast fashion industry. We have rightly raised concerns about national dialogues where many participants were closely connected to the NGO and questions were leading or closed-ended, which may have affected the neutrality of the data collected.”

Textile sector accuse UNEP of flawed guidelines and methodolgy

Data integrity and methodological opacity

The letter highlights discrepancies between the textile waste figures cited in UNEP’s drafts and those found in prior academic and industry studies. Signatories argue that critical data has been shared without disclosure of collection techniques, analytical processes, or validation protocols — preventing independent scrutiny or stakeholder engagement.

Insufficient inclusion of industry actors

Despite consultations via workshops and surveys, many grassroots collectors, sorters, traders, and small-scale actors report that they were excluded from meaningful participation. The letter claims the consultation timeline was rushed, access to draft materials was limited, and certain voices dominated the discourse, diminishing the chance for comprehensive, balanced input.

Definitions and conflict risks

Central definitions — particularly what qualifies as “waste” versus “used textile” — appear to have been applied without adequate peer review or disclosure. Compounding the issue, the coalition raises concerns about potential conflicts of interest: in Ghana, for instance, the research partner leading stakeholder dialogues reportedly has ties to an NGO campaigning on waste issues and receives funding from ultra-fast fashion interests.

“There’s a serious risk UNEP’s work will be tainted unless it disengages from activist organisations beholden to fast fashion interests,” warned Teresiah Wairimu Njenga, Chair, Mitumba Consortium Association of Kenya. “The potential harm to communities in Kenya, and indeed worldwide, could be profound.”

In summary this is a very sharp criticism and accusation from the textile sector against UNEP.

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Calls to Action

The coalition’s open letter presents a set of urgent demands:

1. Suspend advancement of the current draft global guidelines until the underlying research is independently validated and better aligned with the realities of international used-textile trade.

2. Publish full transparency by releasing research methodologies, data sources, definitions, and drafts across all study countries, allowing for peer review and open stakeholder feedback.

3. Broaden representation by engaging independent and regionally grounded experts and practitioners to collaborate on genuinely inclusive and evidence-based global standards.

The letter ends on a collaborative note, urging UNEP to treat these recommendations not as criticism but as an opportunity to reinforce the legitimacy, impact, and fairness of this important global effort. The signatories express willingness to engage in constructive dialogue toward a more equitable and sustainable global textiles trade.

Read open letter here

Read more: The elusive truth behind the second-hand export debate

Context & Background

UNEP’s Circularity and Used Textile Trade Project operates across Ghana, Kenya, Pakistan and Tunisia, aiming to develop policy guidance and global criteria to help distinguish used textiles from waste. UNEP - UN Environment Programme 

he initiative is part of the broader One UNEP Textile Initiative, which seeks to align all UNEP textile work around key goals: eliminating hazardous chemicals, curbing overproduction and overconsumption, and scaling circular business models.

While global guidelines could guide more sustainable trade practices, observers have flagged the difficulty of creating one-size-fits-all criteria for diverse national contexts and value chains. The letter underscores that guidelines disconnected from on-the-ground realities may backfire, harming small actors and undermining access to affordable clothing in many regions.