Shouldn’t policymakers check the facts before making policy?

The EU is pursuing environmental rules that could reshape how second-hand clothes are traded and reused worldwide. Part of the justification is that large quantities of unusable waste are being exported as reusable clothing. But after a year-long investigation cast doubt on that claim, Reuse News asked the European Commission for the evidence. It could not substantiate the scale of the problem.

Reuse News examined the studies, traced the widely repeated figures and visited locations presented as evidence of a textile waste crisis. Those findings prompted a straightforward question to the Commission: what evidence shows that this is happening on the scale claimed?

The distinction matters. Clothing that is already unusable when exported is a different issue from clothing that becomes waste after further use. Yet claims about both frequently appear in discussions about the environmental consequences of second-hand trade.

Several EU policy measures and proposals are intended, in part, to prevent textile waste from crossing borders disguised as reusable goods. The EU has also pressed for international action through the Basel Convention, where governments are considering options for addressing textile waste shipments, including how to distinguish waste from reusable textiles.

The question Reuse News put to the Commission was about the evidence underpinning that approach: how do policymakers know that a substantial share of clothing exported for reuse is already unsellable or unusable?

A year of scrutiny preceded the questions

Before approaching the Commission, Reuse News had spent a year investigating the claims behind the textile waste export debate. We examined studies and policy documents, traced frequently repeated figures and conducted field reporting in Ghana and Kenya.

One central claim was that 40 per cent of second-hand clothing arriving in Ghana becomes waste. Our examination found that the available evidence did not justify the certainty with which that figure was routinely repeated.

We also visited locations in Ghana repeatedly presented as evidence of a textile waste crisis. The accumulations we examined consisted predominantly of plastic and other waste. They did not substantiate the picture of vast quantities of imported, unusable clothing conveyed by the international coverage.

Other research pointed towards substantially lower proportions of unusable clothing than the figures dominating public debate. Taken together, the investigation did not establish a waste export problem on the scale commonly claimed. Several findings pointed in the opposite direction.

Yet those claims were already helping to shape policy and international regulatory discussions.

It was against that background that Reuse News approached the Commission.

Asked to establish the scale, the Commission provided no robust estimate

The correspondence began in June and continued into September.

Reuse News asked what reliable evidence the Commission relied on when assessing exports of textile waste to African countries. We subsequently sharpened the question: what data showed that a significant share of clothing exported to markets such as Ghana was unsellable when imported, rather than becoming waste after further use?

The Commission referred Reuse News to trade statistics, reports and studies.

Our examination of that material found no robust estimate establishing the proportion of clothing exported for reuse that was already unusable. The sources addressed different markets, stages of the supply chain and definitions of waste. Their findings did not establish a consistent picture of the scale of the alleged problem.

Trade statistics can document the volume and destinations of textile exports. They do not, by themselves, establish how much clothing declared for reuse is actually unusable.

Reuse News then asked the Commission to confirm our assessment: that the available research did not establish a robust figure for the scale of the problem. We also requested an on-the-record response.

No such confirmation was provided, and the correspondence ended without a robust estimate answering the central question.

Policy advances while the scale remains unproven

The EU’s wider textile agenda addresses several concerns, including waste collection, producer responsibility and recycling. Preventing waste from being exported as reusable clothing is one part of that agenda.

But where that concern is used to justify tighter controls on second-hand trade, its evidentiary basis matters.

The Basel process could influence which textiles are treated as waste and what requirements apply when they cross borders. Decisions about that boundary have consequences for exporters, importers and the people whose businesses and livelihoods depend on reuse.

Reuse News’s investigation questioned the scale of the problem used to support that intervention. We then asked the Commission for the evidence that could substantiate it. After months of correspondence, the Commission has not provided Reuse News with robust evidence that a substantial share of clothing exported for reuse is already unsellable or unusable waste.

The regulatory process is moving forward. The central question about the scale of the problem remains unanswered.