Europe’s debate over textile waste and circularity is increasingly framed around responsibility: what happens to unwanted clothing once it leaves EU borders, and who bears the economic and environmental cost of overproduction. Yet the countries most often placed at the centre of this debate are not European. They are Kenya and Ghana. From Accra’s Kantamanto market to Nairobi’s Gikomba, second-hand clothing flows have become highly visible symbols in a discussion driven largely by European policy choices, including fast fashion volumes, upcoming textile EPR schemes, and growing pressure to regulate exports. African markets have become the battleground for Europe’s circular economy credibility. Competing narratives and limited evidence on second-hand clothing exports Gikomba, one of the largest second-hand markets in the world. Recent media coverage around Nairobi Fashion Week illustrates how sharply these flows are framed. Some reports describe Kenya as being overwhelmed by imported clothing, portraying the country as a dumping ground for the Global North. Others highlight the same markets as essential economic infrastructure, sustaining livelihoods and supplying material for reuse and upcycling. What is often missing is verification. Claims that second-hand clothing exports primarily constitute waste dumping remain widely contested by both industry actors and academic research in textile reuse and trade. While quality challenges and waste management pressures exist, evidence consistently points to mixed-quality streams, functioning resale markets, and significant local value creation. The narrative, in other words, is far from settled. Reuse News has covered this issue in several articles. Here is one of them: The elusive truth behind the second-hand export debate Accra, Ghana: What from a distance look like textiles is actually plastic Europe’s textile policy and its impact on second-hand clothing exports This matters because Europe is entering a decisive phase on textiles. Extended Producer Responsibility systems are being rolled out across the EU, while exports of used textiles are moving higher on the regulatory agenda through Basel Convention–related discussions and tighter waste classifications. In this context, Kenya and Ghana become more than destinations. They become arguments. Images from African markets are increasingly used to support policy positions in Europe, either to justify export restrictions or to defend the legitimacy of second-hand trade. Second-hand markets as active economies, not waste endpoints Markets like Kantamanto and Gikomba are not passive endpoints of European waste. They are active second-hand economies, deeply embedded in local consumption, employment, and repair systems. Reducing them to a single waste narrative risks obscuring key structural drivers upstream: overproduction, declining garment quality, and Europe’s limited domestic capacity for textile reuse and recycling. As the EU seeks to assert leadership on circular textiles, the legitimacy of second-hand trade will be one of the most contested issues ahead. Kenya and Ghana may sit at the centre of the story. But the debate shaping their future is, fundamentally, a European one.

Second-hand clothing is not only a question of consumption or charity, but increasingly of trade governance: who gets to define what counts as a product, what becomes waste, and which textile flows are allowed to move across borders. Right now, one of the most important bottlenecks for circular textile trade sits in something as technical as a customs number. HS6309. It is the global Harmonised System (HS) code used for second-hand clothing in international trade. The problem is that it effectively bundles everything into the same category: wearable garments, low-quality exports, textile waste, and even clothing intended for repair, resale, or upcycling. The result is that circular textile flows are forced into a trade system built for linear goods. HS codes as a blind spot in the trade infrastructure A recent article in Vogue Business  highlights how today’s HS framework lacks the resolution needed to distinguish between very different textile pathways. A garment imported as second-hand and later exported again as a redesigned or upcycled product is often classified under the same code as when it first entered the market. Customs systems are not equipped to recognise the difference between waste, reuse, and value-creating circular products. The trade code that define the future of second-hand trade This is not a minor administrative issue within customs administration. It shapes investment decisions, business models, and the ability to build functioning secondary markets. Basel, UNEP and the trade boundary between goods and waste Reuse News has previously followed how the Basel Convention and EU waste legislation are moving toward sharper boundary-setting between “waste” and “goods” in textile trade. What is becoming clearer now is that customs classification sits at the very centre of the same conflict. UNEP is expected to publish recommendations in the coming months on how revised HS codes could better account for circular products. At the same time, both the World Customs Organization and the Basel process are exploring potential amendments that would make it possible to better distinguish between: – textile waste – worn but wearable clothing – materials destined for recycling – products intended for reuse and resale This shift could have far-reaching consequences, especially as the EU prepares to roll out Extended Producer Responsibility systems for textiles and tighten rules around exports. Second-hand clothing and the geopolitics of trade classification Trade classification is not only technical. It is political. In countries such as Ghana and Kenya, second-hand clothing flows have already become a contested space between: – livelihoods and local jobs – waste pressure and “dumping” narratives – domestic markets and global overproduction As the EU expands textile EPR and faces increasing scrutiny over the legitimacy of exports, the way these flows are defined internationally becomes decisive. If second-hand textiles are automatically treated as waste, circular markets risk being closed off. If everything is treated as goods, dumping practices may continue unchecked. HS6309 now sits directly inside that tension. Why HS6309 now shapes circular textile trade The circular economy debate is often framed around design, collection systems, and recycling infrastructure. But this is a reminder of another reality: circularity also requires a trade system capable of recognising the difference between waste and value. With UNEP, Basel, and customs authorities beginning to move at the same time, the classification question is no longer peripheral. It is structural. And it may become one of the most consequential regulatory reforms for global reuse and resale in the years ahead. Sources: UNEP work on sustainable textile value chains (policy overview) World Customs Organization Harmonized System information Basel Convention official site (textiles & waste) Vogue Business: article on HS code issues for second-hand textiles ITC (International Trade Centre) on HS classification and trade facilitation

Update (9 February 2026): The European Commission has announced new rules under the Ecodesign for Sustainable Products Regulation (ESPR) aimed at stopping the destruction of unsold textiles and footwear. The policy shift is designed to increase transparency and introduce a targeted ban on destroying surplus goods, turning what has long been a hidden practice into an enforceable regulatory issue. There is something uniquely maddening about the idea of a product being thrown away before anyone has even used it. Not worn out, not broken, not obsolete. Just unsold. Yet this is happening at scale across Europe’s consumer economy, across multiple product categories. A new study from the European Commission’s Joint Research Centre (JRC) puts numbers on the problem. It estimates that around 21 percent of textiles placed on the EU market are left unsold, and that roughly half of those unsold textiles are ultimately destroyed. In other words, a large share of brand new clothing never reaches a wearer, and a significant portion ends up treated as waste anyway. The study also covers electrical and electronic equipment (EEE). There, the share of unsold goods is lower, around 1.3 percent, but the report still highlights destruction as a real outcome in some channels, shaped by returns, logistics and commercial incentives. This is not only a moral issue. It is also an environmental one. The emissions, water use and chemical impacts of making these products have already happened. When the products are destroyed, the damage remains, but the value is lost. Why do companies destroy unsold products? The JRC points to a set of structural drivers. Overproduction is one. High e-commerce return rates are another. Then there are the practical barriers: testing, repackaging, storage costs, complex internal decision making, and regulations that can make disposal feel simpler than reuse. For many businesses, unsold stock is not treated as a resource. It is treated as a liability. And once a product is labelled a liability, the system is built to remove it quickly. ESPR: what the EU plans to do about the destruction of unsold products The JRC study directly supports the EU’s new regulatory push under the Ecodesign for Sustainable Products Regulation (ESPR) . The regulation is best known for product design requirements, but it also reaches into what happens after products fail to sell. The EU’s strategy now has two connected parts. First, transparency through disclosure requirements Under Article 24 , companies will be required to disclose how many unsold consumer products they discard, and what happens to them. This matters because the problem has long been driven by a lack of public visibility. Without reporting, destruction can stay hidden. Second, restrictions through a targeted destruction ban Under Article 25 , the ESPR introduces a ban on destroying unsold textiles and footwear, and gives the Commission a pathway to extend that approach to other product groups over time. The logic is simple. If companies can no longer destroy surplus quietly, they will need to plan differently. They may produce less, manage stock more carefully, and take secondary channels more seriously. What the ESPR could mean for consumers and return systems Most people will never see the warehouse decisions behind unsold stock. But the policy shift could still affect daily life. Return systems may become stricter. If managing unsold goods becomes more expensive, the era of effortless returns could face pressure. More surplus may flow into outlets, resale, or donation channels, depending on how companies restructure logistics and incentives. That could mean more discounted goods available, but through different routes than traditional retail. And if reporting works, consumers will gain a clearer picture of how much waste is built into the modern shopping model, even before a product has lived a single day. When “unsold” goods enter resale: implications for second hand markets The EU’s immediate focus is on unsold goods, not second hand trade as such. But the two worlds touch. If destruction is restricted, more never used products will need somewhere to go. Some will end up in discount channels. Some may enter resale markets. And that could reshape the public meaning of second hand itself, not only as a reuse culture, but as a safety valve for overproduction. The JRC study does not settle that broader debate. But it makes one thing harder to deny: Europe’s economy is producing so much surplus that even brand new products can become waste. The EU is now trying to turn that absurdity into enforceable rules. Source: European Commission Joint Research Centre (JRC), Study on the destruction of unsold consumer products in the EU  (2024). Related policy: European Commission announcement on ESPR destruction ban for textiles and footwear (9 Feb 2026).

In two recent articles in the Financial Times they highlight the critical issue of fashion and textile waste. And, as a society, we must tackle the environmental damage caused by the fashion industry’s relentless overproduction. Extended producer responsibility (EPR) is an important tool to hold brands accountable for the full lifecycle of their products. As a representative of the second-hand clothes trade in Ghana, I support the idea that EPR funds should “follow the flow of garments”. But EPR schemes in the EU and beyond must reflect the realities of global textile reuse and support what already works. The second-hand clothing trade is the most established and scalable solution to textile overproduction and waste, and this is as true in Ghana as anywhere else. Global reuse keeps garments in circulation longer, reduces demand for new production and stops clothing from being sent to landfill or incineration too soon. Europe generates far more used clothing than it can reuse domestically and, in countries like ours, demand is very strong for these goods. In Ghana, this trade not only meets essential clothing needs but also directly supports the livelihoods of approximately 2.5mn people, especially benefiting women and youth through job creation and entrepreneurship. Policies that treat exports as waste by default, or restrict the flow of reusable clothing, risk undermining both environmental and social benefits. Policymakers, brands and consumers must embrace the global value of reuse and ensure garments continue to flow where they are both needed and valued. This isn’t just about cutting waste — it’s about making circularity work in the real world, from Brussels to Accra. Edward Atobrah Binkley General Secretary of the Ghana Used Clothing Dealers Association, Accra, Ghana  “Solving fashion’s waste problem”, Report , FT Weekend, May 31 “Fast fashion stuck in production-consumption rut”, Special Reports , May 22

When I was tasked a year ago with delving into whether the export of second-hand clothing to African countries is, in fact, dumping of textile waste, I could never have dreamed what I would uncover. Right from the start, it sounded a little odd. Why would anyone pay tax and customs to import goods that can’t then be sold? And what forces in Europe would benefit from transporting waste to another continent when it would be far cheaper to incinerate it? It is undoubtedly a fraught issue—at least in those parts of the textile industry and environmental movement engaged with questions of waste management, circularity, and the climate crisis. It is sometimes described as a debated issue. But it is clear that the narrative “Europe is dumping its unwanted clothes in African countries” dominates the conversation. Countless stories in major international media and the haunting images of clothes washed up on Ghana’s beaches have seared themselves into the minds of many Europeans and also in African countries. As a journalist, it’s hard to let go of the question once it takes hold of your mind. What is really going on here? So we did what one should do: We tried to trace the reports and statistics back to their sources, then assess the quality of those sources and the evidence behind their claims. We reviewed the academic research in the field. What does it say, and can we draw any clear conclusions from it? Finally, we decided to travel to the places where these images originate—to assess for ourselves, with our own eyes, what is actually going on. All in all, it quickly became clear: There is no evidence that the import of second-hand clothing into Ghana is generating the volumes of textile waste claimed There are academic studies that paint an entirely different picture When we were on the ground ourselves, we were struck by how much waste there actually is—and how much of what appears to be textiles is in fact not So how has the situation come to this? One reason is that many issues in life are often more complex than they appear at first glance. What, after all, is the definition of textile waste? And surely textile waste is a problem in many countries—that no one can deny? We will attempt to answer these questions and more in our upcoming reports on “The Elusive Truth Behind the Second-Hand Export Debate”. Stay tuned! Thomas Lundkvist Managing Editor Reuse News Read more: The elusive truth behind the second-hand export debate

"It is fast fashion  -  driven by overproduction and throwaway culture  -  that fuels the textile waste crisis. Yet blame has shifted onto a sector that actively reduces waste - the second-hand sector. The claim that this sector exports waste is not supported by data, and it defies logic." Sven Pedersen, Editor in Chief for Reuse News comments about the open letter to UNEP. United Nations Environmental Programme's (UNEP) push for clearer definitions of textile waste is welcome  - precise terminology benefits all stakeholders. But such efforts must be grounded in evidence. UNEP’s approach suggests second-hand clothing is a key source of textile waste, yet available evidence and operational realities point to more nuanced practices and systems.  I have worked in second-hand clothing for over 26 years, the last 10 in Kenya. Here, the trade is a lifeline  -  supporting 2 million incomes and 24 million livelihoods. For many, it is the only way to access decent clothing with dignity. Even in low-income areas, people are well-dressed and take pride in their appearance. Despite claims that textile waste is choking Nairobi’s streets and landfills, that is not what I have seen. After more than ten years here  -  and I have also visited the Dandora landfill  -  it is clear that textile waste is minimal and makes up only a small part of the overall waste stream. In Kenya, clothes are reused, handed down, and worn for years. People buy far less than in high-consumption economies, where fashion trends drive constant turnover. In the Global North, perfectly good clothes are routinely discarded  -  not out of need, but because people can afford to replace them. Much of this waste is incinerated, making it invisible while contributing significantly to CO₂ emissions  -  about 10% of global footprint. Blaming second-hand clothing for textile pollution is misleading. This trade keeps garments in use, reduces demand for new production, and supports millions of livelihoods. Traders in Ghana protesting against false narratives about textile waste earlier this year. Extensive research Extensive studies from Kenya, Tanzania, Uganda, and Ghana show textile waste in second-hand imports is minimal  -  typically 2% to 5%  -  mostly due to human error in manual sorting. The claim that this sector exports waste is not supported by data, and it defies logic. It is fast fashion  -  driven by overproduction and throwaway culture  -  that fuels the textile waste crisis. Yet blame is unfairly shifted onto a sector that actively reduces waste. Here is why it is inaccurate to claim that the second-hand clothing trade exports textile waste: Textile waste is not traded internationally -  it would lead to financial losses for exporters, importers, and local traders. The second-hand clothes sector systematically avoids it. Exporting textile waste to the Global South makes no economic sense.  Incineration in Europe costs €0.05–€0.07/kg, while shipping to Kenya is more than €1/kg. Garments are carefully sorted before export to meet import standards.  The sector has decades of experience tailoring supply to diverse global markets through close collaboration with local traders. Shipments are demand-driven, initiated and prepaid by importers.  These clothes are not ‘dumped’ – they are valued commodities actively sought by traders and consumers in the Global South because of good quality.   False claims about of a high percentage of waste in second-hand clothing are harmful and it is extremely important that research is grounded in thorough evidence. Such claims threaten a sector that provides millions of livelihoods and access to affordable, dignified clothing. Second-hand sector not to blame for textile waste crisis The sector is a working circular economy  -  not a waste stream. It keeps garments in use, reduces landfill and incineration, and strengthens economic resilience. Restricting it undermines a proven solution. These realities are precisely why I support the open letter to UNEP, which calls for greater transparency and methodological rigour in research on distinguishing used textiles from textile waste. Sven Pedersen Editor in Chief Read more: Textile sector accuses UN Environmental Programme of flawed data and methodology Read more: Mountains of textile waste growing in Europe - not in Africa Read more: The elusive truth behind the second-hand export debate

Second hand clothing has long been treated as something informal. A social good, a thrift economy, a circular alternative to buying new. Now it is moving into a very different world: trade compliance and regulatory classification. This week, a UN-backed study supported by the European Union is set to receive renewed attention as it is formally highlighted at an OECD policy forum on 10 February. The report itself was published earlier, but its upcoming presentation signals that the international regulatory conversation around second hand textiles is entering a new phase. Produced under the UN Economic Commission for Europe (UNECE) together with the UN Economic Commission for Latin America and the Caribbean (ECLAC), the study is titled Making trade work for circularity: Improving circularity in second hand clothing through trade regulation . The significance is not that a new law has been passed, but that regulatory frameworks are being prepared . It is that the rules of the game are being designed. Product or waste: the policy distinction reshaping second-hand clothing trade At the heart of this work is the same deceptively simple issue now appearing across Basel, UNEP consultations, and EU textile policy. When is a used garment still a product, and when does it become waste under international controls such as the Basel framework ? That distinction is not semantic. It determines whether shipments move freely, whether they face waste controls, and whether reuse markets are treated as legitimate trade or as environmental risk. The UNECE/ECLAC study argues that today’s system often fails to make that distinction clearly enough. It points to the need for stronger pre-export sorting, verifiable data, and digital documentation aligned with due diligence frameworks. In other words, second hand is no longer being discussed only as a cultural practice. It is being discussed as a regulated category within global trade and waste governance . From moral narratives to trade regulation: classification, traceability, verification Bales of sorted second-hand clothes waiting to be shipped Public discussions around second hand exports often slide quickly into moral narratives, especially about “dumping” and environmental harm in importing countries. The UNECE/ECLAC approach is different in tone. It is bureaucratic rather than emotional. Its focus is on tools: classification, traceability, verification. That shift matters, because technical frameworks tend to travel. Once they exist, they can be absorbed into larger systems, including customs rules, Basel interpretations, and future EU requirements. Blueprints are rarely headlines. But they become regulatory infrastructure . Risk of miscalibrated waste controls in second-hand textile regulation The central challenge is that the policy momentum is accelerating faster than the underlying data. Everyone agrees that textiles eventually become waste. No garment lasts forever. But a much stronger claim is often implied: that second hand trade itself generates large volumes of immediate waste through unsold imports and unusable clothing. That assumption is frequently treated as self-evident in international discourse, even though the scale, mechanisms, and responsibility remain contested. If regulation is built on broad narratives rather than measured flows, the outcome may be blunt controls that harm functioning reuse markets without solving the real environmental problem. In that sense, the key issue is not whether trade should be regulated. It is whether regulation is being calibrated to measured trade flows and verified impacts . Circular economy governance: when reuse depends on regulatory definitions This debate is not only about clothing. It is about how the circular economy is governed. If second hand goods are increasingly treated through the lens of waste control, the entire promise of reuse becomes conditional on documentation, classification, and international trust. And the stakes are high. Overly restrictive rules could shift market share to larger exporters outside Europe, encourage more ultra-fast fashion production to fill gaps, or reduce access to affordable clothing in lower income markets. Poorly designed rules could also undermine the very circularity they claim to protect. A new phase in global second-hand clothing trade regulation The UNECE/ECLAC study is not a binding decision. But it is a signal that second hand is entering a new regulatory phase, where the question is no longer only what people do with used clothing, but what governments define it as. Product or waste. Trade or dumping. Circularity or liability. The coming months will show whether international regulators can build frameworks that rely on verification rather than assumption, and on measured impacts rather than moral shortcuts. Because once the definitions harden, the system will follow. Source: UNECE/ECLAC study (full text)

In the debate around second-hand clothing and the circular textile economy, many myths and half-truths persist. This article aims to separate fact from fiction — exploring what really happens with donated clothes, how much is recycled, the impact of overproduction, policy changes, and the global imbalances in the used-clothing market. So here is True and false about second-hand clothing 1. Do the clothes I donate really help? True.  Donation is not the end of the line — second-hand is part of a well-developed global system. Your donated garments are sorted, graded, and either sold locally or exported. The proceeds from reselling these clothes fund collection, sorting, and transportation, ensuring that many of these garments get reused rather than discarded prematurely. Also a significant part of the second-hand industry has long been run by charitable organisations, which means that the clothes you donate not only find new use around the world, but also that much of the revenue they generate goes to aid work. 2. “Nearly half of donated clothes end up as waste” — Myth or fact? False.  The common claim that 40% or more of donated clothing becomes waste lacks credible evidence. There are no robust, peer-reviewed studies supporting this figure. In fact, many in the industry have pushed back against this narrative, seeing it as harmful to the legitimacy of reuse as a climate-positive strategy. Reuse News has covered this topic in many articles. You can read them here 3. Oversupply of new clothes: the root problem True.  One of the biggest challenges is not just what happens after clothes are used, but how many new garments are produced. European production and import volumes are massive: according to the European Environment Agency, the EU consumes an average of 19 kg of textiles per person per year. eea.europa.eu This overproduction fuels waste: clothing consumption is high, but reuse and recycling capacities are not keeping up. Zero Waste Europe Moreover, some garments never even reach consumers — studies estimate between 4–9 % of clothes sold in Europe are destroyed before use. circulareconomy.europa.eu The scale of overconsumption, especially fast fashion, is a fundamental barrier to creating a truly circular textile system. Zero Waste Europe 4. How much of clothing is actually recycled? Unfortunately, very little.  Only a very small share of used textiles is recycled back into new clothes. According to EU data, about 1 %  of used textiles end up being recycled into new garments. European Commission Recycling is technically and economically difficult: many clothes are made from mixed fibres, have complex constructions, or contain elastane, trims, etc. As a result, most recycled textiles in Europe are downcycled into lower-value products like insulation or industrial rags, rather than being made into new fashion items. 5. Why new sorting legislation in Europe? Policy ambitions — and unintended side effects. The EU is rolling out stricter rules for how textiles should be collected and sorted to promote circularity. European Commission However, these well-meaning regulatory changes have increased costs for organizations that collect used clothes. This has made it harder for many non-profits to sustain their operations, as they must comply with more rigorous sorting requirements. eea.europa.eu In some cases, these regulations might even discourage reuse, because meeting the new standards is expensive — threatening the second-hand infrastructure that depends on sorting and redistribution. 6. Glut of second-hand clothes in Europe Yes, there is an oversupply. Currently, Europe is experiencing a surplus of used clothing. This is driven by several factors: key export markets (such as Russia and Ukraine) have contracted significantly, and new EU sorting rules have increased the volume of clothes delivered to collection centers — including lower-quality items.The surplus has depressed resale prices, making it economically difficult for second-hand traders to operate. Many collection organizations are forced to pre-sort more aggressively before selling onward, raising their costs and undermining their business models. 7. Classification of second-hand clothing as waste A controversial policy debate. There is an ongoing process — notably within UNEP and under the Basel Convention — about whether used clothing should legally be classified as “waste.” If second-hand garments are officially labeled as waste, it could trigger stricter export controls, more bureaucracy, and higher costs for trade. Many in the reuse sector oppose this shift, arguing that it would hamper circularity by making reuse operations less viable and slowing down cross-border trade in second-hand clothes. Pressure on UNEP and Basel is building up: Used textiles not "waste" True and False about second-hand clothing - Why all of this matters The textile sector’s circular transformation is more complicated than many believe. Second-hand clothes often do have a second life, and donations support a broad, global system — but persistent myths about waste risk undermining that system’s credibility. Meanwhile, recycling remains underdeveloped, and policy changes, though well-intended, can harm reuse infrastructure. Most critically, the underlying problem is overproduction — we are simply making too many new garments, many of which never get fully utilized.If we want a truly circular textile economy, we need honest discussions, smarter regulation, and a realignment of incentives — toward reuse, better design, and lower material throughput. Written by Thomas Lundkvist Read more: Pressure on UNEP and Basel is building up: Used textiles not "waste" Read more: How EU:s textile strategy may fuel Chinese ultra‑fast fashion Read more: "Is this what they wanted? To nearly collapse the system for collecting clothes?"

For several years, textile policy has been framed as a question of urgency. Waste volumes continue to rise, recycling rates remain limited, global trade in used textiles is under growing scrutiny, and the environmental footprint of fashion remains high. What now distinguishes the period ahead is that many of the political responses designed to address these challenges are set to converge within a short timeframe. From 2025 onwards, EU textile policy moves from strategy into phased regulatory implementation. Short summary Over the coming years, several key reforms in EU textile policy will be introduced at the same time. Extended Producer Responsibility, rising expectations for textile recycling and tighter global regulation of used textiles are all intended to accelerate the shift towards circularity. This article examines how these policy tools interact, and the risks that arise if regulation is built on simplified assumptions about how textile systems actually function. Key takeaways: Multiple reforms are rolling out in parallel, making policy alignment critical. Second-hand markets risk being constrained despite a limited evidence base. Recycling is expected to deliver faster and at greater scale than current capacity allows. Producer responsibility may improve products, but risks mainly redistributing costs. EU decisions have direct impacts on global textile markets and livelihoods. Extended Producer Responsibility (EPR) schemes for textiles are being introduced or prepared in multiple EU Member States. Expectations around textile to textile recycling capacity are increasing. At the global level, the United Nations Environment Programme (UNEP) and the Basel Convention are continuing their work on how used textiles and textile waste should be classified and regulated across borders. Individually, each of these processes is rational and grounded in legitimate concerns. Taken together, their combined effects may prove decisive. The central question is no longer what policymakers aim to achieve, but whether the different policy instruments now being deployed will reinforce each other or risk pulling the system in conflicting directions. EU textile policy under simultaneous pressure The European Union has made no secret of its ambition. Textiles are identified as a priority product group in the Circular Economy Action Plan, and the EU Strategy for Sustainable and Circular Textiles sets out objectives around product design, durability, reuse, recycling and reduced environmental harm. At the same time, policymakers are under pressure to deliver visible progress. Textile recycling is expected to scale rapidly. Producer responsibility is expected to correct structural market failures. International regulation is expected to reduce environmental harm associated with global textile flows. What remains less clear is whether the assumptions behind these expectations fully align with how textile markets actually function in practice. As UNEP itself has noted, “the fashion and textile sector isn’t just about style; it is also the frontline against the triple planetary crisis of climate change, biodiversity loss and pollution”. Reuse, recycling, waste management and global trade do not operate as separate policy or market systems. They are deeply interconnected. Decisions taken in one policy arena inevitably reshape outcomes in another. The years leading up to 2026 are likely to be when these interdependencies become increasingly difficult to ignore. Four questions that will shape the period ahead 1. Is second hand trade an asset or a problem to be controlled? Second-hand clothing has moved from the margins to the centre of the textile policy debate. For some, it represents one of the most effective forms of circularity, extending product lifetimes, reducing demand for new production and providing access to affordable clothing across many markets. At the same time, a dominant narrative has emerged in which exports of used clothing to the Global South are increasingly framed as large-scale waste dumping, often presented as a primary environmental problem in itself. This framing has gained strong traction in media coverage and advocacy, despite the fact that the empirical evidence underpinning it remains limited and contested. While there is a notable lack of comprehensive, peer-reviewed studies demonstrating systematic dumping through established second-hand trade channels, the academic research that does exist tends to describe more differentiated realities, including functioning reuse markets, multi-grade sorting systems and significant employment effects. This gap between narrative certainty and available evidence has prompted growing push-back from actors with direct operational and research experience. Jessica Franken warns that policies built on mischaracterisation risk undermining systems that already deliver environmental and social value. In open communications to UNEP and the Basel Convention, industry organisations and researchers have cautioned against treating used textiles as waste by default. Jessica Franken, Head of Government Affairs at the Secondary Materials and Recycled Textiles Association (SMART), has argued that “used textiles are not waste — they are the backbone of the global circular economy,” warning that policies built on mischaracterisation risk undermining reuse systems that already deliver environmental and social value. Concerns have also been raised about the data foundations of current policy discussions. In an open letter submitted to UNEP in late 2024, a group of organisations and academics cautioned that regulatory conclusions risk being shaped by incomplete datasets and poorly substantiated assumptions. As UNEP and the Basel Convention continue their deliberations, the question is therefore not simply how to prevent environmental harm, but how to ensure that policy decisions are grounded in robust evidence that reflects how second-hand trade actually functions in practice. The outcome will signal whether reuse is recognised as an evidence-supported circular strategy, or increasingly constrained by regulation driven by contested narratives. 2. Can textile recycling realistically carry the burden placed upon it? Fibre to fibre recycling is widely presented as the future backbone of textile circularity. Policy targets, investment strategies and public narratives increasingly assume rapid scale up over the coming decade. Progress, however, remains uneven. Technical challenges persist, feedstock quality varies significantly, and many recycling solutions are still capital intensive and limited in geographic reach. According to European recycling industry assessments, less than one percent of textile material is currently recycled back into new clothing, underlining how far current systems are from meeting rising expectations (EuRIC Textiles Manifesto). If reuse channels are restricted while recycling capacity does not expand as anticipated, a gap emerges. That gap risks being filled not by circular solutions, but by increased incineration or disposal. The question for the coming years is whether policy expectations are calibrated to technical maturity and market realities, or whether they are running ahead of what existing infrastructure can deliver. 3. Will Extended Producer Responsibility change products or mainly redistribute costs? Extended Producer Responsibility schemes for textiles are now moving from policy design into early stages of implementation in several European countries. In principle, well designed schemes can shift incentives upstream by rewarding durability, repairability and recyclability. Poorly designed schemes, however, risk functioning primarily as cost recovery mechanisms, with limited influence on product design, production volumes or material choices. As EPR systems roll out, their interaction with reuse markets, collection systems and recycling infrastructure will be critical. Whether they meaningfully steer behaviour or mainly add administrative and financial friction should become clearer as schemes mature. 4. Who sets the rules and on whose terms? Perhaps the most sensitive question is also the most structural. Global textile flows connect producers, consumers, collectors, traders and recyclers across continents. When rules governing these flows change, the distribution of costs, risks and decision making power also shifts. Policies developed in the Global North, even when driven by environmental objectives, can reshape markets in the Global South in profound ways. Whether this leads to environmental improvement, market disruption or unintended social consequences depends on how inclusive, evidence based and context aware those rules are. This tension between preventing environmental harm and respecting economic and social realities is likely to sit at the centre of global textile governance debates in the years ahead. When well intended policies collide There is a growing risk that policies which appear coherent in isolation may work against each other in practice. Restricting reuse while relying heavily on recycling. Promoting circularity while increasing administrative barriers to circular trade. Targeting waste outcomes without adequately addressing overproduction upstream. None of these outcomes are inevitable. Avoiding them requires a willingness to test assumptions, question simplified narratives and align policy tools with how textile systems actually operate. The period around 2026 is unlikely to be decisive because of a single regulation or technological breakthrough. It is more likely to be decisive because the cumulative effects of multiple policy choices begin to materialise across markets, infrastructure and livelihoods. A period that demands scrutiny rather than slogans The textile sector does not suffer from a lack of ambition. It faces the risk of oversimplification. As strategies translate into binding rules and intentions into obligations, the margin for error narrows. What matters now is not how forcefully problems are framed, but how carefully solutions are constructed. This makes the coming years a period that demands close scrutiny of data, assumptions and power dynamics, rather than quick conclusions. In the coming period, Reuse News will examine these developments in depth. Because when everything is expected to be fixed at once, getting the fundamentals wrong can be costly. Written by Thomas Lundkvist

A new U.S.–El Salvador trade agreement has clarified that used clothing shipped from the United States can qualify for preferential treatment under CAFTA-DR, as long as it is exported from the U.S. and classified under HS code 6309. Industry group SMART says the change removes a long-running barrier that had caused inconsistent customs decisions and delays for legitimate second-hand trade. For consumers, the move could help keep more affordable clothing flowing into reuse markets while supporting jobs in sorting, resale and textile recycling. The clarification is also being framed as a practical step toward making circular trade work better in real life, where “rules of origin” designed for new products often do not fit second-hand goods.

From policy concept to practical experiment: the EU is testing automated systems that pay consumers to return used clothing, linking collection directly to reuse, recycling and upcoming regulatory frameworks. The European Commission has launched a multi-year pilot project testing automated collection and sorting systems for post-consumer textiles in Spain and Finland. The project, known as TexMat and led by Finland’s VTT Technical Research Centre together with partners in seven EU countries, uses “smart” drop-off bins that scan garments, assess their condition and automatically sort them for reuse or recycling. Consumers are rewarded based on the estimated second-hand value of the items they return. Crucially, the system is designed to integrate with forthcoming EU policies, including extended producer responsibility schemes for textiles and digital product passports. Returned garments can be tracked, valued and directed toward reuse before being classified as waste. The pilots, running from October 2025 to March 2029, aim to address one of the textile sector’s core challenges: ensuring that separately collected clothing actually finds viable downstream outlets. As the EU moves closer to mandatory textile collection, the project offers a glimpse of how financial incentives, digital tracking and sorting infrastructure could reshape the economics of reuse.

Beyond headlines about geopolitics and agriculture, the EU–Mercosur trade agreement is set to alter competitive dynamics in the global textile and apparel sector, with implications for sourcing, sustainability strategies and circular business models. Following the political agreement between the EU and Mercosur countries Brazil, Argentina, Uruguay and Paraguay, textile and apparel actors are beginning to assess how the deal may affect global markets. The agreement will gradually remove tariffs on more than 90 percent of bilateral trade, with textiles and apparel among the sectors expected to benefit most. Industry association EURATEX has described the deal as a “strategic diversification lever”, particularly for exporters of sustainable, circular and industrial textiles. Analysts suggest the agreement could rebalance trade flows by strengthening South American suppliers while increasing competitive pressure on Asian exporters. Rather than cost alone, trade diplomacy, regional integration and supply-chain resilience are likely to play a growing role in sourcing decisions. For European brands, the deal may also intersect with circular economy ambitions. Easier access to Mercosur markets could influence material sourcing strategies, production footprints and long-term investment decisions at a time when regulatory pressure on textiles is intensifying within the EU.