Europe’s new textile producer responsibility systems are set to bring major new funding into collection and recycling. Now a different question is moving up the agenda: should that money also be used to keep clothes in use for longer through repair, reuse and resale? At the World Circular Economy Forum last week, the Global Action Partnership for EPR — involving the Ellen MacArthur Foundation, GIZ, OECD, UNEP, WWF and others — argued that most EPR schemes still focus on collection, sorting and recycling. Those functions matter, but the group says they are not enough on their own to deliver circular economy outcomes. Its proposal for “second-generation EPR” includes eco-modulated fees and ring-fenced funding designed to push systems further upstream. For textiles, that distinction matters. A garment can retain more of its value by being repaired, resold or reused than by being broken down into fibre. Yet producer responsibility systems have traditionally focused on what happens once products enter the waste system. The shift is also visible elsewhere. This week, the ECOSYSTEX conference in Antwerp gathers textile projects under the heading “Circular textiles beyond recycling”. One project being demonstrated is a semi-automated repair station at Belgian reuse organisation De Kringwinkel, designed to reduce repair time and make garment repair possible for staff without traditional sewing skills. The European Commission has also opened a consultation on whether VAT rules should change to better support circular business models, with second-hand goods named as one of three focus areas. None of this means recycling is becoming less important. Europe will still need more capacity for textiles that can no longer be used. But the policy discussion is widening: from paying mainly for collection and treatment towards examining how rules and producer fees can help products stay in use for longer. For textile EPR, that could become one of its defining design choices.

Something is changing in the European debate about circular textiles. For years, much of the focus has been on collecting more used clothes, controlling textile waste and increasing recycling. But several recent developments point towards a broader view. Three shifts stand out. 1. Second-hand is booming – but the industry is struggling Consumers are increasingly buying second-hand clothes. Resale platforms have grown rapidly, charity shops remain important and second-hand fashion has moved into the mainstream. But behind the consumer boom, the industry that collects, sorts and prepares used clothes for reuse is struggling. Several things are happening at the same time. Large volumes of very cheap new clothes continue to enter the European market. They compete directly with second-hand goods and, sooner or later, many of them also enter collection systems. At the same time, more textiles are being collected. But collecting more does not necessarily mean collecting more clothes with a second-hand value. Poorer-quality garments cost money to collect and sort even when there is little or no revenue at the end of the process. This matters because the economics of textile sorting have traditionally depended heavily on the better garments. The Organisation for Economic Co-operation and Development has noted that the highest-quality share of collected textiles generates much of the value that makes sorting economically viable. Europe is also introducing new rules for collection and producer responsibility. These systems could eventually bring substantial new funding into the sector. But their design will determine whether that money supports reuse or mainly pays for waste handling and recycling. The result is an important paradox. Second-hand can be growing as a consumer market while the infrastructure that supplies that market becomes harder to finance. That is one reason why the current discussion about circularity is becoming broader than simply collecting more textiles. 2. Textile recycling is still tiny – and attention is shifting towards keeping clothes in use Textile-to-textile recycling is often presented as an important part of the future circular textile economy. But today, it barely exists at scale. The European Environment Agency has cited estimates that less than one percent of textile waste is recycled into new fibres for clothing. Much of what is currently described as textile recycling instead turns textiles into lower-value products such as insulation or wiping cloths. This is an important starting point. Europe is building collection systems that will produce much larger textile flows, while the technology and markets needed to turn those textiles back into new clothing remain very limited. At the same time, more policymakers and researchers are asking whether recycling has received too much attention in the first place. A new programme funded by the UK Department for Environment, Food and Rural Affairs and UK Research and Innovation warns that an excessive focus on recycling can help maintain a system based on overproduction and high consumption. It instead puts more emphasis on longer product life, repair, reuse and functioning second-hand markets. France is testing a similar approach. A programme run by the French ecological transition agency ADEME is looking at whether progress should be measured through fewer new clothes entering the market, longer use and more repair rather than simply through larger collection volumes. This shift is especially relevant in light of another problem. A considerable part of the European policy debate has focused on concerns that large quantities of textile waste are being exported as second-hand clothing. But the scale of that problem has still not been robustly established. The European Environment Agency itself acknowledges that official trade data cannot reliably distinguish reusable second-hand textiles from textile waste. It describes the lack of a clear distinction, together with differences in how countries classify these flows, as major weaknesses in the available data. The European Commission is also supporting further international research to establish, among other things, how much waste may actually be moving within the used-textile trade. Against that background, the growing interest in reuse and longer product life marks an important change of perspective. A jacket that is worn for another five years remains a jacket. Once it is shredded into fibre, most of its value as a product has already been lost. Recycling will be needed for textiles that can no longer be used. But with textile-to-textile recycling still below one percent, keeping usable products in use is not a marginal part of circularity. It is currently the much larger circular option. 3. Policymakers are starting to look at what enters the system – not only what comes out The third shift is happening further upstream. Much of textile policy has focused on what happens after people stop using their clothes: collection, sorting, export, recycling and waste treatment. Now policymakers are also beginning to look at the flow of new clothes entering the market. France has introduced a new environmental charge aimed specifically at ultra-fast fashion. The European Union is tightening rules for low-value e-commerce imports and making online platforms more responsible for the products they bring into Europe. Early data from the Netherlands already shows how quickly the market can react. Small parcel volumes fell sharply after new charges were introduced, although some trade appears to have shifted towards bulk imports and warehouses inside Europe. It is therefore too early to know whether these measures will actually reduce the number of cheap new clothes being sold. But the change in focus is significant. Instead of concentrating almost entirely on how to manage textile waste after it appears, policymakers are beginning to address one of the forces creating the growing flow in the first place: extremely large volumes of cheap new clothing. That matters directly for reuse. Cheap new garments compete with second-hand goods on price. And when large volumes of low-value clothing eventually enter collection systems, they can make sorting and resale more difficult and expensive. Reducing that flow could therefore affect the whole chain – from consumption and second-hand sales to collection, sorting, recycling and waste. It also changes the nature of the policy discussion. Instead of trying to solve a circularity problem mainly at the waste stage – including through increasingly detailed rules for classifying and controlling used textiles – governments are beginning to intervene before the waste is created. A broader idea of circularity These three developments are different, but they point in the same direction. The second-hand boom is revealing that growing consumer demand does not automatically create a financially healthy reuse system. The limitations of textile recycling are bringing renewed attention to the much simpler option of keeping products in use. And policymakers are beginning to address the flow of new products entering the market instead of focusing almost entirely on what happens at the end. This broader perspective also matters because increasingly detailed policy is being developed around textile waste at a time when some important parts of the underlying problem are still not well quantified – including how much of Europe’s used-clothing exports is actually waste. Circularity may therefore be moving towards a more basic idea. Not simply collecting more. Not simply recycling more. But producing less waste, keeping useful products in use and preserving their value for as long as possible.

Only 15 percent of discarded household textiles and footwear in the EU are collected separately, according to the European Environment Agency’s new textile module. The same data estimates that Europeans generate around 16 kilograms of textile waste per person every year. That leaves a basic question at the heart of Europe’s emerging textile policy: where does the remaining 85 percent go? Across the EU, extended producer responsibility systems are being introduced to finance collection, sorting, reuse and recycling. But their ability to deliver depends on whether the waste stream can actually be identified and captured. If most discarded textiles continue to end up in mixed household waste, national statistics may offer only a partial view of the real volumes involved. The gap also complicates target-setting. Governments may introduce ambitious reuse and recycling goals, but those targets risk measuring only the material that enters formal collection systems. For policymakers, the immediate challenge may therefore be less about setting new percentages and more about understanding the missing flow. Without better collection data, EPR systems could become highly precise mechanisms built on an incomplete picture. There is an important distinction that is often blurred in the textile waste debate. Europe clearly has a textile waste problem. Large volumes of clothing and household textiles are discarded every year, and EU rules requiring separate collection of textile waste from January 2025 were introduced to address that internal waste stream. But that is not the same as proving that Europe’s second-hand exports are, to a significant extent, exports of waste disguised as reusable goods. The central question in the export debate is narrower: what share of clothing exported as second-hand goods is unsellable at the point of import or first resale in destination markets such as Ghana? Evidence of textile waste in Europe, rising export volumes, weak traceability, or poor waste-management systems in destination countries may justify concern. But none of these, on their own, demonstrate that large volumes of second-hand clothing exports are actually unsellable waste upon arrival. Sweden’s recent experience illustrates the policy risk. After the EU requirement for separate textile waste collection took effect in January 2025, Sweden saw a sharp increase in collected textile waste and higher sorting costs. The government later clarified the rules so that torn or stained textiles that obstruct reuse or recycling would no longer have to be collected separately from October 2025. In other words, even within Europe, a broadly framed textile waste rule had to be adjusted when it placed excessive pressure on the collection and sorting system. That experience matters for the export debate. If regulation treats functioning reuse flows as if they were primarily waste flows, it can shift costs, create bottlenecks and weaken the very systems that keep textiles in use.

New data from the European Environment Agency gives repair a striking result: 95 percent of the textiles brought to participating European Repair Cafés in 2025 could be repaired. The figure suggests that many garments discarded or brought in for help are not at the end of their useful life. They may need a new zip, a repaired seam, a button or another relatively limited intervention before they can be used again. Yet repair often remains a minor part of textile policy. Extended producer responsibility systems are largely discussed in terms of collection, sorting and recycling capacity. Repair is frequently recognised as desirable, but it receives less attention in funding structures, targets and public reporting. That creates a mismatch between policy and practical results. Material recycling can require complex infrastructure and may still produce residues, while a successful repair preserves the product and much of the value already invested in it. The EEA data does not show that every discarded garment can be saved, nor does it measure the full cost of each repair. But a 95 percent success rate raises a clear question for governments and producer responsibility organisations. If repair performs this well in practice, why is it still treated as a side activity rather than a central part of Europe’s textile strategy?

A new EU ban on destroying unsold clothing, accessories and footwear took effect on 19 July. It initially applies to large companies, while medium-sized businesses will follow in 2030. Small and micro-enterprises are exempt. The principle is straightforward: new and usable products should remain in use rather than be incinerated, landfilled or otherwise destroyed. Companies are expected to prioritise measures such as discounted sales, alternative markets, donations, repair and preparation for reuse. Destruction is still permitted in limited cases, including unsafe, damaged or counterfeit goods, but companies must document the grounds and keep records for inspection. New unsold clothes can no longer be destroyed. The ban may nevertheless create new pressure elsewhere in the system. Preventing destruction does not guarantee that an item will find a buyer or user. Large volumes of unwanted stock could instead be channelled into donation, resale or sorting systems that already struggle with fluctuating quality and demand. Products may technically be “prepared for reuse” without achieving actual reuse, while charities and second-hand operators could face higher handling and disposal costs. There is also a risk that excess stock is shifted to alternative markets primarily to remove it from corporate inventories. The critical measure will therefore not be how much destruction falls, but what happens next. The first annual disclosures should show whether the ban reduces overproduction, or merely changes the destination and classification of unsold clothes.

The push to regulate textile waste exports began with the assumption that the problem was already understood. The Basel process has instead exposed fundamental uncertainty about what is actually being traded, what should count as waste and whether the problem exists in the form originally described. When Reuse News examined the issue ahead of the Basel Convention meeting, the political direction appeared clear. Used clothing exports were increasingly being presented as a waste problem requiring international control. The remaining question seemed to be how the rules should be designed. The meeting produced a very different picture. Instead of moving directly towards new restrictions, the Basel process exposed how much remains uncertain. Governments and organisations described different problems, different markets and different meanings of the word waste. The evidence did not support one simple account of a global trade in unwanted clothing. The process has now been forced back to a more basic stage. The Basel Convention is gathering experiences and data on trade in used textiles and textile waste. It is also examining the available regulatory options and the distinction between the two. The issue is expected to return when governments meet again at the next Conference of the Parties in 2027. Used textiles or textile waste? This may sound like a technical discussion, but the distinction has consequences far beyond customs procedures. A used garment can be a donation, a commercial product, recycling material or waste, depending on its condition, its buyer and the market in which it arrives. The same item may have little value in one country and a clear use in another. Any international definition must somehow capture those differences while remaining simple enough for authorities to apply at borders. That is not merely a bureaucratic challenge. It goes to the centre of how a circular economy is supposed to work. When a waste definition becomes too broad Markets for reuse depend on the possibility that goods can retain value after their first owner no longer wants them. If governments define waste too broadly, usable products may be caught in systems designed for disposal. Trade becomes more expensive, smaller markets become harder to serve and clothes that could have been reused may instead be destroyed closer to where they were collected. What the evidence has not established What the Basel process has not established is that the international second-hand trade as a whole resembles the waste trade described by some of its critics. That matters for the public debate. Images of polluted beaches and overflowing dumps have helped create the impression of a direct and well-documented chain from clothing collection in wealthy countries to environmental destruction elsewhere. But when Reuse News examined locations presented as evidence of textile waste in Ghana, much of what appeared to be discarded clothing was actually plastic. Previous Reuse News investigations have also found that the wider chain is often assumed rather than demonstrated. The commercial structure of the second-hand trade provides no obvious economic logic for systematically exporting unusable clothing as a product. The presence of discarded clothing does not by itself prove that waste was exported. Nor does it prove that the clothing had no market value when it crossed the border, or that the problem exists on the scale commonly claimed. Evidence before new controls The next phase should therefore be judged by the quality of the evidence it produces, not by how quickly it delivers new controls. Governments need to understand what is traded, why it is traded, where genuine abuse occurs and what happens when legitimate reuse markets are restricted. Basel began with pressure to regulate textile waste. It has arrived at the harder task of establishing what textile waste is and whether the original diagnosis was correct. That is a reason to ensure that future rules address a problem that can be shown to exist, rather than one that has mainly been repeated. Source: Basel Convention Secretariat: Used textiles and textile waste overview.

The Geneva meeting did not move proposals for stronger controls on used textiles forward for adoption at COP18. The second-hand industry has reason to be cautiously optimistic after last week’s Basel Convention meeting in Geneva. But not because the issue has gone away. At OEWG-15, delegates discussed whether and how the Basel Convention should address the international trade in used textiles and textile waste. Some Parties and observers pushed for stronger controls, including possible prior informed consent procedures and changes to Basel annexes. Others warned that such steps could disrupt legitimate reuse markets before the problem has been clearly defined. In the end, proposals to move used textiles closer to stronger Basel controls were not taken forward for adoption at COP18. Instead, Parties and observers have been invited to submit another round of comments by 30 November 2026. For parts of the second-hand sector, that outcome is best understood as a pause, not a victory. It means there is still time to bring forward evidence, data and practical experience before global waste rules are reshaped around the trade in used clothing. Kenya argued that it would be premature to move directly towards stronger controls and called instead for further technical work. Representatives from the second-hand sector, including the Mitumba Consortium Association of Kenya, the Ghana Used Clothing Dealers Association and SMART, stressed the economic importance of the trade, the need for better data and the risk of treating reusable goods as waste. That does not settle the issue. But it shifts the debate from a simple question of whether textile waste exists to a more difficult one: who should define it, on what evidence, and with what consequences? Related to Reuse News investigations, the Geneva outcome underlines a central point in the wider textile waste debate: the second-hand industry is not arguing that waste should be left unregulated. The question is whether global regulation should be built around claims of large-scale waste exports before those claims have been tested against robust, transparent and verifiable evidence. The next phase is therefore crucial. If the Basel process now focuses on technical guidance, classification, traceability and inspection tools, regulators will need to answer practical questions: What makes a garment reusable? Who decides when it becomes waste? And how can a global system avoid confusing low-value but usable clothing with waste? The Geneva meeting did not remove the risk of future controls. But it did prevent the issue from moving forward on assumptions alone. For an industry built on reuse, that is a meaningful — if temporary — reason for cautious optimism.

The debate over textile waste often focuses on environmental risks. Less attention is sometimes given to what existing reuse systems already deliver. Every year, large volumes of used clothing are collected, sorted and redistributed through international second-hand markets. These systems provide affordable clothing to consumers, create economic activity and extend the life of products that might otherwise be discarded. Research has consistently shown that extending product lifetimes can reduce environmental impacts compared with replacing garments immediately with newly produced alternatives. The sector also supports substantial employment. Estimates suggest that more than two million people in both Ghana and Kenya depend directly or indirectly on second-hand clothing markets through sorting, repair, transport, wholesale and retail activities. For many consumers, second-hand markets are not a lifestyle choice but an economic necessity. Supporters of stricter regulation argue that stronger controls are needed to prevent environmental harm and improve accountability. Those concerns are legitimate and increasingly influential in policy discussions. The question is whether policymakers can distinguish between waste that should be controlled and products that remain valuable and usable. If they succeed, regulation could strengthen confidence in reuse systems. If they fail, policies intended to promote sustainability could unintentionally reduce reuse, increase demand for newly manufactured clothing and weaken an important source of livelihoods and affordable goods. That is why the current debate matters far beyond the textile sector itself. It is ultimately a test of how circular economy policies balance environmental protection with economic and social realities. The Geneva meeting last week of June did not settle the question of how used textiles should be treated under the Basel Convention. Instead, the process now moves into a new phase. Parties and observers have been invited to submit another round of comments by 30 November 2026, before the issue is taken forward towards COP18 in April 2027. That makes the coming months important. The focus is now likely to shift towards technical guidance, definitions, classification, traceability, inspection tools and the unresolved question of how officials should distinguish reusable textiles from textile waste. For the second-hand sector, this distinction is crucial. Future rules could include instruments such as prior informed consent, new Annex entries, certification requirements or closer alignment between Basel rules and customs codes. But without clear evidence and workable definitions, such measures risk treating functioning reuse markets as waste flows by regulation. The next phase should therefore not only ask how textile waste can be controlled. It must first answer a more basic question: what exactly is the problem, how large is it, and how can regulators act without damaging legitimate reuse?

When the Basel Convention invited comments on used textiles and textile waste, responses arrived from governments, industry associations, NGOs, charities, academics and international organisations. On paper, the process is open to all 191 parties to the convention. In practice, only a small share submitted formal comments. Twelve parties and twenty-two observers participated in the consultation. The limited participation raises important questions. Countries with extensive policy resources often have greater capacity to engage in technical consultations, while many developing countries face competing priorities and resource constraints. The responses reveal a significant divide in how stakeholders understand the problem. Many environmental NGOs and activist organisations argue that current systems allow waste to be exported under the label of reuse. They generally support tighter definitions, stronger controls and greater traceability. Industry groups, reuse organisations and many actors involved in second-hand trade tend to focus on the benefits of reuse. They argue that exported clothing is intended for continued use and warn that excessive restrictions could undermine circular systems that already exist. The disagreement is therefore not simply about regulation. It is about the underlying diagnosis of the problem. Is the primary issue waste disguised as reuse, or is there a risk that functioning reuse systems are increasingly being treated as waste? Update: Since OEWG-15, the Basel process has formally invited Parties and observers to submit another round of comments by 30 November 2026. That makes the earlier lack of participation even more important: the next few months may determine whether future rules are shaped by broad evidence or by a small group of highly active voices.

International waste regulators are moving closer to the question of used textiles. After a week of negotiations in Geneva, the issue is now firmly on the agenda for future global rules on waste exports. But one central question remains unresolved: what evidence shows that large-scale exports of unusable second-hand clothes are actually driving the textile waste problem? If new rules are built on unclear or incomplete data, they could end up restricting a functioning reuse system without solving the real waste problem. The Basel Convention regulates the international movement of hazardous and other wastes. At the latest round of negotiations in Geneva last week, used textiles and textile waste moved further into that global regulatory process. For most people outside environmental policy circles, it is an invisible process. But its decisions can have far-reaching consequences for global trade, including the trade in used goods, recyclable materials and waste. The meeting did not decide new global controls for used clothes. But it did move the issue further into the Basel process. The question will now continue toward the next Conference of the Parties, COP18, in Panama in April 2027. A clear divide over reuse and waste exports The Geneva discussions exposed a clear divide. On one side, several governments and environmental groups argue that today’s system leaves too much room for waste to be exported under the label of reuse. They want clearer international rules to distinguish reusable textiles from textile waste, and stronger controls to prevent importing countries from being left with material they cannot sell, recycle or manage safely. On the other side, actors in the reuse and recycling sector warn that poorly designed rules could damage a circular trade system that already keeps garments in use, supports livelihoods and reduces demand for new production. They also strongly challenge the evidence behind the claim that second-hand exports are a major waste stream, pointing instead to studies, field observations and market data that suggest a very different picture: most exported second-hand clothing is commercially valuable, sorted for reuse and imported because there is demand for it. Their argument is not that textile waste should move freely, but that reusable second-hand clothes must not be swept into waste controls simply because they cross a border. Reuse News found a weakly evidenced claim Reuse News’ own investigations ahead of the Geneva meeting found that one of the central claims behind the policy pressure remains weakly evidenced: that large-scale exports of unusable second-hand clothes are being shipped to African countries under the cover of reuse. Read more: How the myth of textile waste is reshaping a global circular system In Ghana, one of the most frequently cited examples, the visible waste crisis documented by Reuse News was dominated by plastic and mixed municipal waste, not mountains of imported textile waste. Interviews and field observations also pointed to strong commercial incentives to import sellable clothes, not unusable waste. Read more: What looks like mountains of textile waste, is actually not. It's plastic. What happens next? The issue now is whether global waste rules should be reshaped around a claim that has still not been proven with robust, transparent and verifiable evidence. The Geneva meeting did not settle that question. But it made the next phase more important. After OEWG-15, proposals to move used textiles closer to stronger Basel controls were not taken forward for adoption at COP18. Instead, Parties and observers have been invited to submit another round of comments by 30 November 2026. The next phase is expected to focus heavily on technical guidance, data and the unresolved question of how officials should distinguish reusable textiles from textile waste. What happens next is therefore not just a technical follow-up. Ahead of the November deadline — and ultimately COP18 in April 2027 — the key question will be whether the Basel process treats the evidence gap as a problem to be solved, or moves ahead on the assumption that the problem has already been proven. Better definitions may be needed. But definitions built on weak evidence could turn a circular trade flow into a waste problem by regulation. If used textiles are now moving closer to global waste controls, the evidence must move just as quickly. Before second-hand clothes are treated as a waste problem, regulators need to prove what the problem actually is. Read more: Second-hand industry appears cautiously optimistic after Geneva waste talks After Basel: Waste or reuse? Written by Thomas Lundkvist Sources: Basel Convention Secretariat: “Used textiles and textile wastes: Note by the Secretariat” IISD Earth Negotiations Bulletin: “Summary report 23–26 June 2026” Environmental Investigation Agency: “Stitching up the textile loophole in the Basel Convention”

Strong rules need strong evidence. After Basel’s OEWG 15 meeting in Geneva, the debate over used textiles is moving further into formal policy work. That makes the evidence behind the claims more important than before. The central question is whether there is reliable evidence that large-scale exports of unusable clothing are driving a waste crisis in receiving countries, and whether that evidence is strong enough to justify new international controls on second-hand trade. This is where the policy process faces a difficult test. Much of the current debate is built around concern over waste, dumping and weak sorting. But concern is not the same as evidence. If reusable clothing is increasingly treated as a waste-risk category, regulators will need to show why the existing trade-based system is not sufficient, where it fails, and at what scale. Reuse News’ own reporting has repeatedly found a gap between some of the strongest claims made in the debate and the evidence available to support them. In several receiving markets, used clothing is not simply dumped after import. It is bought, taxed, sorted, traded, repaired, resold and used through complex commercial systems. Poor quality goods, illegal shipments and genuinely unusable material should be addressed, if it exists. But if new rules are built on unclear definitions or weak data, there is a risk that regulation aimed at waste could also restrict legitimate reuse. The next phase of the Basel process should therefore raise the evidentiary bar — not only for the second-hand sector, but also for policymakers, NGOs and researchers. If global rules are to be developed, the evidence should be strong enough to answer a basic question: what problem is being regulated — and how large is it?

Who draws the line — and how? After the Basel Convention’s OEWG 15 meeting in Geneva, the formal process on used textiles and textile waste is moving forward. The work ahead will focus on definitions, guidance and possible future steps — with one question now at the centre: how should reusable clothing be distinguished from textile waste? For many actors in the second-hand sector, this question should not be part of the Basel Convention at all. They argue that reusable clothing is a traded product, not waste, and that importing countries already regulate what can enter their markets. But whether the issue belongs in Basel or not, the process is now under way — and the distinction between reuse and waste is becoming decisive. The difficult question is who should make that distinction, and how. Is a garment waste because it is low quality? Because it is damaged? Because it is unlikely to be resold in Europe? Or only when it cannot realistically be reused, repaired, recycled or sold in the receiving market? That judgement is complicated because value is not fixed. A piece of clothing that has no commercial value in one market may still have value in another. What looks unsellable to an exporter, inspector or policymaker may still be traded, repaired, downcycled or used in a local market with different price levels, needs and sorting systems. Today, much of that judgement is made by the trade itself: buyers, importers, wholesalers, retailers and consumers decide what is worth paying for. Replacing that market judgement with a regulatory test would require clear criteria, reliable inspection systems and evidence that the current system is failing at scale. The next challenge is therefore not only to define waste. It is to decide who should make that judgement, at which point in the trade chain, on what evidence — and with what consequences for a global reuse system that still appears to work at scale.