Instead, it is drowning in clothes. Europe collected more clothes than it could absorb — pushing its reuse system to the limit. As volumes surged and new regulations reshaped the market, the system handling used textiles came under increasing strain. Now, the consequences are becoming visible. Fewer clothes are reaching second-hand markets, while more are likely being diverted into waste streams instead. Across Europe, the systems that collect and redistribute used clothing have come under growing pressure. Governments are introducing new rules to prevent textile waste, increase textile collection and tighten control over used clothing exports. The aim is to build a circular textile economy. But together these changes are also reshaping the system that has long absorbed Europe’s surplus of clothing. In some cases, the pressure has become visible across the entire chain that handles used textiles. Step 1: A market that absorbed the surplus For decades, Europe’s second-hand clothing trade quietly absorbed part of the fashion industry’s growing surplus. Garments collected through charity containers and commercial collectors were sorted, graded and resold across global markets. Wearable clothing was redistributed to buyers in Europe, Africa, the Middle East and other regions where demand for affordable garments remained strong. This system was not originally designed as a waste management solution. It was a market system built around reuse. But in recent years it has increasingly been expected to function as part of Europe’s waste management strategy. Used clothes ready to be distributed. Step 2: Market shocks weaken the system Even before the latest wave of textile policy reforms, the sector had already begun experiencing significant market disruptions. Several important export markets weakened or disappeared. The war in Ukraine effectively closed two major destinations for used clothing — Russia and Ukraine themselves — while other markets became more volatile. At the same time, new actors entered the global second-hand trade, increasing competition. For sorting companies and collectors, margins tightened. Prices for used clothing declined in several categories while labour-intensive sorting operations became more expensive. In many parts of Europe, the economic foundations of the reuse sector were already becoming more fragile. As conditions worsened, some operators began scaling back activities, while others exited the market entirely. These adjustments would later begin to affect how much material the system was able to absorb. Step 3: Export rules tighten At the same time, policymakers began focusing more closely on the international trade in used textiles. Authorities increasingly sought to distinguish between clothing intended for reuse and textiles considered waste. Under evolving interpretations of waste shipment rules, exporters in several countries faced stricter requirements to demonstrate that shipments contained reusable garments. In practice, this made the trade in unsorted clothing more difficult in some parts of Europe. Many collectors had historically sold mixed clothing to specialised sorting companies that processed and graded the garments after export. Where this practice became restricted, organisations faced pressure to sort textiles domestically instead. Sorting, however, is expensive. For charities and collection organisations that rely on clothing donations to fund social activities, the additional costs created new financial pressure. Closed collection bins in Sweden. Step 4: A sudden surge in collection Another major shift came with new rules requiring households to separate textile waste from general household garbage. The policy goal was clear: prevent textiles from being incinerated with other waste and instead channel them toward reuse or recycling. But in many regions, the infrastructure for dedicated textile waste streams was not yet fully developed. As a result, large volumes of textiles began entering existing clothing collection systems, many of which had originally been designed primarily for reusable garments. Collectors in several countries reported sharp increases in the volume of textiles entering their systems. At the same time, the average quality of the collected material declined, as containers began receiving larger amounts of worn-out or damaged textiles. Sorting costs increased significantly. Some operators responded by reducing the number of collection containers. Others struggled to manage the growing volumes. Several sorting companies reported severe financial pressure, and at least one major operator entered bankruptcy proceedings. Over time, these pressures began to translate into reduced collection capacity in parts of the market. As containers were removed and operations scaled down, fewer textiles were channelled into reuse systems. Most discarded textiles in Europe are not reused or recycled, but diverted into waste streams — primarily incineration. In recent months, this adjustment has become more visible. While earlier phases of the crisis were marked by rising volumes inside the system, parts of the market are now characterised by contraction. This does not necessarily mean that fewer clothes are being discarded. It may instead reflect a reduced ability — or willingness — of the system to collect and process them. While parts of the system are adjusting, another question becomes increasingly difficult to answer. Step 5: Recycling has not yet scaled In the long term, policymakers expect textile recycling to absorb a larger share of Europe’s clothing surplus. Significant investments are now being directed toward new textile-to-textile recycling technologies that could transform used garments back into new fibres. But large-scale fibre-to-fibre recycling remains limited. Most collected textiles today are still recycled into lower-value applications such as insulation materials, wiping cloths or industrial fibres. Only a relatively small share of textiles can currently be recycled back into new clothing. For the foreseeable future, reuse markets therefore remain the primary outlet for wearable garments. Step 6: The ban on destroying unsold clothes Another policy change is now approaching. Under the EU’s Ecodesign for Sustainable Products Regulation, companies will soon be required to disclose how they handle unsold clothing and footwear. Large companies will also face a ban on destroying unsold products. The measure addresses one of the most controversial symbols of fashion’s waste problem: the destruction of new garments that never reach consumers. Few policymakers dispute the intention behind the rule. Yet the ban also raises a practical question. If unsold clothing can no longer be destroyed, those garments will need to enter the same system that has already struggled to handle increasing volumes of used textiles. Collected clothes is piling up in Europe. A growing surplus inside Europe Taken together, these developments have reshaped Europe’s textile system. More textiles entered collection systems. Exports came under greater scrutiny. Recycling capacity remained limited. And the destruction of unsold garments is increasingly restricted. Each measure addressed a specific problem. But together they increased the pressure on the systems responsible for sorting, redistributing and processing clothing after use. As parts of the market have begun to contract, that pressure has not disappeared. Instead, it is increasingly shifting outside the formal reuse system. The climate paradox From a climate perspective, the situation contains an unresolved contradiction. The majority of emissions in the textile sector occur at the beginning of the lifecycle — during fibre production, processing and manufacturing. Yet many of the policies currently transforming the sector focus on the end of a garment’s life. These policies may improve transparency and reduce certain forms of waste. But they do not directly limit the scale at which new garments continue to enter the market. As long as production volumes remain high, large quantities of clothing will continue to flow into collection systems — or, where those systems contract, into general waste streams. If fewer textiles are collected while production volumes remain high, a larger share of discarded clothing is likely to be directed into general waste streams, including incineration. Does current policy adress the real negative impact on climate? What happens next? Europe is entering a new phase of textile governance. Governments are building systems to collect more textiles, track clothing flows more closely and prevent the destruction of usable products. These measures aim to reduce waste and promote circular use of materials. But circular systems require capacity. Even if Europe collects fewer clothes than before, the underlying imbalance remains. As long as production volumes stay high and reuse and recycling systems cannot absorb the flow, the surplus does not disappear. It shifts. It will simply accumulate somewhere else in the system — or bypass it altogether.

Europe’s textile system was built around reuse. Today, that system is under pressure, and most discarded clothing no longer finds its way back into use. Most discarded textiles in Europe are not reused or recycled, but diverted into waste streams — primarily incineration. Across Europe, millions of tonnes of clothing are discarded every year. While policies aim to increase reuse and recycling, the system handling used textiles is struggling to keep pace. Reuse markets remain limited and increasingly unstable. Recycling capacity is still small. At the same time, more textiles are entering collection systems as new regulations take effect. As a result, a growing share of discarded clothing is diverted into waste streams. In practice, this often means incineration. The shift is not driven by a single policy or market change, but by a combination of pressures: rising volumes, weaker export markets, higher sorting costs and limited alternatives at scale. Together, these factors are reshaping where Europe’s clothes actually end up. The full dynamics behind this shift — and the policies driving it — are explored in our main analysis.

Across Europe, pressure in the textile system is no longer only visible in volumes and operations. It is increasingly becoming visible in the data. As the system grows more complex to manage, the European Commission is preparing new rules to track how textiles move through it. The initiative focuses on reporting obligations for used textiles and textile waste, aligning existing frameworks with updated requirements under the Waste Framework Directive. On paper, the change is technical. In practice, it signals something else. A system that is becoming harder to understand. In recent years, EU textile policy has focused on increasing collection, restricting exports and limiting the destruction of unsold goods. Together, these measures are reshaping how textiles move after use. But as volumes rise and pathways become more constrained, visibility into what actually happens to those textiles remains limited. As Reuse News previously reported, a share of garments already "dissappears from view" after failing to find a market At the same time, operators across the value chain report growing pressure from rising volumes, declining margins and increasing regulatory complexity. The new reporting initiative suggests that policymakers are now trying to map a system already under strain. Better data may improve oversight. It may also reveal how large the gap has become between what the system is expected to handle and what it can realistically absorb. But the timeline points to a structural delay. The new reporting framework is not expected to be adopted before 2027. Until then, key parts of the system will continue to operate with limited transparency. This places the EU’s textile strategy in a paradoxical position. Policies are accelerating the flow of textiles into collection and reuse systems. At the same time, the mechanisms to fully understand and manage those flows are still being built. The result is a system that is not only under pressure, but only partially visible. And in a system where volumes continue to grow, what remains unseen may be just as important as what is already becoming visible. Source: European Commission – Waste Framework Directive The initiative forms part of the EU’s broader textile strategy, where increased collection and stricter regulation are reshaping post-consumer textile flows across member states.

Europe is building new rules to control textile waste, increase circularity and track material flows. But as these rules take shape, a central problem is becoming visible. Large parts of the textile system they are meant to regulate remain only partially understood. Across Europe, the textile system is entering a new phase Over the past few years, EU textile policy has expanded rapidly. Separate collection of textiles is being introduced across member states. Controls on exports of used clothing are tightening. New rules on unsold goods are being prepared. And additional reporting requirements are now under discussion. Together, these measures are designed to build a more circular textile system. But they are also being applied to a system that is still only partly visible. A system under pressure and still difficult to map In warehouses, sorting facilities and collection systems across Europe, operators report rising volumes, declining material quality and increasing operational complexity. At the same time, the pathways through which textiles move after use are becoming harder to track. Some garments are collected and resold. Others are exported. Some are downcycled. And a significant share still ends up in disposal. But as flows become more fragmented and conditions more constrained, visibility into what happens to textiles after collection remains limited. As Reuse News has previously reported, a share of garments already disappears from view after failing to find a viable market — raising a broader question: More rules, but limited oversight In recent weeks, the European Commission has taken steps that point to a growing awareness of this gap. A new consultation under the proposed Environmental Omnibus aims to simplify parts of the regulatory framework, including rules affecting circular systems. At the same time, the Commission is preparing updated reporting requirements under the Waste Framework Directive to improve tracking of textile flows. On paper, these are technical adjustments. In practice, they signal something more fundamental. The system is becoming harder to operate and harder to understand. Policy is reshaping flows faster than they can be tracked Current EU textile policy is not only increasing volumes entering the system. It is also changing how those volumes move. Separate collection is bringing more textiles into formal systems. Export controls are altering where and how used clothing can be traded. New obligations are increasing the need for sorting and documentation. Together, these changes are reshaping the structure of textile flows across Europe. But the mechanisms to fully track and understand those flows are still being developed. The proposed reporting framework, for example, is not expected to be adopted before 2027. Until then, large parts of the system will continue to operate with limited transparency. As textile flows become harder to track and outcomes more uncertain, a broader pattern begins to emerge. A system that is only partially visible This creates a structural tension in the EU’s textile strategy. Policies are accelerating the transformation of the system by increasing volumes, introducing new requirements and reshaping existing pathways. At the same time, the tools to fully observe and manage that system are not yet in place. The result is a system that is not only under pressure, but only partially visible. And as volumes continue to grow, what happens outside the visible part of the system may become increasingly important. From building rules to understanding the system EU textile policy is entering a new phase. If the past years were about building regulatory frameworks for circular textiles, the current phase is about making those systems function in practice and understanding what they actually do. Because before a system can be fully regulated, it needs to be fully seen. Source:   European Commission – Waste Framework Directive The initiative forms part of the EU’s broader textile strategy, where increased collection and stricter regulation are reshaping post-consumer textile flows across member states.

Across Europe, pressure in the textile system is no longer abstract. It is becoming visible. Collection volumes are rising, export markets are shifting, and parts of the system designed to handle used textiles are struggling to keep pace. Now, the European Commission is beginning to adjust existing rules — not to introduce new ambitions, but to make the current system work in practice. Across Europe, signs of strain are emerging across the textile system. Operators handling used clothing report rising volumes, weaker margins and growing operational complexity. Policies designed to reduce waste and increase circularity are now interacting with a system that is already under pressure. In response, policymakers are beginning to shift focus — from setting new targets to making existing rules operational. Last week, the European Commission opened a consultation on its proposed “Environmental Omnibus”, a package aimed at simplifying parts of EU environmental legislation, including rules affecting textiles and circular systems. On paper, the initiative is about reducing administrative burden. In practice, it signals a growing need to make existing rules operational. The system is becoming harder to operate. What the Environmental Omnibus means for EU textile policy Over the past few years, EU textile policy has expanded rapidly. New requirements on textile collection, tighter controls on exports of used textiles, and upcoming rules on unsold garments are all designed to build a circular system. But as Reuse News recently reported, these changes are also putting pressure on the system that handles used textiles. Volumes are rising. Quality is declining. Costs are increasing. The Environmental Omnibus suggests a shift in focus. The emphasis is no longer only on adding new rules, but on adjusting how existing rules function in practice. What is the Environmental Omnibus? An “omnibus” is a legislative update that modifies several existing legal acts at once. In this case, the European Commission is reviewing parts of its environmental regulatory framework to: simplify reporting requirementsreduce overlapping obligationsimprove compliance across EU member states The consultation signals that the regulatory framework for circular textiles is still being developed and adjusted. Closed collection bins for used clothes in Sweden, due to system failures. Growing pressure on textile collection and sorting systems The push for simplification comes as both material and regulatory pressure increase at the same time. More textiles are entering collection and sorting systems, while rules governing how they are handled are becoming more complex. The result is a growing gap between policy ambition and operational reality in the EU textile system. The Commission is not changing direction. But it is beginning to adjust how the system works. A new phase in EU textile policy implementation EU textile policy is entering a new phase. If the past years were about building regulatory frameworks for circular textiles, this phase is about making those systems function in practice. This is often where structural constraints and unintended effects become visible.

What actually happens to the clothes that are never sold? Each year, hundreds of thousands of tonnes of garments fail to find a buyer in Europe. Most are redistributed through secondary markets. But a smaller share simply disappears from view — with limited data on where it goes or how it is handled. Now, the EU’s Ecodesign regulation is about to bring this hidden part of the system into focus. A commonly cited figure is that around 20 percent of garments go unsold. But this does not mean that one in five items is never used. It refers to products that fail to sell in their initial retail cycle, including returns, and are then redistributed through channels such as markdowns, outlets and off-price sales. Most eventually find a buyer. What remains is a much smaller, but more consequential share: garments that fail to find a market at all. This fraction, according to EU estimates, represents roughly 4–9 percent of all textiles placed on the European market, equivalent to approximately 264,000 to 594,000 tonnes per year. It is this residual stream of unsold clothing that is now being targeted by regulation. Limited data on the residual stream of unsold clothing The problem is that there is no clear picture of what this residual stream consists of, or how it is handled in practice. While resale channels such as outlets and discount platforms are relatively well understood, the final stages of the process remain opaque. What happens to garments that cannot be sold, even at a discount, is not systematically documented. This lack of transparency is structural. Until now, companies have not been required to disclose how they manage unsold products that are ultimately discarded as waste. EU estimates are therefore based on partial data and industry assumptions rather than comprehensive reporting. Approximately 264,000 to 594,000 tonnes of unsold clothes effectively disappear every year through destruction. Ecodesign regulation introduces reporting requirements for unsold textiles The Ecodesign regulation changes this. Companies will be required to report how they handle unsold clothing and footwear, including the volumes discarded and the reasons why. For the first time, policymakers and the public may gain insight into a part of the system that has largely remained out of view. The EU’s stated objective is to reduce waste and emissions. Fewer new garments should be destroyed before use. But the regulation also alters the cost structure of overproduction. If unsold goods can no longer be disposed of, the cost of forecasting demand incorrectly increases. In theory, this could lead to tighter production volumes, improved demand planning and more cautious inventory management. In practice, the outcome remains uncertain. Structural constraints in the fashion system limit immediate effects The fashion industry is structurally built on volume, speed and availability. Producing less carries risks in the form of missed sales, while producing more has historically been manageable through markdowns, secondary channels and, in some cases, destruction. Without that final option, companies will need to identify alternative pathways for managing surplus. These may include deeper discounting, expanded outlet channels, extended storage or new forms of redistribution. A key question is whether part of this volume will move into second-hand markets. On the surface, this appears plausible. Unsold garments are intact, unused and often of higher quality than much of what is collected post-consumer. In a global context, where European fashion cycles are less relevant, they may retain resale value. But this is not only a question of product quality. It is also a question of system capacity. Second-hand and recycling systems face capacity and value constraints Across Europe, infrastructure for handling used textiles is already under pressure. Collection volumes are increasing, while margins in sorting and resale are declining. Even if unsold garments have resale value, it is unclear whether existing systems can absorb additional volumes at scale. At the same time, one of the long-term solutions highlighted in policy discussions, fibre-to-fibre recycling at scale, remains limited. Most textile recycling today results in lower-value outputs, and fully circular systems are still in development. This leaves a limited set of practical pathways for managing surplus: resale, redistribution, downcycling or waste. With destruction now restricted under the Ecodesign regulation, one of these pathways is being removed. The regulation is clear about what should not happen. Less clear is what should happen instead. Until there is better data on how unsold clothing is currently handled, it remains difficult to assess how the system will respond when one of its final exit routes is removed.

The European Commission has launched a new infringement procedure against Lithuania for failing to properly transpose the EU’s Waste Framework Directive into national law. T he case was announced as part of the Commission’s March infringements package, a regular review of how EU legislation is implemented across member states. Infringement procedures are used when the Commission believes national authorities have not correctly applied EU law. The Waste Framework Directive is a cornerstone of EU waste policy, setting out key principles such as the waste hierarchy, recycling targets and responsibilities for waste management systems. While the procedure concerns Lithuania specifically, enforcement of the directive has broader implications for several emerging policy areas, including textile waste management. Many of the measures now being developed under the EU’s textile strategy build on the legal framework established in the directive. The case highlights the ongoing challenge of translating EU environmental legislation into functioning national systems across the bloc.

A proposal linked to the European Commission’s Environmental Omnibus initiative has triggered concerns among recycling industry representatives about the future enforcement of Extended Producer Responsibility (EPR) rules. The proposal would suspend, until 2035, the requirement for producers selling products in EU countries where they are not established to appoint a local Authorised Representative responsible for ensuring compliance with national EPR systems. Recycling Europe has warned that removing this obligation could make it harder to ensure that foreign producers register, report volumes and contribute financially to waste management schemes. According to the organisation, the change could increase free-riding, weaken traceability and ultimately undermine the functioning of recycling systems across the EU. The issue is particularly relevant as the EU prepares to roll out new textile EPR systems , which are expected to finance the collection, sorting and treatment of used clothing across the bloc. Industry groups argue that weakening enforcement mechanisms at this stage could complicate the implementation of those systems.

Europe is preparing to ban the destruction of unsold clothing. The move is widely welcomed as a step towards a more circular textile economy. Few people argue that usable garments should be burned or discarded. But the decision arrives at a complicated moment for Europe’s textile system. In many parts of the continent, the infrastructure designed to handle used clothing is already under growing pressure. The question now facing policymakers is straightforward, even if the answer is not: what happens to unsold garments when destruction is no longer an option? Ecodesign regulation introduces new rules for unsold clothing Under the EU’s Ecodesign for Sustainable Products Regulation, companies will soon be required to disclose how they handle unsold clothing and footwear. Large companies will also be prohibited from destroying unsold products, with the aim of reducing waste and encouraging reuse or recycling. The logic behind the measure is simple. If companies cannot dispose of excess stock through destruction, they will have a stronger incentive to manage it differently, through resale, donation or recycling. In theory, fewer clothes will be wasted. In practice, however, the question is where these garments will go. Europe’s textile collection and sorting systems are already under strain Across Europe, the systems that collect and sort used clothing are experiencing significant changes. New rules require households to separate textile waste instead of discarding it in general waste streams. As a result, large volumes of textiles are now entering collection systems that were originally designed primarily for reusable garments. At the same time, the market conditions for second-hand clothing have become more difficult. Several traditional export markets have weakened in recent years, while competition between sorting operators has intensified and resale prices for used garments have declined. The result is a system where volumes are rising while margins are shrinking. Sorting companies and charitable collectors in several countries have reported growing costs and increasing pressure on storage and sorting capacity. Textile recycling capacity remains limited In the longer term, policymakers expect textile recycling to play a much larger role in absorbing Europe’s clothing surplus. Significant investments are being directed toward new textile-to-textile recycling technologies. But industrial-scale recycling for mixed post-consumer textiles remains limited. Most clothing collected in Europe today can only be recycled through processes that produce lower-value outputs such as insulation or industrial materials. Fully circular fibre-to-fibre recycling is still emerging and currently handles only small volumes. This means that reuse markets continue to play a crucial role in extending the lifespan of garments that remain wearable. EU ban on destroying unsold clothing does not address production volumes The ban on destroying unsold clothing addresses one part of the textile waste problem: the treatment of excess inventory. But it does not change another fundamental dynamic of the global fashion system: the scale at which new garments are produced. Clothing production has grown rapidly over the past two decades, and large volumes of garments continue to enter the market each year. When those garments remain unsold, they add to the growing pool of surplus clothing that must be redistributed, reused or recycled. If fewer garments are destroyed and recycling capacity remains limited, more of that surplus will need to be absorbed elsewhere in the system. A new capacity challenge for European textile policy Europe’s textile policies are entering a new phase. Governments are introducing rules to collect more textiles, monitor clothing flows more closely and prevent the destruction of usable products. These measures are intended to reduce waste and encourage more circular use of materials. But they also raise a practical question about system capacity. If more clothes are collected, fewer are destroyed and recycling systems are still developing, the pressure on the rest of the textile system inevitably grows. For now, the answer to where those clothes will go remains uncertain. What is clear is that Europe’s textile system will have to find new ways to handle the growing surplus.

In recent years, regulation of used clothing has moved rapidly up the political agenda. At the same time, a growing number of regulatory processes are focused on what happens after garments are discarded, while the questions of overproduction and overconsumption remain largely unresolved. This imbalance is striking in climate terms. The textile sector is estimated to account for roughly 2–4 percent of global greenhouse gas emissions, with most of the impact occurring upstream in fibre production, processing, dyeing and manufacturing. The climate impact linked to what happens after a garment is discarded represents only a marginal share of that footprint, yet it is precisely this part of the system that current regulatory efforts are focusing on. The textile sector is estimated to account for roughly 2–4 percent of global greenhouse gas emissions Export rules are tightening. Textile shipments face greater scrutiny under the EU Waste Shipment Regulation. And under the Basel Convention, technical discussions are exploring whether certain second-hand textile exports should be classified as waste.Taken together, these developments signal a clear shift. Reuse and second-hand clothing have become central objects of textile governance. Why are second-hand textile flows becoming a focus of textile policy? Several dynamics appear to converge. One is institutional. Waste regulation is an established policy domain with existing legal tools and administrative structures. Expanding those frameworks to include textiles is considerably easier than attempting to regulate production volumes in a globalised industry. Visibility also matters. Global flows of used clothing are highly tangible. Images of large volumes of garments arriving in markets in Africa or Asia have become powerful symbols in debates about textile waste. Production systems, by contrast, are geographically distant and embedded in complex supply chains. Advocacy has also shaped the agenda. In recent years, several NGOs have framed global second-hand trade as an environmental burden for importing countries. These narratives have contributed to growing political momentum around export controls and classification debates within EU and Basel policy processes. Finally , focusing on second-hand flows allows policymakers to demonstrate action on textile waste without confronting some of the more politically difficult questions surrounding production scale, consumption patterns and trade policy. Together, these dynamics help explain why reuse has moved to the centre of textile policy discussions. But they lead to a further question: If new regulatory attention is built on the assumption that second-hand flows represent a significant environmental problem, how strong is the evidence behind that assumption? This questions are examined further here: How robust is the evidence behind environmental claims in the second-hand clothing trade? Tougher rules for discarded clothes — but textile production volumes remain outside EU climate control

Much of the current momentum in textile policy is built on growing concern about the environmental consequences of global second-hand clothing flows. Underlying many of these discussions is a basic assumption: that large-scale trade in second-hand clothing contributes significantly to environmental harm in importing countries. But how well documented is that assumption? Reliable data on the environmental impacts of global second-hand trade remain surprisingly limited. While a number of reports highlight visible waste challenges in major importing hubs, far fewer studies have been able to quantify the environmental effects of second-hand flows in a systematic way. Field observations versus widely circulated imagery In several high-profile cases, the narrative has been shaped as much by imagery as by data. Reuse News has previously reported from locations frequently cited in the global debate about textile waste, including coastal areas in Ghana often portrayed as destinations for European clothing waste. Field reporting and photographic documentation from those locations did not support the widely circulated image of beaches overwhelmed by discarded garments. Instead, the dominant waste streams observed were plastics and other municipal waste. This does not mean that textile waste problems do not exist. Markets handling large volumes of used clothing inevitably generate some unsold or low-value material that must be managed locally. Coastal areas in Accra, Ghana is often portrayed as destinations for European clothing waste. Field reporting and photographic documentation from those locations does not support this narrative. Instead, the dominant waste streams observed were plastics and other municipal waste. Textile waste and clothing consumption But it is important to distinguish between different types of textile waste. All garments, whether new or second-hand, eventually reach the end of their useful life. The presence of textile waste in a country therefore reflects overall clothing consumption and local waste management systems, not only the origin of the garments themselves. Framing textile waste primarily as a consequence of second-hand imports risks obscuring this basic fact. If consumers in countries such as Ghana or Kenya were instead purchasing larger volumes of newly manufactured garments, often inexpensive ultra-fast-fashion products produced elsewhere, the same items would still eventually enter the waste stream once they reached the end of their life. Scale and waste management systems This raises a broader question about scale. Clothing consumption levels in many African countries remain far below those seen in Europe or North America. Estimates of annual garment purchases in countries such as Kenya or Ghana are typically a fraction of European consumption levels, often less than one fifth. That does not mean textile waste management is easy. Many cities across the Global South face serious challenges in managing municipal waste streams, including plastics, organic waste and other materials. Textile waste forms part of that broader system. But available evidence suggests that textiles represent only a small share of overall urban waste streams in most cases. The environmental challenges facing these waste systems are therefore wider than textiles alone. Evidence gaps in the second-hand clothing policy debate Seen in this context, the environmental question may be less about whether second-hand clothing exists in local markets, and more about how waste management systems cope with end-of-life materials of all kinds. Yet current regulatory debates increasingly frame second-hand trade itself as a central environmental problem. As governments move to tighten export rules and redefine how used textiles are classified in global trade, the strength of the evidence behind that framing becomes increasingly important. If second-hand clothing is becoming a central focus of textile regulation, how robust is the empirical foundation for treating it as a major environmental driver? It is a question that remains far less settled than current policy debates might suggest. Read more: The unresolved climate gap in textile policy Why is textile policy focusing on the smallest part of the problem?

Across Europe and in international forums, new rules are tightening how used clothing is collected, sorted and shipped. Governments are building systems to manage what happens after garments are discarded. Yet most of the sector’s climate impact occurs long before clothes are thrown away — and that part of the system remains structurally harder to regulate. Summary: EU institutions and international bodies are entering a more operational phase in textile governance. Export controls are tightening, extended producer responsibility schemes are being rolled out and classification rules are being clarified under the Basel Convention. Many of these measures are designed to address the environmental and trade risks associated with used clothing flows. At the same time, production volumes — where most emissions occur — remain outside direct regulatory limits. Addressing scale is proving more complex than regulating disposal. Further reading in this series : Why is textile policy focusing on the smallest part of the problem? How robust is the evidence behind environmental claims in the second-hand clothing trade? EU textile governance moves from strategy to enforcement Textile policy in Europe is entering an operational phase. From 2025, separate textile collection becomes mandatory across the EU. By 2028, all Member States must introduce Extended producer responsibility (EPR) schemes for textiles. These systems will require companies placing garments on the market to finance collection, sorting and treatment. National authorities are now defining fee structures, governance models and cost allocation mechanisms — decisions that will determine how financial responsibility is distributed across the value chain. At the same time, the revised Waste Shipment Regulation tightens scrutiny of textile exports. Authorities must assess whether shipments qualify as products intended for reuse or as waste subject to stricter controls. The distinction is legally decisive: misclassification can shift regulatory obligations, trade permissions and enforcement thresholds. Under the Basel Convention , technical discussions continue on the classification and reporting of used textiles in international trade. The outcome may influence documentation requirements, traceability standards and cross-border movements well beyond Europe. Taken together, these processes bring used clothing more firmly into waste governance and trade control frameworks. They are designed to improve transparency, prevent misclassification and reduce environmental harm associated with poorly managed textile flows. Political momentum behind export controls has partly been driven by claims that international trade in used clothing contributes to waste burdens in receiving countries. However, the scale and systemic impact of those claims remain empirically contested, and data gaps continue to shape the debate. Extended producer responsibility shifts financial power — but not production levels Textile EPR schemes represent a structural shift in regulatory logic. For the first time, producers will be required to finance end-of-life management at scale. This creates new financial flows, new data requirements and new institutional roles for compliance organisations and national authorities. Fee modulation — linking costs to product durability or recyclability — could influence design decisions. But EPR does not limit how many garments can be placed on the market. It redistributes end-of-life costs without directly constraining production volumes. The regulatory signal is therefore corrective rather than restrictive. Waste law is established territory. Production control is not. Upstream, policy instruments look different — and more cautious. The Ecodesign for Sustainable Products Regulation (ESPR) provides a legal basis for textile-specific durability requirements, recycled content criteria and information obligations. Digital Product Passports are being developed to improve traceability and material transparency across supply chains. A ban on the destruction of unsold textiles is being phased in for large companies, combined with reporting obligations intended to increase visibility around excess stock and corporate sustainability reporting rules now require more detailed disclosure of environmental and supply chain impacts. These measures target product design, transparency and business practices. They can extend product lifespans, improve material efficiency and increase market scrutiny. What they do not do is set binding limits on production volumes. The unresolved climate question: scale Environmental impact in textiles is concentrated at the beginning of the lifecycle — in fibre production, processing, dyeing and manufacturing. Global clothing output has more than doubled over the past two decades, while European consumption remains structurally high. Regulating waste flows builds on established environmental law and administrative practice. Regulating production volumes raises broader questions about trade policy, industrial competitiveness, consumer demand and global supply chains. There is no existing EU framework designed to cap output in a globalised industry characterised by complex cross-border production networks. The result is a structural asymmetry: regulatory clarity is advancing rapidly in end-of-life management, while production scale — where the majority of emissions occur — remains outside direct quantitative control. The tightening of rules around used clothing marks a significant shift in textile governance. Whether comparable enforceability can be developed at the production stage remains one of the central unresolved questions in EU textile climate policy. Read more: Why is textile policy focusing on the smallest part of the problem? How robust is the evidence behind environmental claims in the second-hand clothing trade?