A new Nordic study recommends reducing exports of lower-grade textiles to developing countries, despite uncertainty about what ultimately happens to the garments. The Textile Recycling Association warns that the proposed measures could undermine legitimate reuse and recycling markets. Where do used clothes go after leaving the Nordic countries, and what happens to them when they arrive? These questions drove a study presented in Brussels on 4 November by UK environmental consultancy Eunomia Research & Consulting and Norwegian waste specialists Mepex. The researchers combined trade statistics, industry interviews and digital trackers placed in 200 used garments from five Nordic countries. The tracking covered routes through 23 countries over six months. What the tracking revealed European sorting centres emerged as key points in the journey. Poland accounted for 30% of the garments' last recorded locations and Slovakia for 18%. Overall, 71% of the trackers last reported from within Europe. But those positions did not necessarily mark where the clothes ended up. Quality also appeared to matter. Among the lowest-quality garments, 56% had their last recorded position outside Europe, compared with 24% of the highest-quality items. The figures describe the study's limited sample, not the proportions of all Nordic textile exports. The results add detail to a familiar trading system in which garments are sorted by quality and sold onwards to different markets. The unanswered question The main gap remained. Tracking became much harder beyond the first sorting stage, and a device's last signal could not establish whether its garment was eventually worn again, recycled or discarded. The researchers could therefore not calculate how much of the tracked clothing ultimately became waste. That is a limit of what these observations establish, not proof that the exports were either waste or reusable products. Eunomia has stressed that traceability alone cannot create a circular textile economy. Better garment quality, longer product lifetimes and investment in sorting and recycling also matter. Recommendations go beyond the tracked outcomes Despite these uncertainties, the report recommends reducing exports of lower-grade textiles to developing countries. It proposes stronger downstream requirements, including management plans, reporting and minimum standards for receiving facilities. Yet the tracking did not establish that the lower-grade garments observed in African and Asian markets were discarded. This leaves a question about the evidence underpinning the proposed reduction: would keeping more of these textiles in Europe produce better environmental outcomes? The UK Textile Recycling Association has welcomed the report’s more measured approach but warned that its recommendations could undermine legitimate reuse and recycling markets. Lower commercial value does not necessarily mean clothing cannot be reused, the association argues. Alan Wheeler, UK Textile Recycling Association. “The important question is not simply where used textiles travel, but what actually happens to them when they get there,” TRA chief executive Alan Wheeler said in a press release issued on 5 November. The report itself acknowledges that restricting exports without alternative treatment capacity risks stockpiling, increased disposal and disruption to collection systems. The findings arrive as the EU changes rules for textile collection, producer responsibility and waste shipments, while potential controls on international used-textile trade are debated under the Basel Convention. For policymakers, knowing the routes clothes take is not the same as knowing their environmental fate. This study offers more detail on the former but leaves the latter unresolved. The study was conducted by Eunomia with Mepex and funded by the Norwegian Retailers' Environment Fund (Handelens Miljøfond), the Nordic Council of Ministers and Shape Foundation. The publicly available project information does not identify a single formal commissioning organisation. Sources: Eunomia — study findings New research explores how used and waste textiles are managed in global export markets (4 November 2026). Public summary of tracking results, quality comparisons and limitations. Eunomia — original report and project information Understanding Used and Waste Textiles Exports from the Nordics (2026). Study report and stated funders. Mepex — project background Norwegian project presentation describing textile tracking and interviews. Press Club Brussels Europe — report presentation Mapping Nordic textile exports: insights for a circular textile transition (4 November 2026). Textile Recycling Association — press release Textile Recycling Association welcomes Nordic textile export study but urges caution over policy recommendations (5 November 2026).

POLICY & REUSE Donated clothes can be fit to wear — yet EU rules classify them as waste when collected. New proposals spell out what it would take to sell them as second-hand clothes again. But the required checks and paperwork could prove too costly for smaller reuse businesses. Consider a shirt dropped into a clothing collection container. Its owner expects someone else to wear it. But the garment’s physical condition and its legal status are different questions. The EU’s revised Waste Framework Directive requires separately collected textiles to be treated as waste upon collection. There is an exception: items handed directly to a reuse operator and professionally assessed as reusable at the collection point can remain products. The directive requires national implementation; it does not mean every donation everywhere in Europe already follows identical rules. For clothing entering the waste system, proposals published by the Commission’s Joint Research Centre on 26 October set out how it could regain product status. These are technical recommendations, not adopted rules. From collection to sale Under the proposal, the shirt would undergo sorting and any necessary preparation for reuse. Qualified staff would assess cleanliness and functionality. Minor faults would be acceptable if they do not compromise safety or intended use. The operator would document compliance through an externally verified quality-management system. A statement confirming conformity would accompany each consignment to its next holder. JRC expects common criteria to reduce legal uncertainty. But stakeholders consulted for the report warned that certification costs could force smaller operators out of the market. JRC nevertheless retains external verification, arguing that consistent controls are needed for safety and trust. When safeguards can obstruct reuse The report also records warnings that compulsory repairs could cost more than garments are worth and push usable clothing towards recycling. JRC accepts that overly rigid appearance requirements could undermine reuse and affordability. Its approach leaves room for professional judgement and different second-hand markets. A separate JRC proposal, published on 27 October, addresses recycling. It does not allow textiles to become products merely because they have been sorted for recycling: the relevant processing and output requirements must also be met. Nor would EU product status automatically settle every export question. Under the EU Waste Shipment Regulation, disagreement between dispatch and destination authorities over whether something is waste means it is treated as waste for shipment purposes. The separate Basel Convention process is considering options for used textiles and textile waste, with comments due by 30 November. The JRC proposals do not decide that process. Sources: Joint Research Centre — preparing for reuse EU-wide end-of-waste criteria for preparing for re-use and remanufacturing of textile, textile-related and footwear waste (26 October 2026), JRC147948. Technical proposals, including quality criteria, conformity statements, stakeholder concerns and JRC’s assessment; not adopted rules. Joint Research Centre — recycling EU-wide end-of-waste criteria for recycling of textile and textile-related waste (27 October 2026), JRC147954. Separate technical proposals covering recycling processes and output requirements; not adopted rules. European Union — revised Waste Framework Directive Directive (EU) 2025/1892 of 10 September 2025 (published 26 September 2025), amending Directive 2008/98/EC. Article 22d addresses textile collection, professional assessment and sorting, including the exception for directly assessed reusable donations. European Union — Waste Shipment Regulation Regulation (EU) 2024/1157 of 11 April 2024 (published 30 April 2024). Article 29(2) addresses disagreements between authorities over classification as waste or non-waste for shipment purposes. Basel Convention Follow-up to OEWG-15: call for comments on possible options concerning used textiles and textile wastes. Submission deadline: 30 November 2026.

Turning discarded clothes into new fibres requires more than working technology. Collection, sorting and processing limit how much can be recycled — while uncertain demand, costs and investment risks hold back expansion. Two industry assessments expose the gap between recycling’s potential and its commercial reality. The findings come from two assessments published in early October: Textile Exchange’s analysis of recycled fibre availability, developed with Fashion for Good, Reverse Resources and TEXroad, and Accelerating Circularity’s assessment of financing barriers across 13 recycling routes. The implications reach beyond the recycling industry. The EU’s textile strategy makes sufficient fibre-to-fibre recycling capacity part of its vision for 2030, alongside longer-lasting products, reuse and repair. It envisages textiles made largely from recycled fibres and minimal incineration and landfill. Delivering that vision requires both workable processes and businesses that can finance and operate them. More discarded textiles does not mean more usable fibre Textile Exchange estimates that global supplies of recycled fibre suitable for spinning could rise from 1–1.5 million tonnes in 2025 to 3–5 million tonnes by 2030. The estimates cover both manufacturing waste and used textiles. But this is a modelled possibility, not a delivery commitment. Collection, sorting, processing and technology constraints mean only part of the available textile feedstock can become new fibre. The organisation also acknowledges gaps in the data. The distinction matters: textiles available for recycling, a factory’s potential capacity and fibre actually produced are different things. Collecting more clothes does not, by itself, close the loop. Working technology still needs paying customers Accelerating Circularity identifies a second barrier. A process can work at demonstration scale while the industrial plant remains too risky for commercial lenders. Recycled fibres often cost more than the virgin materials they replace. Brands’ interest does not necessarily translate into binding, long-term orders. Without those contracts, lenders lack confidence that a plant will earn enough to repay its loans. Uncertain construction costs and performance add further risks. Sorting and recycling investment can also stall together: sorters need buyers before expanding, while recyclers need reliable supplies before committing. The combined risk is that recycling expands more slowly than Europe’s ambitions require. That could delay both the replacement of virgin fibres and reductions in textile disposal. Technical progress alone will not bridge the gap: the system also needs reliable supplies, customers and revenue. Sources: Accelerating Circularity Systemic Bankability of Textile-to-Textile Recycling (6 October 2026). Framework assessing financing barriers across 13 recycling routes. Textile Exchange Textile-to-Textile Recycled Fiber Availability Data for Apparel and Home Textiles (6 October 2026). Developed with Fashion for Good, Reverse Resources and TEXroad. European Commission EU Strategy for Sustainable and Circular Textiles (30 March 2022), COM(2022) 141 final. The EU's 2030 vision for circular textiles.

REUSE & TAX Tax breaks can encourage companies to donate surplus goods. But European reuse network RREUSE warns that recipients can end up paying to handle what cannot be reused — leaving fewer resources for their social and environmental work. The company gets a tax benefit. The organisation receiving its donation gets goods it cannot reuse and a bill for dealing with them. That is the problem described by RREUSE in its response to the European Commission’s consultation on VAT and the circular economy, published on 30 October. The network says experiences in Spain and Wallonia show that corporate donation tax relief has shifted handling and disposal costs onto social enterprises already under financial pressure. Its submission does not detail individual cases. The warning raises a question for the EU’s tax review: how can governments encourage useful donations without rewarding companies for passing their waste costs to someone else? Who gets the benefit? Spain provides a concrete example of the tax incentive. Since April 2022, qualifying donations to eligible non-profit organisations have attracted zero VAT, provided the goods are used for the recipients’ general-interest purposes. Tax adviser Ángel Pérez of Baker Tilly explained in an analysis of the reform that qualifying donors also retain the right to deduct VAT paid when acquiring the donated goods. This removes a tax obstacle to giving useful products away. But making a donation financially attractive does not ensure that its contents are useful to the recipient. Goods that cannot be reused still require handling and waste treatment. If those costs fall on the receiving organisation, the donation can consume resources intended to support affordable second-hand goods, employment and social inclusion. Who pays for the rest? RREUSE wants corporate donation incentives tied to a reasonable prospect of reuse. It also calls for an explicit right to refuse donations and for donors to cover handling and waste-treatment costs. The distinction matters for the wider debate over textile taxation. Reuse News has previously reported calls for lower VAT on second-hand clothing to help businesses cover the costs of keeping garments in use. Donation incentives address a different transaction: the transfer of goods into those organisations. Both can support reuse. But RREUSE’s warning is that encouraging goods to enter the system is insufficient if the organisations receiving them cannot afford to deal with what arrives. The Commission’s consultation opened on 10 September and closes on 4 November. It will inform proposed changes to the EU’s VAT framework; no reform has yet been agreed through this process. Sources: RREUSE Answer to the Call for Evidence on VAT in the Circular Economy (published 30 October 2026). Submission describing members’ experiences in Spain and Wallonia and proposing safeguards for corporate donations; individual cases are not detailed. European Commission Public consultation on VAT and the Circular Economy (10 September 2026). Explains the review’s scope and the consultation deadline of 4 November 2026. Spanish Tax Agency VAT tax regime for product donations to non-profit entities. Official guidance on the zero VAT rate and qualifying conditions introduced with effect from 10 April 2022. Baker Tilly — Ángel Pérez El IVA en las donaciones de productos (25 April 2022). Published tax analysis explaining that qualifying donors retain input VAT deductibility. Reuse News Fashion companies demand VAT cut on used clothes (23 November 2025). Earlier coverage of calls to improve the financial conditions for second-hand clothing sales.

Claims that wealthy countries are dumping unusable clothing on poorer ones have influenced headlines and international policy. But the evidence behind some of the most widely repeated claims has proved uncertain and contested. If those claims lead to restrictions on clothing that could be reused, the consequences could extend to livelihoods, circularity and efforts to reduce emissions. In August 2021, Australian broadcaster ABC published Dead White Man’s Clothes, a report from Ghana featuring The Or Foundation. It reported that an estimated 40 per cent of imported second-hand clothing was worthless on arrival and ended up in landfill. The story gave international visibility to a powerful message: clothes donated with good intentions were becoming someone else’s environmental burden. But the certainty of that message has increasingly been challenged. Research examined by Reuse News does not securely establish that large shares of second-hand imports go directly to disposal. Some studies report substantially lower waste levels; others measure different things from the problem described in the headlines. That gap between the prevailing account and its evidential foundations is why Reuse News began investigating. A disputed picture of the trade The Or Foundation’s work at Kantamanto, Accra’s large second-hand market, helped frame discarded clothing as an issue of global injustice. Its campaign against “waste colonialism” argues that importing communities should receive funding to manage the waste associated with the trade. Industry representatives have pushed back against the portrayal of their trade as a means of dumping waste. Exporters and importers argue that they supply paying customers with reusable products, and that influential waste estimates misrepresent what happens in their markets. Ghanaian trade representatives have publicly challenged both the prevailing picture and the definitions behind it. Their commercial interest makes those arguments worth examining, rather than accepting at face value. The same scrutiny should apply to the claims they dispute. What is actually being measured? A central difficulty is that “textile waste” can describe several different things: clothing unsuitable for use when it arrives, items left unsold at a market, or garments discarded after further use. Those distinctions can disappear as findings move from research into headlines and policy discussions. Evidence of clothing at a dumpsite does not, by itself, establish that it arrived in the country as waste. Reuse News has examined the studies, traced recurring figures and conducted field reporting to ask a specific question: how well established is the claim that substantial quantities of unusable clothing are being exported as reusable goods? Our investigation found that the available evidence did not substantiate the scale commonly described. Why the answer matters The debate has reached the Basel Convention, where governments are considering how international waste controls should address textiles, including the distinction between reusable clothing and waste. Getting that distinction wrong could carry environmental costs. Reuse can reduce demand for new clothing and the resources and emissions associated with producing it. If restrictions make continued use more difficult, some of those benefits could be lost. The outcome depends on how the rules affect actual trade, disposal and purchasing decisions. The investigations collected here examine the claims, the competing evidence and the policy response. They ask whether the measures being developed address a demonstrated problem—and what happens if the diagnosis is wrong. Back to: EXPLORE - The textile waste debate

Europe has adopted tighter rules for textile shipments and is advancing international discussions on further controls. These measures could restrict reuse, affect livelihoods in lower-income countries and undermine the climate benefits of keeping clothes in use. Yet its own sources still cannot establish how much second-hand clothing is exported as unusable waste. As Reuse News reported in Shouldn’t policymakers check the facts before making policy? the European Commission declined to answer further questions about the evidence underpinning its approach to textile waste exports. The uncertainty remains, but the regulatory process is moving ahead. The European Union has already legislated to change how collected textiles are classified, sorted and shipped. From May 2027, new restrictions will also apply to exports of non-hazardous waste to countries outside the OECD. Alongside these decisions, Europe has helped bring used textiles and textile waste onto the Basel Convention’s agenda. But the evidence behind the export debate remains incomplete. The European Environment Agency acknowledges that there is little information on actual reuse rates in importing countries or the proportion of exported textiles that becomes waste. A report prepared for the Basel negotiations likewise finds that the scale and nature of textile waste flows remain inconclusive. The legislation is moving towards implementation while those basic questions remain unresolved. The rules are already adopted The revised Waste Framework Directive entered into force in October 2025. Member states must transpose it into national law by 17 June 2027 and establish textile producer responsibility schemes within 30 months of its entry into force. Producers will finance collection and the subsequent management of textiles, including preparation for reuse and recycling. The directive also changes the legal starting point for separately collected textiles: they are generally to be considered waste upon collection, with an exception for products directly assessed by professionals as fit for reuse. Shipments presented as reusable goods will require evidence of sorting or professional assessment, including records relating to the bales in a consignment. The Commission describes the purpose as preventing waste from being falsely labelled and exported as reusable clothing. The rules therefore address the boundary between a second-hand product and a waste shipment—a distinction with direct consequences for the trade. The Waste Shipment Regulation, adopted in 2024, adds another layer. From 21 May 2027, exports of green-listed, non-hazardous waste to non-OECD countries will generally be prohibited unless the destination country meets the conditions for an exemption. Waste exporters will also face requirements for independent audits of receiving facilities. These restrictions concern waste, rather than all second-hand clothing. That makes the classification of collected textiles central to determining which shipments can proceed and under what conditions. Europe is also pursuing international controls The push extends beyond EU borders. In March 2024, Denmark, France and Sweden called for a common EU proposal to bring textile waste under the Basel Convention’s control mechanisms. Their proposal envisaged prior informed consent: official authorisation before covered waste shipments could proceed. The three governments explicitly presented international controls as a way to align global regulation with Europe’s developing rules. An EU proposal at Basel’s 2025 conference sought a process for examining options. The conference subsequently placed used textiles and textile waste on its work programme, including the distinction between them. The EU also financed the preparation of the options report considered by the convention’s working group in Geneva in June 2026. That report compiles submissions from governments and observers; it is not an independent measurement of waste in exported consignments. In Geneva, the EU argued that textiles represented an emerging challenge the convention should address. Other countries urged caution. China called for technical studies before additional measures, while Kenya considered prior informed consent and changes to the convention’s annexes premature. The meeting adopted no new textile-specific consent requirement. Instead, governments and observers were invited to submit further comments by 30 November 2026, for consideration at COP-18 in 2027. International controls remain under discussion. Export volumes have become evidence of a waste problem One document illustrates how the distinction between used clothing and waste can disappear in the policy debate. The March 2024 note from Denmark, France and Sweden referred to a threefold increase in “textile waste” exports and cited 1.7 million tonnes exported in 2019. The EEA briefing reporting those figures described used textiles and explicitly acknowledged uncertainty about their quality and subsequent fate. The difference matters. An increase in second-hand trade does not establish an equivalent increase in unusable waste being shipped abroad. The EEA identifies limited and largely anecdotal evidence about what happens to exported textiles. The Basel options report records fragmented or missing statistics and stresses the importance of distinguishing waste associated with imports from domestic waste streams. Clothes arriving unfit for use, clothes discarded after a second life and waste generated by domestic consumption represent different problems. Their presence in the same disposal system does not establish how much waste was imported. The EU’s adopted measures introduce classification, sorting and documentation requirements intended to prevent waste from passing as reusable goods. The international process could lead to further controls. But the proportion of second-hand exports that is already unusable when shipped—the central measurement needed to establish the scale of that export problem—remains unresolved.

The EU is pursuing environmental rules that could reshape how second-hand clothes are traded and reused worldwide. Part of the justification is that large quantities of unusable waste are being exported as reusable clothing. But after a year-long investigation cast doubt on that claim, Reuse News asked the European Commission for the evidence. It could not substantiate the scale of the problem. The stakes extend beyond waste management. If tighter controls make reusable clothing more expensive or difficult to trade internationally, they could reduce access to affordable clothes and affect jobs and incomes in lower-income countries. They could also weaken the climate benefits of reuse if clothing is discarded sooner or replaced by newly manufactured garments. Whether those risks materialise depends on how the rules are designed and applied. But they make the evidence behind intervention consequential. Reuse News examined the studies, traced the widely repeated figures and visited locations presented as evidence of a textile waste crisis. Those findings prompted a straightforward question to the Commission: what evidence shows that this is happening on the scale claimed? The distinction matters. Clothing that is already unusable when exported is a different issue from clothing that becomes waste after further use. Yet claims about both frequently appear in discussions about the environmental consequences of second-hand trade. Several EU policy measures and proposals are intended, in part, to prevent textile waste from crossing borders disguised as reusable goods. The EU has also pressed for international action through the Basel Convention, where governments are considering options for addressing textile waste shipments, including how to distinguish waste from reusable textiles. The question Reuse News put to the Commission was about the evidence underpinning that approach: how do policymakers know that a substantial share of clothing exported for reuse is already unsellable or unusable? A year of scrutiny preceded the questions Before approaching the Commission, Reuse News had spent a year investigating the claims behind the textile waste export debate. We examined studies and policy documents, traced frequently repeated figures and conducted field reporting in Ghana and Kenya. One central claim was that 40 per cent of second-hand clothing arriving in Ghana becomes waste. Our examination found that the available evidence did not justify the certainty with which that figure was routinely repeated. We also visited locations in Ghana repeatedly presented as evidence of a textile waste crisis. The accumulations we examined consisted predominantly of plastic and other waste. They did not substantiate the picture of vast quantities of imported, unusable clothing conveyed by the international coverage. Other research pointed towards substantially lower proportions of unusable clothing than the figures dominating public debate. Taken together, the investigation did not establish a waste export problem on the scale commonly claimed. Several findings pointed in the opposite direction. Yet those claims were already helping to shape policy and international regulatory discussions. It was against that background that Reuse News approached the Commission. Asked to establish the scale, the Commission provided no robust estimate The correspondence began in June and continued into September. Reuse News asked what reliable evidence the Commission relied on when assessing exports of textile waste to African countries. We subsequently sharpened the question: what data showed that a significant share of clothing exported to markets such as Ghana was unsellable when imported, rather than becoming waste after further use? The Commission referred Reuse News to trade statistics, reports and studies. Our examination of that material found no robust estimate establishing the proportion of clothing exported for reuse that was already unusable. The sources addressed different markets, stages of the supply chain and definitions of waste. Their findings did not establish a consistent picture of the scale of the alleged problem. Trade statistics can document the volume and destinations of textile exports. They do not, by themselves, establish how much clothing declared for reuse is actually unusable. The technical replies came with a restriction: they were not to be quoted or attributed. Although Commissioner Jessika Roswall supplied a general comment on the EU’s textile ambitions, it did not answer the specific question about the scale of waste being exported as reusable clothing. In the beginning of September, Reuse News put its assessment directly to the Commission: the available research offered conflicting findings and no robustly established figure for the scale of the problem. Was that a fair reading? We explicitly requested an on-the-record response. No on-the-record confirmation or correction of that assessment followed. The correspondence does not establish why the Commission declined to address that assessment on the record. But the result is that readers are left without a public explanation of how it interprets conflicting findings, what scale of waste exports it considers established, or how uncertainty affects its case for tighter controls. An exact percentage is not a prerequisite for policy action. Governments may need to act on incomplete evidence. But that makes explaining the evidence and its limitations more important. By declining to answer the question on the record, the Commission left a central part of its reasoning unavailable for public scrutiny: how does the evidence it supplied support the intervention it is pursuing? Policy advances while the scale remains unproven The EU’s wider textile agenda addresses several concerns, including waste collection, producer responsibility and recycling. Preventing waste from being exported as reusable clothing is one part of that agenda. But where that concern is used to justify tighter controls on second-hand trade, its evidentiary basis matters. The Basel process could influence which textiles are treated as waste and what requirements apply when they cross borders. Decisions about that boundary have consequences for exporters, importers and the people whose businesses and livelihoods depend on reuse. Reuse News’s investigation questioned the scale of the problem used to support that intervention. We then asked the Commission for the evidence that could substantiate it. After months of correspondence, the Commission has not provided Reuse News with robust evidence that a substantial share of clothing exported for reuse is already unsellable or unusable waste. The regulatory process is moving forward. The central question about the scale of the problem remains unanswered.

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.

Claims that poorer countries receive large quantities of unusable clothing have become a central argument in the secondhand export debate. But how well has the problem been measured? Reuse News examined recurring studies and reports — and found that their headline figures seldom answer the most relevant questions. Over the past year, Reuse News has investigated the evidence behind claims of widespread textile waste exports. We examined reports, traced repeatedly cited figures and visited locations presented as evidence of a waste crisis. Our findings, brought together in How the myth of textile waste is reshaping a global circular system, challenged the certainty surrounding those claims. We then asked the European Commission to substantiate the scale of the problem and identify the evidence underpinning its assessment. As reported in Shouldn’t policymakers check the facts before making policy?, That correspondence ended without the Commission providing robust evidence to substantiate its concern that substantial quantities of textile waste are being exported under the guise of reusable clothing. This article examines and explains the research behind the debate. It asks which studies are available, what they measure, how reliable their findings are and what readers can reasonably conclude from them. First, define the problem The existing research measures different things and uses different definitions of waste. Each study may provide useful information, but its findings do not necessarily tell us how much waste is being exported as secondhand clothing. To assess that claim, we first need to define what we mean by waste and identify the question the evidence should answer. Only then can we judge whether the available research provides a clear answer. For this review, we define waste as clothing that, following import, is neither sold nor otherwise passed on for continued use, but instead goes directly to landfill, dumpsites or burning. Our question is therefore: What proportion of imported bale contents goes directly to dumping, landfill or burning, without first being sold or passed on in the receiving country? For this examination, that is what Reuse News means by direct waste. It is a practical test of the claim about immediate disposal, rather than a comprehensive legal definition of textile waste. The same reasoning should apply to new clothes. A shipment does not retrospectively become waste at the border because some garments later might fail to sell. Defining the question matters. Otherwise, evidence of a country’s broader textile waste problem can be mistaken for evidence that its secondhand imports arrived as waste. Measures intended to prevent dumping could then also affect clothing with a functioning market for continued use. Reuse News has assessed the publications below against this specific question. This is a focused examination of central references in the debate, rather than an exhaustive global review. Four reports associated with claims of substantial waste These publications feature in arguments about substantial waste in secondhand imports or the markets receiving them. They use different methods and definitions, and sometimes investigate different problems. None provides a secure, representative answer to our specific question. That does not make every finding invalid. It limits what those findings can establish about waste at arrival. The Or Foundation: Waste Landscape Report — Ghana, 2022 This report draws on extensive local observation and research at Kantamanto, Accra, Ghana. It estimates that 40% of clothing circulating through retail leaves as waste, while earlier research put the immediately unsellable share of a bale at around 4%. Our assessment: might give useful knowledge of the market, but no sufficiently clear calculation establishing that 40% of imports arrives as waste. The two percentages describe different stages and cannot be used interchangeably. Changing Markets Foundation: Trashion — Kenya, 2023 This report uses trader interviews and field observations to argue that 20–50% of bale contents is unsellable. Our assessment: the accounts reveal individual experiences, but their wider significance is uncertain. We have not been able to verify a clear interview total, random selection or safeguards against leading answers. Without those details, readers cannot judge whether the interviewees represent the wider market or whether their estimates establish a national waste rate. Greenpeace: Fast Fashion, Slow Poison — Ghana, 2024 This report examines discarded clothing and the environmental conditions around its disposal. Our assessment: testing garments from dumpsites can reveal what those garments contain. It cannot show what proportion of all imported clothing is thrown away. The report also draws on other organisations’ waste estimates. It contributes evidence about disposal and pollution, rather than an independent measurement of waste arriving in imported bales. Mensah and colleagues: Textile waste from fashion shops and imported second-hand clothing in the Greater Kumasi Sub-Region of Ghana — 2026 This peer-reviewed study examines 279 secondhand bales and classifies 23.8% of their weight as waste. Our assessment: the bale sample provides a concrete research base. The difficulty is what “waste” means: traders reportedly resold most of the material classified that way. The study therefore does not establish that 23.8% was immediately discarded. Answering our question requires identifying what happened after resale. What do these reports establish? They provide accounts of different problems that may be legitimate subjects for further investigation. But their percentages cannot be lined up as independent measurements confirming that substantial shares of imported clothing go straight to disposal. Some concern different stages of trade. Some rely on traders’ estimates without establishing how representative those accounts are. Some repeat earlier figures. One classifies material as waste while reporting that most of it is sold onwards. Together, they do not securely establish the large direct-waste shares often attributed to secondhand imports. That leaves a second question: what does the research show when investigators try to measure actual waste leaving a market or distinguish discarded material from clothing that continues to find buyers? Research pointing towards lower waste quantities The following four publications provide relevant evidence, although they do not all measure the same outcome. Two also share underlying research. GIZ: Assessment study — Used textiles at Kantamanto market — Ghana, 2024 Researchers investigated actual waste quantities through two field visits spanning several weeks and a ten-day collection trial paying people to deliver unwanted textiles. Once fully operational, collection averaged around four tonnes daily. The authors concluded that waste generation was far below the earlier claimed 100 tonnes a day. Our assessment: a meaningful field test challenging the higher estimates. It did not capture every disposal route or establish the waste percentage of imported bales. But its own fieldwork provides direct evidence against the claimed daily volume and should not be presented simply as support for the high-waste narrative. Full Cycle Resource: Trade in Secondhand Clothing — Uganda and Tanzania, 2026 Prepared within the UK-funded SMEP programme, implemented in partnership with UN Trade and Development — UNCTAD — this is the most extensive investigation in our selection. It reports more than 2,000 respondents and a clothing dataset exceeding 244,000 items, with 1.1–1.3% classified as textile waste. Our assessment: its structured interviews, trained interviewers, local academic partners and checks on recorded responses make it one of the strongest methodological foundations here. It also separates wearable clothing, rags and disposal. However, its selected markets and reliance on trader information prevent a definitive national estimate; the reported garment dataset is not the same as an independently audited count of every item. WasteAid/Full Cycle Resource: A study of textile waste at Owino Market, Kampala — Uganda, 2024/2025 The researchers conducted around 1,000 surveys covering market participants and report 0.9–1% going directly to landfill. Our assessment: the study asks a directly relevant question and distinguishes cheap, saleable clothing from material actually discarded. Its breadth gives the findings weight, but trader answers are not the same as independently tracking disposal. It covers one market and partly overlaps with the later Uganda–Tanzania study, so the two are not independent confirmations. Information Research Solutions, edited by Patrick Diamond: The Quality of Second-Hand Clothes Imported to Kenya and the Associated Environmental Impacts — 2023 Commissioned by the Mitumba Consortium Association of Kenya, the study includes 120 qualitative interviews with traders and other stakeholders and reports 1–2% waste. Our assessment: it addresses actual disposal, making it relevant to our question. But interviewees’ estimates were not established through a representative physical audit. The findings document reported low waste levels; they cannot securely fix the percentage for Kenya’s imports as a whole. What can readers conclude? The evidence examined here does not substantiate a general claim that large shares of imported secondhand clothing go directly to disposal. Several market studies instead report small immediate waste fractions, while GIZ’s field investigation challenges a prominent estimate of daily waste generation at Kantamanto. However,markets differ, the studies cover limited periods and places, and much of the information comes from people working in the trade. Research independently following representative shipments would give an even firmer answer. But those limitations do not make all claims equally well supported. A report about clothing on dumpsites, an estimate of waste leaving retail and an investigation of imported bale contents carry different weight when the question is waste at arrival. The GIZ findings also illustrate why each report must be read beyond its inherited assumptions. A publication can repeat an earlier estimate in its background material while producing field results that challenge the scale previously claimed. Even a small waste fraction can create substantial local costs. Clothing successfully reused will also eventually wear out. Both issues deserve scrutiny, just as they do for new clothing. Neither establishes that the goods were waste when they crossed the border. The central question remains whether imported clothing has a market for continued use or goes straight to disposal. The research should establish that distinction before its figures are used to portray secondhand trade as waste export.

The European Commission was not the only institution Reuse News approached after its investigation challenged claims about textile waste exports. Eight MEP offices received questions about the evidence. Five did not respond. The exchanges with those that did left the central question unresolved: what establishes that large quantities of unusable clothing are being exported as reusable goods? In our preceding article, Shouldn’t policymakers check the facts before making policy? , we reported how months of correspondence with the European Commission failed to produce robust evidence establishing the scale of that problem. Alongside those exchanges, Reuse News contacted members of the European Parliament, officials and researchers. We wanted to test our findings against the evidence available to those working within the policy process. The questions followed a year-long investigation. Reuse News had examined studies, traced widely repeated figures and visited locations presented as evidence of a textile waste crisis. That work had not substantiated the scale of waste exports commonly described in public debate. Several findings pointed towards a materially different picture. We therefore asked policymakers to identify evidence we might have missed. Eight offices, three replies On 8 June, Reuse News sent requests for comment to the offices of eight MEPs: Jutta Paulus, Anna Zalewska, Karin Karlsbro, Mohammed Chahim, Pascal Canfin, Sirpa Pietikäinen, Anna Cavazzini and Alice Bah Kuhnke. We asked whether they considered the available data reliable and sufficiently robust, which studies they regarded as most important, and how they responded to the findings of our investigation. In August, follow-up questions sharpened the distinction at the centre of the reporting: evidence of large textile export volumes is not the same as evidence that a substantial share of those exports is already unusable waste. The offices of Paulus, Chahim and Cavazzini replied. No replies were found from the other five offices by the time this article was prepared, despite August reminders to four of them. The responses differed. Some offered assistance or directed us elsewhere. Some supplied material for examination. They did not resolve the question of how much clothing exported for reuse was already unsellable or unusable when imported. Paulus’s office explained that she had not worked on these particular issues, suggested contacting Cavazzini and subsequently supplied a parliamentary briefing on textile trade. Chahim’s office said its team had not worked on the specific topic and could not provide an answer or the underlying data. It forwarded the request to another team. These were replies, and should be counted as such. They also illustrate the difficulty of locating an answer within the institutions considering the policy. Separate questions sent on 7 August to François Wakenhut at the Commission’s Directorate-General for Environment and Lars Mortensen at the European Environment Agency produced no substantive replies that Reuse News could identify. When the question became more specific A separate exchange with the office of MEP Delara Burkhardt provides a fuller account of how the evidence question was handled. In May, Burkhardt supplied written answers about the ban on destroying unsold textiles and the role of exports. She recognised that second-hand exports could be legitimate, while stressing the need to prevent European waste being transferred elsewhere. Asked what evidence informed concerns about exported textiles being destroyed abroad, she referred to European Environment Agency reports and journalistic investigations. After examining that material, Reuse News followed up in August. Did her office rely on any additional study showing that a significant share of second-hand clothing exported to markets such as Ghana was unsellable when imported? The reply, received on 14 September, supplied no additional study establishing that proportion. Instead, the office emphasised that its concern extended beyond clothing quality at import to the volume of discarded textiles, the consequences of fast fashion and pollution in destination countries. It also referred to contacts with stakeholders whose observations differed from Reuse News’s findings. On 18 September, we asked for those contacts or any published data, reports or documentation underlying their observations. We have found no subsequent reply. The exchange exposed an important distinction. Concerns about overproduction, export volumes and waste management can all be relevant to textile policy. They do not establish what proportion of clothing exported for reuse is already unusable when it arrives. A current problem — or a future risk? An answer from Sweden’s Environmental Protection Agency offered another explanation for tighter controls. In a written response on 25 June, the agency described measures to reduce the risk of textile waste exports as preventive, pointing to the larger quantities expected to enter collection systems as European textile collection expands. That is a different basis for intervention from evidence that large quantities of unusable clothing are already being exported through second-hand channels. Reuse News asked the agency to clarify the distinction: which actors or export flows constituted the current problem, and was Sweden’s approach primarily a response to documented exports or a precaution against future risks? The immediate follow-up explained the rules for sorting and waste classification. It did not identify the requested flows or quantify their scale. Preventing a future problem can be a policy objective. But readers need to know when that is the argument being made — and when claims about an existing problem are supported by measurements of its actual extent. Across these contacts, Reuse News received explanations, references and broader environmental arguments. What remained missing was robust evidence establishing that a substantial share of clothing exported for reuse was already unsellable or unusable waste. Unanswered emails do not prove that such evidence does not exist. But after an investigation questioned a central claim in the policy debate, the opportunity to substantiate it produced no clear answer. The Commission’s response was part of a wider pattern. The problem’s scale remained unestablished in the material presented to Reuse News, while the policy process continued. Reporting note: The eight-office count covers requests sent on 8 June. Replies from parliamentary staff are counted as replies from their offices; automatic acknowledgements are not. Separate contacts with Burkhardt’s office and other institutions are described separately. Material explicitly supplied off the record is not reproduced.

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.

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.