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.

Instead, it is drowning in clothes. Across Europe, the systems that collect and redistribute used clothing are 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 is now becoming visible across the entire chain that handles used textiles. Summary Europe is collecting more textiles than ever before, while several parts of the system designed to redistribute them are under increasing strain. New rules on textile collection, tighter export controls and limited recycling capacity are reshaping how clothing moves through the system. At the same time, production volumes remain high and new garments continue to enter the market. What emerges is a growing gap between policy ambition and system reality — raising a new question for Europe’s textile policy: what happens when more clothes enter the system than it can absorb? 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. 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. 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 is already handling increasing volumes of used textiles. Collected clothes is piling up in Europe. A growing surplus inside Europe Taken together, these developments are reshaping Europe’s textile system. More textiles are being collected.Exports are subject to greater scrutiny.Recycling capacity remains limited.And the destruction of unsold garments is increasingly restricted. Each measure addresses a specific problem. But together they increase the pressure on the systems responsible for sorting, redistributing and processing clothing after use. In warehouses, sorting facilities and collection systems across Europe, operators are already reporting growing volumes of textiles moving through the system. The surplus of clothing is becoming more visible within Europe itself. 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. 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. If the mechanisms capable of redistributing or recycling clothing do not expand at the same pace as collection volumes, the pressure will increasingly shift elsewhere in the system. For now, the question remains unresolved. If Europe continues collecting more clothes than it can absorb, and fewer options exist to move those clothes elsewhere, the surplus will not disappear. It will simply accumulate somewhere else in the system.

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?

France has temporarily increased financial support for textile collection and sorting under its Extended Producer Responsibility scheme, raising payments from around €228 to €268 per tonne. The €40 uplift is intended to prevent insolvencies in a sector under mounting economic pressure. The decision comes as France’s textile recovery system faces a widening structural gap between volumes placed on the market and volumes collected. In 2024, nearly 891,000 tonnes of new textile products were placed on the French market, while collection volumes reached approximately 289,400 tonnes. Operators report falling resale values, rising logistics costs and saturated export markets, particularly in parts of Africa. The higher payment level is designed to cover a larger share of net sorting and logistics costs and preserve the collection and treatment capacity built up under the French REP system. Without intervention, industry representatives warned that bankruptcies could undermine both employment and recycling infrastructure. The measure is presented as temporary. At the same time, the government has signalled broader structural reforms to the textile REP framework, aimed at improving economic viability, traceability and domestic recycling performance. Discussions reportedly include stronger cost alignment within the system and potential financial penalties targeting ultra-fast fashion models. France’s move highlights a wider European question: whether textile EPR fees are calibrated to reflect real system costs in a market increasingly strained by overproduction and volatile second-hand demand. As the EU prepares to harmonise textile producer responsibility across Member States, the French case offers an early test of how quickly national systems can come under financial stress.

The Swedish company Circulose has announced it will restart commercial-scale production at its facility in Sweden later this year, marking a rare development for industrial textile-to-textile recycling in Europe. The plant, previously operated by Renewcell before its insolvency in 2024, was the world’s first commercial chemical textile recycling facility for cotton-based textiles and has now been revived under new ownership and a revised strategy. The restart comes at a time when the global textile recycling sector is struggling to move beyond small-scale pilots and demonstration projects toward stable industrial volumes. Across Europe and beyond, new ventures are emerging, but complex value chains, uneven collection systems and supply constraints have kept truly commercial textile-to-textile recycling rare. Recent initiatives in the United States, France and Spain have focused on building textile regeneration hubs that integrate sorting and pre-processing with recycling, but most remain in early implementation phases. Industry observers have pointed to logistics, access to consistent and quality-controlled feedstock, and regulatory uncertainty as key barriers to scaling fiber-to-fiber recycling. Textile recycling, fiber-to-fiber, is still underdeveloped for stable industrial volumes. Demand-linked production model for recycled dissolving pulp Circulose’s announcement underscores both the potential and the fragility of industrial textile-to-textile recycling. The company said preparations are underway for production to resume in the fourth quarter of 2026, with new CIRCULOSE pulp expected before year-end. The material is a dissolving pulp made from discarded cotton textiles and is designed to be processed into regenerated cellulosic fibres such as viscose, lyocell and modal. Chief executive Jonatan Janmark said the company has aligned its production plans with confirmed demand and secured commitments from eleven partner brands before restarting operations. He described the restart as a milestone for scaling next-generation materials and said the ambition is to integrate recycled dissolving pulp into existing fibre supply chains. Strategic agreements have also been signed with fibre producers, including Tangshan Sanyou, Aditya Birla Group and Jilin Chemical Fiber, aimed at anchoring commercial volumes within established viscose and cellulosic fibre production. Until new production is fully operational, orders are being supplied from existing inventory produced prior to Renewcell’s bankruptcy. Circulose was acquired by private equity firm Altor in 2024, and the company’s revised approach signals a shift toward demand-linked production rather than speculative capacity expansion in advance of secured offtake. Industrial textile-to-textile recycling in a shifting EU policy context The revival carries symbolic weight in a European context where several high-profile textile recycling ventures have struggled to secure long-term profitability at industrial scale. At the same time, EU policymakers are advancing rules under the EU Strategy for Sustainable and Circular Textiles intended to increase recycled content, strengthen separate textile collection and restrict the destruction of unsold textiles. These measures are expected to influence future demand for recycled fibres and secondary raw materials. Yet upstream challenges remain significant. Large-scale textile-to-textile recycling depends on reliable access to sorted, traceable and quality-controlled textile feedstock, an area where collection, sorting and pre-processing infrastructure across Europe is still uneven and in transition. For now, Circulose stands as one of the few examples of a commercial-scale textile-to-textile recycling facility in Europe returning to operation after insolvency. Whether this restart marks a turning point for fiber-to-fiber recycling will depend less on technology alone and more on how effectively supply chains, collection systems, regulatory frameworks and market incentives align in the years ahead.

Rising inflows, uneven material quality and delayed financing are pushing parts of the system towards instability. RREUSE and a coalition of European social and circular economy organisations has issued a stark warning: the EU’s textile collection and sorting system is under acute pressure. The statement came 18 January, just months after separate textile collection became mandatory across the EU under the revised Waste Framework Directive, and before extended producer responsibility (EPR) schemes for textiles are fully operational in many member states. RREUSE describes the situation as an unfolding crisis for collectors and sorters. Since the obligation to collect textiles separately took effect, volumes have increased significantly in several countries. However, collection is only the first step in a longer and more resource-intensive chain. Sorting, grading, preparation for reuse and potential recycling require labour, logistics capacity and stable end markets. In many regions, that infrastructure is still adjusting to the new regulatory landscape and to the forthcoming EPR framework. “The influx of disposable fashion, and therefore low quality, non-reusable and non-recyclable garments, is overwhelming recovery systems,” said Neva Nahtigal, Director of RREUSE, as part of the coordinated industry warning. She added that the organisation is “extremely concerned about what this means for the future of social enterprises across the EU.” Overflowed collection bin in Sweden. Financing gap in textile EPR rollout A central concern is the gap between rising inflows and secured financing. Extended producer responsibility systems for textiles are being rolled out across Europe following amendments to EU waste legislation, but implementation timelines, fee structures and governance models vary. In the meantime, many collectors, including social enterprises that rely on resale revenues, face higher operational and compliance costs without corresponding financial support. The result is mounting economic pressure at the front end of the post-consumer textile system. “Social economy actors are pioneers of the circular economy, reusing goods instead of destroying them. Today, we can’t afford to pay for the consequences of global overproduction,” said Eve Poulteau, Chief Executive of Emmaüs Europe. “Producers and marketers must accept the consequences of their actions and economically support our actions.” Material quality and export market uncertainty Quality is another structural challenge. As more textiles enter separate collection streams, the share of low-value or non-reusable items increases. That material must still be sorted, documented and handled in line with waste legislation, even if it cannot easily be resold or recycled at scale. At the same time, export markets for used textiles are becoming more uncertain amid ongoing debates over waste classifications, shipment controls under the Waste Shipment Regulation and tightening environmental standards in importing countries. For operators who depend on international resale channels to finance collection and sorting, this adds another layer of regulatory and commercial risk. Sequencing of reforms creates transitional strain RREUSE does not question the goals of mandatory separate collection or textile EPR. Instead, the coalition argues that the sequencing of reforms is creating strain. Collection obligations have moved ahead quickly, while financing mechanisms, market outlets and domestic recycling capacity are still catching up. The imbalance leaves local collectors and sorters exposed during a transitional period in the EU’s circular economy transition. The warning also comes at a moment when EU policymakers are tightening rules on the destruction of unsold textiles under the Ecodesign for Sustainable Products Regulation and placing greater emphasis on keeping materials in circulation. If inflows continue to rise before sorting and recycling capacity stabilises, pressure on the system could intensify further. For now, the message from parts of the reuse sector is clear. Europe’s textile collection system is expanding rapidly under new EU waste rules, but the economic and logistical foundations needed to support that expansion are still under construction. About RREUSE RREUSE is a Brussels-based European network representing social enterprises active in reuse, repair and recycling across more than 20 countries. It engages in EU policy debates on waste, circular economy and extended producer responsibility, representing organisations involved in activities such as textile collection and sorting.

Operation Demeter XI marked a shift. For the first time, textiles were treated as a priority waste stream in the World Customs Organization’s global enforcement effort against illegal waste trafficking. The result: 1,176 tonnes of textile waste were reportedly intercepted or returned across 25 operations. But when customs went looking for textile waste, what did they actually find? Customs authorities themselves have flagged a core challenge: many jurisdictions lack clear criteria  for distinguishing between used textiles and textile waste. According to the World Customs Organization’s reporting on Operation Demeter XI, participating customs administrations noted “significant regulatory gaps, particularly the absence of clear national criteria distinguishing used textiles from textile waste.” On paper, the message seems clear. Textile waste exports are presented as a growing compliance problem. Enforcement is tightening. Authorities are responding. But the first textile-focused results raise a more complicated question. What exactly counts as textile waste under current customs and waste law frameworks? Textile waste classification under the Harmonized System Operation Demeter was designed to combat illegal trafficking in hazardous and regulated waste streams. In previous editions, the focus has been on plastics, e-waste and other materials where the economic logic is straightforward: treatment is costly, compliance is strict, and the incentive to externalise disposal costs can be strong. But textiles are different. Used clothing is not automatically a negative-value waste stream. It is also a global commodity, traded in established markets, sorted by grade, priced by quality and resold across continents. Millions of tonnes move annually through commercial channels that depend on resale value rather than disposal. In many importing countries, lower grade clothing is very far from a europeans definition of waste. It is cheaper clothing within an established secondary market. When such a market is examined through a waste enforcement lens, classification becomes central. Under the Harmonized System, used clothing intended for reuse falls under HS 6309. Textile waste and rags fall under HS 6310. In practice, however, the boundary between the two is not always self-evident. It depends on declared intended use, degree of sorting, quality thresholds and, crucially, market context. A garment deemed unsellable in a European sorting facility may still carry value in a different market segment elsewhere. In many importing countries, lower grade clothing is not automatically waste. It is cheaper clothing within an established secondary market. Waste law, by contrast, operates on a binary basis. A shipment must be declared either as goods for reuse or as waste subject to stricter controls under waste shipment rules. What the Demeter XI figures show – and do not show The 1,176 tonnes reported under Operation Demeter XI sound significant. Yet in the context of the European Union’s annual textile exports, which run into the millions of tonnes, the volume represents a small fraction of overall flows. A targeted enforcement operation will by design identify irregularities. What remains unclear from the publicly available information is how many of the intercepted shipments involved deliberate illegal waste trafficking, and how many reflect disputes over customs classification, documentation, contamination levels or quality thresholds. The operation demonstrates that authorities are scrutinising cross-border textile flows more closely under waste shipment control regimes. It does not, at this stage, quantify the scale or nature of systemic illegal textile waste exports. Waste shipment enforcement meets the global second-hand textile trade The tension may lie less in criminal intent and more in regulatory design. Hazardous waste enforcement frameworks assume a relatively clear boundary between valuable goods and unwanted material. The global second-hand textile trade does not operate along such a clean line. It is a graded market, shaped by income levels, repair cultures and price sensitivity. What one market rejects, another may absorb at a lower price point within a functioning resale system. When customs officers are asked to draw a binary line within that spectrum for the purposes of waste shipment enforcement, ambiguity is almost inevitable. Operation Demeter XI may therefore reveal not only instances of irregular shipments, but also the structural difficulty of applying waste law and customs codes to a functioning global resale market. The question now is not simply whether textile waste is being illegally exported. It is whether current waste shipment enforcement tools and textile waste classification rules are capable of distinguishing waste from value in a trade flow that does not fit neatly into either category.

A coalition of European industry organisations, including EURATEX, Landbell Group and the Global Fashion Agenda, has issued a joint statement raising concerns over a growing shift in some EU Member States toward state-run Producer Responsibility Organisations (PROs) within new and emerging Extended Producer Responsibility schemes. The signatories argue that moving responsibility away from producer-led governance risks weakening core EPR principles, reducing incentives for investment and eco-design, and creating fragmentation across the Single Market. They also warn that blurred boundaries between regulators and operators could undermine transparency, and that EPR fees may increasingly be treated as public revenue rather than a policy tool grounded in the polluter-pays principle. The statement highlights a widening governance debate as textile EPR systems take shape across Europe: whether responsibility should remain primarily producer-driven, or increasingly be administered through state-controlled structures.