Used textiles : Recycling industry pushes back on Basel Convention textile waste proposals

The debate over how to classify and regulate used textiles is heating up. The Bureau of International Recycling (BIR), representing over 30,000 recycling companies across 72 countries, has submitted detailed comments to the Basel Convention consultation on transboundary movements of used textiles and textile waste—and the organization's message is clear: current regulatory frameworks don't reflect how the industry actually works.

According to BIR, at the heart of the issue lies a fundamental confusion between waste and goods. The Basel Convention currently classifies textile waste under code B3030 as non-hazardous, covering both used textiles and industrial textile waste. Meanwhile, trade code HS6309 uses ambiguous language that doesn't align with either Basel classifications or industry practice, creating what BIR describes as a regulatory grey zone that hinders legitimate operators while making effective monitoring nearly impossible.

"Materials included under Basel code B3030 do not adequately reflect industry practice," BIR's submission states. "The entry 'worn clothing and other worn textile articles' fails to encompass the full range of materials usually collected in customary separate collection systems and fails to distinguish between waste and product."

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BIR is calling for policymakers to recognize three distinct categories of used textiles that currently get lumped together:

• Unsorted used textiles: Post-consumer textiles, shoes, and accessories collected and baled for export, containing mixed wearable and non-wearable items.
• Used textiles sorted for recycling: Post-consumer and post-industrial materials intended for fibre recycling and remanufacture.
• Used textiles sorted for reuse: Items professionally sorted and intended for second-hand markets—clothing, footwear, accessories, and household textiles.

Here's where BIR draws a hard line: the organization argues that items in that third category aren't waste at all. Once professionally sorted and deemed reusable, BIR contends they're goods that should be regulated through product frameworks, not waste conventions.

"Items in category (c), which have been deemed reusable after professional sorting, are not waste; they are goods, and therefore should be regulated through product frameworks, not the Basel Convention," the submission emphasizes.

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One of the most contentious questions in this debate: how much of what gets shipped internationally is actually waste? BIR has compiled data from multiple countries that the organization says challenges narratives about "waste dumping."

According to BIR's submission, in Guatemala, studies show 87.8% of imported unsorted textiles are reusable. Major retailer Megapaca demonstrated that 91.6% of its imports were reused, with only 3.27% becoming non-recyclable waste across the entire value chain.

In Ghana, Africa's leading importer of second-hand clothing, BIR reports that most retailers find between 0% and 4% waste in imported bales—with 56% of bales containing less than 1% waste. BIR cites a 2024 study at Kantamanto market that found 47% of textile waste collected consisted of tailoring cuttings rather than discarded imported garments. When researchers examined landfills and beaches, BIR notes, they found minimal textile waste—with waste streams dominated by plastics and fishing nets instead.

In Uganda and Tanzania, according to BIR's data, waste material with no economic value ranges between just 1.1% and 1.3% in imported bales. Kenya's Mitumba Association reports 2% waste content in imported second-hand clothing, BIR states.

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BIR points to Pakistan to illustrate how international textile flows support both reuse and recycling. The organization cites a 2025 study characterizing Pakistan as a major sorting and recycling hub, with 10,000 employees at the Karachi Export Processing Zone processing imported textile materials for regional and global second-hand markets as well as the local recycling industry in Faisalabad.

"In some cases, even waste generated during the recycling process is further processed and repurposed to create various products. The high valorisation of these materials is driven by their diverse range of applications, such as being used as filling materials, high-quality apparel, insulation, or non-woven fabrics," according to the National Textile University Faisalabad study cited by BIR.

BIR emphasizes what it sees as a crucial point: different regions specialize in different parts of the textile value chain. Some focus on sorting, others on recycling, and still others represent important markets for second-hand garments. The transboundary flow of these materials, BIR argues, isn't about dumping—it's about efficiency in a highly globalized circular industry.

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Beyond environmental considerations, BIR highlights that the second-hand clothing trade provides critical economic opportunities in developing countries. The organization cites data showing that in Tanzania, 98% of respondents in one study indicated the trade financially benefits their families. In Guatemala, where poverty rates are high, BIR says the sector provides accessible and stable livelihoods where formal employment is severely limited.

BIR emphasizes the gender dimension as particularly striking. In Guatemala, according to the organization's submission, 60.7% of surveyed traders were women, and 57.4% of business owners were women—more than double the national average of 27% for female business ownership. The gender wage gap in the second-hand clothing sector (17%) is also lower than the national average (26%), BIR reports.

"These socio-economic dimensions must be carefully considered, as restrictions in trade could inadvertently harm vulnerable populations who rely on this trade for livelihoods and affordable clothing," BIR warns.

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While acknowledging legitimate concerns about illegal dumping, BIR points to Chile as an example of how robust national frameworks can address waste management challenges without restricting legitimate trade.

Chile—the world's fourth-largest importer of used textiles in 2021—has dealt with illegal dumpsites in areas like Alto Hospicio. But rather than calling for international trade restrictions, Chile designated textiles as a Priority Product under its Extended Producer Responsibility (EPR) Law in 2025 and developed a Circular Economy Strategy for Textiles to 2040.

"Chile's proactive regulatory response demonstrates that robust national frameworks can effectively address waste management and circularity challenges," BIR notes. "As circumstances vary significantly across importing countries, outcomes depend heavily on local management practices, regulatory frameworks, and economic conditions."

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BIR's submission centers on three main recommendations:

1. Clearly distinguish waste from goods in international frameworks, guaranteeing that second-hand goods are not viewed as waste. According to BIR, professionally sorted items intended for reuse should be regulated as products, not waste.
2. Keep B3030 classified as non-hazardous under Annex IX of the Basel Convention. "There is a thriving global sorting and recycling industry reintroducing these resources in the economy as second-hand clothing and secondary raw materials. Change in status would greatly hinder this value chain," BIR argues.
3. Harmonize definitions across regulatory frameworks. BIR calls for consistent definitions between the Basel Convention, the forthcoming UNEP Global Guideline, and WCO HS Code classifications. The organization also proposes reforming HS Code 6309 to create six distinct categories that reflect actual industry practice (see the annex in BIR's full submission).

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BIR warns that applying Prior Informed Consent (PIC) procedures to legitimate textile trade would cause severe delays and raise compliance costs to prohibitive levels, essentially paralysing the industry.

"Applying PIC procedures would cause severe delays and raise compliance costs to prohibitive levels, paralysing legitimate trade. This would seriously impact the livelihoods of people involved in the second-hand sector in developing countries, particularly women, who represent the majority of traders and business owners in many markets," according to BIR's submission.

The organization argues the environmental consequences could be equally severe. BIR contends that restricting used clothing exports would likely increase incineration or landfilling of post-consumer textiles in the Global North, where sorting and recycling capacity isn't yet available at scale. It would also weaken second-hand clothing markets, BIR says, pushing consumers in importing countries toward new, low-cost, low-quality ultra-fast fashion—exactly the opposite of what circular economy policies should achieve.

"Inadequate sorting and processing infrastructure in exporting regions would result in the accumulation of valuable materials, disrupting collection systems. The consequent loss in collection and recycling capacity would be counterproductive to global circular economy ambitions," BIR states.

As regulatory discussions accelerate, BIR has significantly stepped up its engagement. Trade & Environment Policy Officer Bianca Mannini actively contributed to two major international consultations in late 2024: the UNEP Global Guideline for Used Textiles online consultation and the Basel Convention Secretariat consultation on used textiles and textile waste.

In December, BIR further strengthened its engagement through direct dialogue with UNEP and stakeholders on textile circularity, including targeted meetings with government representatives from several countries. The organization also monitored high-level events like the Joint Research Centre (JRC) stakeholder consultations on EU-wide End-of-Waste criteria for textile reuse and recycling, and UNEA-7 discussions on textile value chain sustainability.

Looking ahead, BIR is planning a dedicated textile recycling event to be held parallel to the BIR World Recycling Convention in May in Gothenburg, providing a focused platform for policy dialogue and industry exchange.

As BIR sees it, the fundamental challenge is ensuring that emerging policies target actual illegal dumping and uncontrolled incineration—not the legitimate global reuse and recycling infrastructure that the organization considers essential to textile circularity.

"It is essential to distinguish between illegal practices and legitimate trade within the reuse and recycling industry. When textiles are shipped for reuse and recycling through proper channels, they do not represent an environmental hazard; harm occurs through illegal dumping or uncontrolled incineration. As shown above, these practices are rare and best solved through expansion of waste management capacity," BIR argues.

The organization emphasizes it's ready to work constructively with the Basel Convention Secretariat and other stakeholders: "BIR stands ready to engage constructively with the Basel Convention Secretariat, Parties, and other stakeholders to develop practical solutions that protect the environment while supporting sustainable livelihoods and a global circular economy."

Whether policymakers will heed BIR's call for nuance over broad-brush restrictions remains to be seen. But according to the organization, the stakes are high—not just for the recycling industry, but for millions of people whose livelihoods depend on the global used clothing trade, and for the broader goal of building a truly circular textile economy.

For more information, see BIR's full submission to the Basel Convention consultation and the open letter to UNEP