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Humana calls for sorted used clothing to be considered a product rather than waste
06-10-2025
The European Commission has proposed that transboundary movements of textile waste be addressed under the Basel Convention. Discussions now underway include its possible reclassification as hazardous or problematic. Such a shift would subject shipments of textile waste to Prior Informed Consent (PIC) procedures, creating significant barriers to trade.
Humana, with almost four decades of experience in the collection, sorting, trade, and retail of post-consumer textiles, warns that this approach risks undermining the global transition to sustainable and circular textile systems.
The post-consumer textiles value chain is highly globalized. A large share of sorting and recycling capacity, as well as second-hand clothes markets, are found in low- and middle-income countries. The recovery of discarded textiles cannot be carried out at scale without them – even if reuse and recycling grow in the Global North, as they should.
Concerns that these activities are causing environmental harm in the Global South are often overstated and based on unclear or incomplete data. On the one hand, evidence shows that clothing which has been deemed reusable after sorting is indeed of good quality, and only a small fraction goes unsold in receiving markets, contradicting claims of large amounts not being fit for resale; on the other hand, imposing stricter controls on shipments of post-consumer textiles will not solve the lack of waste management infrastructure in receiving countries. Alongside refining and enforcing existing regulation, building waste management capacity is the true lever to act upon pollution – which stems overwhelmingly from packaging waste, textiles playing a negligible role.
Beyond the lack of knowledge about the reality of the post-consumer textiles value chain, the discussion on textile waste shipments is further being biased by the lack of harmonized and granular definitions of textile waste.
In this light, Humana recommends:
- Sorted second-hand clothes to be seen as a product, not textile waste. The trade of second-hand clothes must be regulated through appropriate product frameworks. The Basel Convention, pertaining to waste, is not fit for purpose.
- No reclassification of textile waste as hazardous. Applying PIC procedures to textile waste would create significant challenges for exporting unsorted post-consumer textiles and textiles destined for recycling, mainly due to the added administrative burdens and costs. This would disrupt established business models and force closures of both formal and informal businesses in the Global South. A weakened value chain would potentially lead to increased levels of incineration or landfilling of textile waste in the Global North. With reuse receding, fast-fashion would step in, intensifying environmental damage and undermining the EU’s Sustainable and Circular Textiles Strategy.
Instead, what is needed to prevent pollution while fostering a safe and dynamic circular textiles economy is:
- Clear Criteria to distinguish Waste and Reusable Textiles. Establish harmonized definitions distinguishing reusable textiles from waste, building on UNEP’s ongoing dialogue to distinguish between reusable and waste textiles and the EU’s End-of-Waste criteria work.
- Reform of Codes. Broaden the scope of Basel code B3030 to align with industry practice and promote clarity in customs; expand HS code 6309.00 into sub-codes that reflect reuse, recycling, and waste streams.
- Ecodesign Requirements. Mandate durability, repairability, and recyclability in new textiles, addressing design issues and promoting circularity at its source.
- Waste Management Infrastructure Support. Assist Global South countries in developing waste management systems through international collaboration, recognizing that textiles represent only a small share of their overall waste streams.
