SMART Calls on UNEP and Basel Convention to Reject Proposals that Misclassify Used Textiles as ‘Waste’

Reclassification could dismantle functioning global circular systems and threaten millions of livelihoods.

The Secondary Materials and Recycled Textiles Association (SMART) has submitted detailed comments to the Basel Convention Secretariat and United Nations Environment Programme (UNEP), urging them to reject proposals that would reclassify used textiles as “waste,” “hazardous waste,” or “plastic waste.” SMART warns that such measures – though well-intentioned—would dismantle functioning circular-economy systems that keep billions of garments in use, sustain millions of livelihoods in developing economies, and prevent vast quantities of textiles from ending up in landfills.

“Used textiles are not waste- they are the backbone of the global circular economy,” said Jessica Franken Head of Government Affairs at SMART. “If we classify secondhand clothing as hazardous or waste, we risk destroying the very system that is already delivering really environmental and social impact at scale.” In its submission, SMART underscores that credible, data-driven research consistently shows 80–95% of secondhand clothing exports are reused, resold, or repurposed, with only 5–10% proving unwearable—contradicting outdated and methodologically weak studies often cited in international debates.

SMART’s letter to UNEP highlights several key points:

1. Evidence-based policymaking is critical. The proposed classification relies on flawed data that overstates waste volumes and ignores recent peer-reviewed studies confirming that the vast majority of exported used clothing is reusable.
2. The global secondhand trade sustains millions of jobs—particularly for women and youth—in Africa, Latin America, and Asia, while contributing to GDP and government revenues in importing countries.
3. Reuse is among the most powerful environmental interventions available. Life-cycle analyses show extending garment lifespans through reuse reduces carbon emissions by up to 70-fold compared to producing new clothing.
4. Secondhand textiles are not hazardous materials. By definition and composition, they do not meet Basel’s criteria for hazardous waste and should not be subject to controls designed for contaminated or toxic materials.
5. Textiles are not plastic waste. Extending Basel’s plastic waste amendments to apparel conflates distinct materials and would undermine legitimate reuse and recycling systems that reduce virgin fiber demand and prevent plastic leakage.
6. Global North-led restrictions risk “policy colonialism.” Imposing trade barriers on used textiles could devastate livelihoods in the Global South and drive trade underground, undermining both environmental and social progress.

SMART is calling on UNEP and Basel Convention Parties to:

• Clearly distinguish reusable goods from waste within international frameworks and trade codes (HS 6309 and 6310).
• Recognise distinct textile reuse and recycling flows to safeguard legitimate circular trade.
• Reject proposals to classify secondhand textiles as hazardous or subject to Prior Informed Consent (PIC) procedures.
• Focus regulatory efforts upstream—on overproduction and fast fashion—through Extended Producer Responsibility (EPR) measures that address the true root causes of textile waste.