Exporters operating under Article 18 controls are now being required to provide evidence demonstrating that receiving facilities are legally able to accept textile waste and recover it in an environmentally sound manner.
TRA members have reportedly faced issues with the practical implementation of the guidelines, especially where such documentation does not exist in export destinations.
TRA Chief Executive Alan Wheeler said: “What we are experiencing in England provides a very current warning about unintended consequences.
“The objective is understandable, but regulatory requirements have to reflect the systems and documentation that actually exist in destination countries.
“Trade with important markets such as India and Pakistan is being seriously disrupted and this now needs to be resolved urgently.”
Following the reports of disruption to the trade, which already faces severe difficulties, the TRA has requested urgent engagement with the Agency.
The EA has advised that the matter is being considered internally and that it will provide further information on next steps.
Wheeler added: “We need effective regulation, but it must address evidenced problems. We should not inadvertently damage the collection, sorting, reuse and recycling systems that are already part of the solution.”
Changes under the Basel Convention
The textiles sector is also facing changes under the Basel Convention, with policymakers examining how used textiles and textile waste should be treated in international movements, including possible additional controls.
The TRA called for an “evidence-led approach” and warned that poorly targeted regulation of the international used textile trade risks undermining the reuse and recycling systems that policymakers are seeking to support.
The association advised that any changes to the convention should:
- Be based on robust evidence
- Clearly distinguish reusable textiles from waste
- Take account of the potential consequences for established global reuse and recycling markets
Alan Wheeler concluded: “Before introducing additional controls, we need to establish what problem we are trying to solve, its actual scale and where in the supply chain it occurs.
“There is a real danger of policy being driven by perception rather than evidence.”
Difficulties in the second-hand textiles market
The second-hand textiles sector has faced tough economic conditions in recent years.
The industry is being flooded by “ultra-fast fashion” which has reduced the quality of second-hand clothing, while at the same time increasing supply.
Traditionally in the UK, second-hand clothing is sold to “collector, sorter and processor” merchants.
The clothing is then usually graded by quality and sent for reuse in secondary markets in Eastern Europe, Africa and Asia.
Items which cannot be sold overseas are discarded as waste via landfill or incineration.
However, the low value of ultra-fast fashion items has undermined this system, with overseas importers no longer as interested in low-grade textiles coming from the UK.
At the same time, end markets such as those in Eastern Europe and the Middle East have been disrupted due to ongoing geopolitical tensions.
Most recently, the Environment Agency introduced strict new rules around the export of used textiles, meaning merchants are having to dedicate extra resources to sorting processes.
The situation has seen textiles merchants cutting prices and collections across the sector, including the implementation of gate fees for HWRC collections – which tend to be the lowest quality.
The reduction has also led to an increase in fly tipping at textile banks as merchants struggle to keep up with collections.
View our more detailed textiles price index here.
Register for free to comment