I am writing this submission to you as Director of the Textile Recycling Association (TRA), the UK trade association for collectors and processors of used clothing and textiles. We were established in 1913 and were a founding member of the textiles division of the Bureau of International Recycling (BIR) in 1948. I also hold the official position of General Delegate (General Secretary) of the Textiles Division at the BIR.
TRA members represent around 70% of the established industry in the UK which has a turnover in excess of £500 million a year.
The issues affecting the sustainability of the entire UK clothing supply chain are complex and nuanced. I recommend reading the article “A Stich in Time” which I wrote and was published in the trade publication “Recycling and Waste World” in 2017 (click here).
However, I would like to concentrate on the particular considerations that need to be addressed that impact on the clothing re-use and recycling industry.
The key points can be summarised as follows:
1) Fast fashion is growing at an unsustainable rate with consumption rising around 5 times since the 1980s. The industry now accounts for 8% of all global greenhouse gas emissions.
2) Consumption of new clothing is higher in the UK than any other European country – 26.7kg per capita.
3) Existing markets for re-usable/recyclable clothing are under severe pressure and will not be able to cope with the extra influx of used clothing that would ensue as the global fashion industry moves towards a circular economy.
4) China has rapidly become a market leader in the export of used clothing and if it continues at its rate of expansion, existing markets for used clothing will become saturated.
5) Existing markets are also under threat from misguided political policies which threaten to shut down important international markets.
6) There is an urgent need to support existing domestic and international markets for used clothing and recycling textiles and to develop new markets and new recycling processes.
7) Consideration should be given as to whether Extended Producer Responsibility on clothing could be introduced in the UK that incentivises improvements in the sustainability of the UK clothing supply chain, supports UK collection, sorting and processing of clothing, facilitates R&D into new markets and new recycling processes and which promotes publicity to international Governments and the public on the need to support sustainable fashion initiatives and the used clothing sector.
No – The recent report “Measuring Fashion” published by Quantis estimates that the apparel and shoe industry accounts for around 8% of all Greenhouse gas emissions globally and consumption of new clothing is approximately 5 times as much as it was in the 1980s. In the UK we are now buying about 1.1 million tonnes of new clothing every year and it is estimated that household expenditure rose from just over £4 billion in 2001 to around 14 billion in 2015. Our demand for new clothing seems to be insatiable, growing at an almost exponential rate, with no regard for its environmental impact or the social impacts felt particularly by those who work in textile production. A recent report commissioned by the European Clothing Action Plan (ECAP) estimates that the UK consumes around 26.7kg of new clothing per capita. This compares to a consumption rate of 16.7 (Germany), 16.0 (Denmark), 9.0 (France), 14.5 Italy, 14.0 (Netherlands) and 12.6 (Sweden). Click here and view Table 4.
At the end of its useful life this glut of clothing is either simply being dumped in the bin (around 380,000 tonnes p.a.) or sent for re-use and recycling (about 650,000 tonnes p.a.). The re-use/recycling industry is the most sustainable part of the clothing supply chain and it is actors operating in this field that are having to deal with the sheer volumes of clothing that have been put on the market by the fashion industry and consumed by the public, once these products are no longer wanted by their original owners and it is our sector that has to find markets for these items.
Additionally, it is important to understand that circularity in the clothing industry can only be achieved by the presence of the re-use/recycling industry. Whilst efforts to improve the environmental credentials of other aspects of the clothing supply chain are important (e.g. by switching to sustainable fibres) these do not address circularity issues but merely improve the sustainability of linear business model that still largely exists.
If the fashion industry is serious about achieving circularity then designers, manufacturers and retailers must consider the re-use/recycling issues for the products that they put on the markets and take into account their responsibility for ensuring that this happens.
Although it is noteworthy that the amount of used clothing that we collect per head of population in the UK is high, we also consume considerably more new clothing than our European counterparts and our markets for used clothing are under severe pressure.
Of the 650,000 tonnes currently collected annually, about 30% is sold in the UK (e.g. through charity shops, online sales, vintage shops, boot fares etc). Most of the rest of the clothing is exported for re-use either in Africa or Eastern Europe. The 3 biggest exporters of used clothing globally are the USA (which accounts for about 15% of all exports), followed by the UK and Germany (which both export around 10% of all used clothing). The fact is only a handful of countries account for the significant majority of all used clothing/textiles collected, with the majority of countries not collecting anywhere near enough to make the global clothing industry sustainable. Most countries in the world need to dramatically improve their performance. However existing markets would not be able to cope with the ensuing increased supplies of used clothing.
We are already seeing a dramatic increase in the amount of clothing being collected by China. According to data from the Observatory of Economic Complexity, in 2010, China only accounted for only 0.88% of all exports of used clothing globally (by value). It was not a significant player in the market at all. However, by 2015, China’s exports had shot up dramatically accounting for 6.4% of all global exports and were the world’s 5th largest exporter. Data from 2016 showed that China had become the 4th largest exporter of used clothing.
It is also noteworthy as to where China is exporting its used clothing. Kenya is a really important market for the UK. It is largest export market in East Africa for the UK, and the third largest in the world. However, China is now the biggest exporter of used clothing into Kenya. In 2010 China only accounted for 0.18% of imports into Kenya by value, by 2015 this had shot up to 29%.
Whilst of course it is vital that other countries improve their own collection and recycling rates, this is nevertheless creating a major problem in the markets. What is even more worrisome is that although China is now a major player in the global export market, the Chinese are still collecting a tiny fraction of the used clothing that is potentially available to them. They have the potential to completely swamp the existing markets. Additionally as I have already pointed out need to improve their collection rates for re-use and recycling, one has to ask where all this used clothing and textiles are going to go? This issue needs to be addressed now.
On top of the increased competition from China, we are also experiencing threats from various Governments to either ban or impose punitive import duties on used clothing into their countries (creating a de facto ban). Most recently this threat of a ban was made by member states of the East African Community (Kenya, Tanzania, Uganda, Rwanda, Burundi and South Sudan). Most member states have now reneged on this decision but Rwanda is still holding out.
The rationale behind this decision is misguided as the Governments have asserted that used clothing imports are largely responsible for struggling textile production in their countries. This is not the case. The main reason as to why textile producers in Africa are struggling is the abolition of the World Trade Organisation’s Multi Fibre Agreement (MFA) in 2005. The MFA was established in the early 1970s with the intention of protecting the jobs of textile producers in the west. It did this by placing strict quotas on the amount of clothing each developing country could export to the west. In effect, what the MFA actually did was limit the amount that major textile producers (such as those on the Indian Sub-continent and later China) could export and enabled textile producers in other parts of the world (e.g. Africa) to take up the slack. I.e. the MFA favoured African textile producers and enabled them to trade. When it was abolished on 1st January 2005, the rug was pulled completely from under the feet of textile producers throughout the world (including Africa) who were all of a sudden, simply not able to complete with China. During the first few months of 2005 exports from China to the west doubled and most of the rest of the world have not had a look in.
You may also find this opinion piece that I wrote for Geographical Magazine in 2015 useful (click here).
There is also a view extolled by some that the west exports low quality and waste textiles to the African market. This view is unfounded. The used clothing industry operates in the global market place and if an exporter were to try and sell low quality clothing or rubbish to an African wholesaler, they would not get repeat business and soon go bankrupt. This assertion is back up by some recent research (Export of Nordic Used Textiles – Fate, Benefits and Impacts) that was commissioned by the Nordic Council of Ministers who looked into exports of used clothing from the Nordic Countries and other European countries to Africa last year.
Taking the above into account it is important that the UK Government understands that used clothing industry is not the main factor behind struggling textile production in Africa and does not export waste and it is important that the Government uses this knowledge to work with the industry to communicate these messages to relevant Government’s abroad and to the wider public to help keep these vital used clothing markets open. If further research is needed to verify what I have stated and to satisfy the Government that this is the case then the TRA would welcome this.
It would also be helpful if the UK Government could use its leverage to encourage African governments to develop the equivalent of manufacturing jobs in the textile sorting and recycling industry. Currently most jobs created in the used clothing sector in Africa are either in the wholesale import sector or retail in markets. However, the Frip Ethique initiative run by Oxfam has demonstrated that there is a real opportunity to develop manufacturing equivalent sorting and processing jobs within Africa. These are highly sought after jobs, with good working conditions and it instils pride in the local community. Ultimately when an African Government states that it wants to support the textile production industry, it is my view that really they want to create manufacturing jobs and they see textile production as an obvious answer. If we are to have a truly circular economy for the fashion industry then I believe that it will be important to protect existing re-use markets by establishing more projects such as Frip Ethique and creating more manufacturing equivalent jobs in the used clothing and textile recycling industry in Africa. Additionally, a newly created textile recycling industry in Africa, could end up supplying textile manufacturers in that part of the world.
You may also be interested to know that the Textile Recycling Association has been working with Bangor University and the World Bank on developing proposals to create more jobs in Africa and we would be happy to share our ideas with you.
More recently, the Bulgarian Government has announced its intention to introduce a levy on all used clothing sold there because it wants to discourage such sales. This proposal is real and if it goes ahead there is a concern that other Eastern European countries may implement similar proposals. Not only is this worrying on environmental grounds but it also goes to highlight that there is a huge amount of work to be done in not only changing both the public’s and politician’s attitudes. The Bulgarian Government should be proud that it’s used clothing domestic market is doing so well and should be trying to position its country as a global leader in promoting domestic re-use of clothing.
As well as protecting and trying to establish new markets for re-useable clothing, it is really important to develop new markets and new processes for fibre recycling. The actual ability for our sector to recycle fibres is the Achilles Heel of our industry and is perhaps the biggest stumbling block that the fashion industry will need to overcome if it is to achieve actually circularity and not merely an improvement of the current linear industry.
Current recycling processes (largely mechanical) actually damage the original fibre and shorten the fibre length. This limits the options and range of markets for recycled fibres and in most cases once the fibres have been recycled and used to make new products, they can only be recycled once. Demand from these existing markets are low and hence the value that can be attained for textiles that have to go for recycling are much lower than that are of used clothing.
Whilst the importance and environmental benefits of existing recycling markets should not be overlooked (e.g. recycled textiles used to make insulation will last for decades and help to reduce greenhouse gas emissions), it is only through the development of new markets and new applications for recycled fibres that demand for this grade will be stimulated. This will ultimately improve the economic viability of collecting and processing more of this grade and greatly facilitate progression towards circularity for the fashion industry.
There are many different R&D projects going on in various parts of the world. A few worth mentioning include:
Click here to find out more about Eco Tlc.
Click here to read their newsletter (in English) with information about their funded projects.
In addition, WRAP have recently undertaken some research into the implementation of new Fibre to Fibre recycling technologies in the UK should they become technically and economically viable. I ask members of the Environment Audit Committee to take note of the recommendations made when this research is published (due shortly).
In this submission, I have identified a number of key issues that are also summarised at the beginning of this document.
To address all these issues will cost money.
As I have mentioned France has already introduced an Extended Producer Responsibility scheme for clothing. In addition, the Nordic countries are taking a serious look at introducing similar schemes (particularly in Sweden). Some detailed research has been published by the Nordic Council of Ministers about this.
Furthermore WRAP are currently undertaking some research into the economic viability of introducing Extended Producer Responsibility (EPR) on clothing in the UK. Again I would urge members of the Environment Audit Committee to give serious considerations to its findings when it is published.
The TRA recognise that EPR on clothing is not the silver bullet that will make the fashion industry circular in the UK. However it may have a significant role. It is only right that the fashion industry, which generates billions of Pounds in revenue every year, by putting clothing onto the market, should take some responsibility for improving the sustainability of the products and improving re-use and recycling rates.
Since the introduction of the scheme in France around 7 years ago, collection rates have increased significantly, albeit from a low starting point, R&D is being funded, there is a notable amount spent on publicity to help promote collections and about 97% of retailers are legally compliant. So on these issues the EPR scheme is clearly delivering important goals.
If it would help the committee, I know the person well who was the main architect of the EPR scheme in France and I would be happy to ask them if they would be prepared to provide information about their own experience.
I hope that you find what I have written to be of interest and I would be happy to discuss any of the issues I have raised.
August 2018