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The European Commission last week released its proposal for an extended producer responsibility (EPR) scheme for textiles, a much-anticipated report meant to hold companies responsible for the full lifecycle of the clothes they make.
The aim is to create a funding mechanism to finance the services and infrastructure that will be necessary to accommodate the separate collection of textiles that all EU member states are required to have in place by January 2025, with the aim of moving fashion towards a circular model. Per the proposal, fashion brands and textile producers would be required to pay fees that can fund the creation of those services
However, equally notable is what’s not included in the proposal. The Global South is where textile and clothing waste accumulates en masse, but the report does not mention cleanup efforts, nor directly address the burden this part of the world carries or recognise how that burden needs to change. It does not set a limit on total production volumes, and neither does it lay out a distribution plan for the funds generated through EPR, an oversight that could mean funding remains in Europe even though the waste does not.
“These are not our clothes. It’s coming from other countries, it’s not part of our waste generation at all,” says Solomon Noi, director of the waste management department at the Accra Metropolitan Assembly in Ghana, said to be the single largest importer of used clothing in the world.
Evidence of the problem is abundant on the beaches of Accra. Cleanup groups organised by local advocacy group The Or Foundation, in collaboration with Accra’s waste management department, regularly gather to pull tangled webs of clothing from beneath the sand — clothes that have wound their way to the beach because the markets of Accra are so saturated, textile waste overflows into the sewer system. Members of the community, including The Or Foundation team, resell, repurpose and upcycle as many clothes as they can before they end up as waste, but it’s never enough. It’s this type of work that is not accounted for in the EPR proposal. The European Commission did not respond to requests for comment before time of publication.
If passed, the policy would amend the Waste Framework Directive to establish EPR in the fashion industry, as well as in the food industry, which are among the resource-intensive sectors on the continent yet do not “fully adhere” to the waste hierarchy principles that prioritise prevention of waste, followed by reusing and recycling it. It would not itself establish EPR for clothes across all of Europe, but instead would require EU member states to establish their own policies. The European Commission says the main goals — informed by meetings with key stakeholders across the value chain — were to ensure that EPR schemes enforce the waste hierarchy “by setting quantitative targets for waste prevention and preparation for re-use” and to create a harmonised approach to eco-modulation of EPR fees and fair competition in recycling markets, among others.
The paper focuses heavily on tackling illegal exports and emphasises the need for better sorting of clothing waste, saying the goal is to improve textile waste management according to the principles of the waste hierarchy and prioritise “collection, sorting, reuse, preparing for reuse and recycling infrastructure”. To minimise the financial burden on small businesses, it would also exempt “microenterprises”, defined as companies with 10 or fewer employees and representing, according to the commission, 88 per cent of all companies in the sector. (The report does not specify how this figure was calculated, or how much waste these businesses account for.)
Illegal exports are not a key issue in the textile trade, though; most of the clothes that make their way to places like Accra’s Kantamanto market do so legally through global secondhand clothing trade. And sorting and recycling only improve the ability to handle clothing waste responsibly if other aspects of waste management — from infrastructure creation to reducing overall waste volumes — are put into place as well.
“Where does it end up? Who does it end up with? What does it do to the environment? You’re trying to tackle environmental and climate change, and you button [the textile waste problem] up to just sorting?” Nabia Chambas, an outreach manager and researcher at The Or Foundation, said during a meeting the organisation held at its office this week to discuss the EU proposal. “How does sorting, or re-sorting or whatever they want to do about sorting, have anything to do with the impacts on the environment? You are not actually tackling anything.”
Also not mentioned in the proposal is how much money companies will need to pay into the EPR fund or, more importantly, a call to distribute those funds to places that are already on the receiving end of the world’s clothing, such as Accra.
“This regulation is about making more money from textile waste, not rewarding Africa for taking textile waste from Europe and other continents,” says Elmar Stroomer, founder of Africa Collect Textiles. “I would like to see an exchange between Europe and Africa. We need more bins in the streets to collect more; we need chemical recycling plants; we need workshops on ecodesign. It’s all needed — but, I think most of the money should first go towards installation of waste management and circular textile systems in the receiving countries.”
After the proposal was released on 5 July, the European Environmental Bureau (EEB) issued a response saying it “may lack teeth to effectively slash overproduction and waste” in food and textiles. The EEB criticised the proposal for lacking separate targets for textile waste prevention, collection, reuse and recycling in the proposal, “despite a clear call from members of the [European] Parliament to do so when they adopted the EU Textile Strategy on 1 June”, and said that EPR should support communities in the Global South “who deal with unmanageable amounts of EU exports of clothing cast-offs”.
Back in Accra, Kennie Oforiwa MacCarthy, product development coordinator for The Or Foundation, sits inside a warehouse where the organisation is finding ways to upcycle some of the T-shirts that retailers at the market were unable to sell because they had arrived too stained, too torn, or never had much value to begin with. They would have likely ended up on the beach or at one of the city’s informal dumpsites, but The Or Foundation is looking for ways to repurpose as many of them as possible.
Sitting in the shadow of over 100,000 of such T-shirts — compressed into bales that are stacked about 10 feet high — MacCarthy says this is the kind of work that EPR funds should be paying for.
“These are the clothes — they are here,” she says, gesturing to the bales in front of her. “We don’t produce them. We have managed to recirculate what we can.” However, with 30 million people living in Ghana and 15 million garments estimated to arrive in Accra every week, the numbers don’t add up. “Very obviously, some of that will end up as waste. That waste should be someone’s responsibility.”
With additional reporting by Bella Webb
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