This article is part of our ‘(Re)Made in Ghana’ series, which explores what one of the world’s largest circular fashion ecosystems — Kantamanto Market — can teach us about the future of fashion. Read our series on ‘Made in Italy’ here, ‘Made in India’ here, and ‘Made in the UK’ here.
A few years ago, Ghanaian American non-profit The Or Foundation tried to strike up a collaboration with a European textile-to-textile recycling startup. It was a common-sense pairing. Ghana has an abundance of used textiles, receiving some 15 million garments per week from the Global North, much of which cannot be reworn or repurposed. The recycler, on the other hand, needed feedstock, and lots of it. But an unexpected bump in the road revealed a systemic barrier to circular fashion: global shipping codes were not designed for the circular economy, and now they were thwarting progress.
Shipping codes, or Harmonised System (HS) codes, were developed by the World Customs Organization in 1983 to help customs officials make sense of global trade. The six-digit codes — of which there are more than 5,000 — are used to classify products being imported and exported between jurisdictions, and to determine which taxes and duties are owed.
“HS codes are critical to every cross-border movement of materials, because they allow customs to understand what’s being exported and imported,” says The Or Foundation co-founder and executive producer Branson Skinner. “If you trade in new garments, there are hundreds of codes, and they’re super segmented, from fiber type to garment type and any other number of nuances.” Circular products, however, have just a couple of options. As a result, Skinner says the HS codes in this segment of fashion are no longer fit for purpose. “For secondhand, you [have to] take all of that [nuance] and you scramble it up into one code, which currently encapsulates everything. In terms of transparency and traceability, we’re not setting ourselves up for success.”
The used clothing collected by The Or Foundation was imported to Ghana under HS6309, which covers worn clothing among other worn articles. Despite the fact that The Or Foundation had collected the waste textiles from resellers in the local market, sorted them by color and fiber type, pre-processed them to remove finishings and fastenings, and cut them into panels, ready to be recycled, its only option was to re-export them under the same HS code, says Skinner, because there was no other option that acknowledged the value added.
In the eyes of customs officials, the materials were still just worn articles, whether they had been processed or not, and exporting under the same code you imported something as raises suspicion, kick-starting a slew of additional questions at customs. “That creates a major roadblock at customs and brings extra scrutiny, which has massively limited our capacity to explore global partnerships for recycling,” says Skinner.
It’s not just Ghana struggling with this issue; shipping codes are thwarting circular fashion around the world. Last year, H&M-backed recycling startup Syre announced its plans to open a gigascale recycling facility in Vietnam. From the beginning, Syre had a big hurdle to contend with: Vietnam has strict regulations on the import of secondary materials such as textile waste, meaning the country would reject imports with the secondhand shipping code. Through close collaboration with the Vietnamese government and Gia Lai province — where the factory will be built — senior director of public affairs and sustainability Stina Billinger says Syre is slowly reaching a solution, but much more advocacy work is needed.
Innovators in India have faced similar challenges, says Harshitha Venati, a consultant in India’s textile waste industry, who works with textile recovery alliance Re-Start as partnership and engagement lead. “We see increasing demand for the introduction of recycled-specific HSN codes [the local version of HS codes used primarily in India]. Players across the textile recycling ecosystem are hoping to unlock fiscal incentives and other policy measures needed to stimulate investment, growth, and access to global markets for recycled textiles,” she explains. “In my view, the creation of new HS codes alone will not be sufficient to enable genuine circular economy outcomes, but if HS codes are at least differentiated up to the recycled yarn manufacturing stage, we would make meaningful progress.”
With circular fashion clusters around the world calling for HS codes to be revised, the issue is starting to gain prominence. In fact, the United Nations Environment Programme (UNEP) is due to publish a framework for revised HS codes in the coming months, with recommendations for how circular fashion could be included. Meanwhile, both the World Customs Organization (which created and maintains the HS codes) and the Basel Convention (a 1989 treaty designed to reduce, control, and manage the transboundary movement of hazardous and other waste) are weighing potential amendments, which would make it possible to differentiate between waste, worn textiles, and upcycled or recycled products fit for resale.
“It’s a no-brainer,” says professor Nazia M. Habib, founder and research center director for the Centre for Resilience and Sustainable Development (CRSD) at the University of Cambridge, who published a report on the potential of revised HS codes to accelerate circular fashion in January 2025. HS codes should not be a political issue, she adds, but simply a way for different industries to collaborate and share resources — one industry’s trash is another industry’s treasure, after all.
Expanding the scope
Alongside HS6309 are a limited group of HS codes pertaining to used textiles, be they pre-consumer, post-consumer, or otherwise. HS6310 covers rags, scrap twine, cordage, rope and cables; and worn-out articles of twine, cordage, rope, cables, or textile materials. HS5202 covers cotton waste, including yarn waste and garnetted stock. And HS5505 covers waste of manmade fibers, including noils, yarn waste, and garnetted stock. A bulletin issued by the United Nations Office on Drugs and Crime in April 2025 stated that, between these four codes, the majority of global secondhand clothing imports since 2017 have used code HS6309 — 75% by value and 85% by volume.
Habib’s report identified several specific policy reforms to transform HS codes in favor of circular fashion, chief among which is to replace HS6309 with seven new codes, which would distinguish between waste, recycling, reuse, garments, shoes, accessories, and unsorted originals. “The code needs to differentiate so that companies can buy the right input for their value chain,” she explains. Skinner suggests at least three new HS codes as a starting point: preparation for reuse, appropriate for reuse, and upcycled material.
A broader range of HS codes wouldn’t just benefit recycling companies hoping to transport feedstock; it could also help the thousands of resellers buying used clothing from the Global North in mixed bales that often include damaged or inappropriate garments alongside genuinely resellable secondhand goods. “We’re missing a business opportunity here,” adds Habib.
These calls are now being echoed across continental Europe, where incoming legislation calls for companies to use a certain amount of recycled content in new production. “Whatever customs and shipping codes are out there, they should facilitate the circular economy instead of hampering it,” says Mariska Boer, president of recyclers association Recycling Europe (formerly the European Recycling Industries’ Confederation). “I’m hopeful that things will change there.”
The ripple effect on upcyclers
Beyond taking part in recycling pilots, The Or Foundation is trying to get an e-commerce platform off the ground to sell the upcycled goods coming out of Kantamanto Market to the world. Creative director Daniel Mawuli Quist says shipping costs have been the main stumbling block. “The majority of people who want these beautiful things and can afford the things that go through this [time-intensive upcycling] process are outside of Ghana, but the price of shipping would add around 300% to the cost, which is a huge barrier,” he says. “The work we are doing on HS codes could make it easier for designers to sell abroad without us having to intervene every time.”
This is where the complexity kicks in. In order for upcyclers to obtain a certificate of origin, or other relevant documentation that would prove their eligibility for different HS codes with lower shipping costs, they would need access to technology that is out of reach for most, says Skinner. “When you’re upcycling, you don’t necessarily know the fiber type you’re working with,” he explains. “Tracking the composition tags for multiple items you’re upcycling would be an undue burden, and near-infrared scanners [which can detect material composition in the absence of a care label] are not widely available. Those are critical barriers.”
This idea of selling upcycled pieces made from the Global North’s textile waste back to the Global North was pioneered by Ugandan brand Buzigahill, run by designer Bobby Kolade. He says HS codes have been a challenge since he started selling upcycled goods to the Global North in 2022, and the price is prohibitive. “I remember the first invoice I received for domestic duties paid to the UK; I was shocked. I didn’t realise how high some of the taxes would be,” he explains. “Sometimes, it’s as much as 35% on top of the retail price, and we absorb that cost so we stay competitive with other brands.”
Originally, Kolade thought his products would benefit from free trade agreements between Uganda and the Western countries he was selling to, either waiving or subsidising the import taxes, but he quickly realised that limited HS codes had a ripple effect. “In order to benefit from these agreements, you have to ship products with a certificate of origin. Our products have a label that says ‘Made in Uganda’, but the Ugandan customs office didn’t register them in this way, because they are upcycled from secondhand clothes. I invited them to see our manufacturing process, but they didn’t understand it, even though we use industrial sewing machines and have a team of 35 people. There is no HS code for upcycled products.”
A global approach
To reform shipping codes, the fashion industry needs to take a unified global approach — something it hasn’t historically been good at. That needs to include an honest conversation about the flow of “secondary materials”, such as used textiles, and the potential unintended consequences of receiving shipments that may contain — or end up as — waste, says Billinger. “At Syre, we believe that when you are trading with this type of material, it should be controlled and strictly monitored with the highest environmental standards at the center. It cannot be an unregulated market.” She is trying to negotiate an exemption for textile-to-textile recyclers in Vietnam, to be able to import used textiles as feedstock, rather than advocating for anyone to be able to trade secondary materials.
Many others share her concerns. When it comes to textile waste, shipping codes are partly designed to stop waste from being passed around the world with no real recourse to end-of-life management. The Basel Convention — which works in tandem with the World Customs Organization HS codes — offers an insight into some of the main concerns at play. For textiles, these include heavy metals, phthalates, perfluorinated compounds (also known as “forever chemicals”), chlorinated organic dye carriers, plastics, and hexabromocyclododecane (a flame retardant often used in textiles). All of this still needs to be considered when expanding HS codes to aid circularity, says Billinger.
Likewise, there needs to be supporting infrastructure to make sure new classifications are upheld, says Venati. “For recycled-specific classifications to be effective, they need to be accompanied by integrated data systems that enable digital traceability, claim verification, and auditability,” she says. “Without this, there is a real risk that misclassification, weak enforcement, or even greenwashing could undermine not only the credibility of industry players, but also trust in recycled products more broadly — ultimately affecting consumer acceptance [of circularity].”
At the root of the shipping code conundrum is a global trade dogged by historic power imbalances, which are now codified and reinforced at every level. The key to reforming this system, says Habib, is developing the codes in partnership with the global stakeholders affected. “The main reason any institution will write policy — whether it’s at the company level or the national level — is to equalise the distribution of power,” says Habib. “We need a people-centered approach. We need to bring in the people we are trying to do this for.”
