Sorting and Collection Plants Full Because Demand In Recipient Countries Is Very Slow

But this was on the cards, wasn't it? Only a month or so ago the CTR Group, Fortune Eximports, LMB Barry, Savanna Group and Randisi Textiles had warned that a string of factors were hitting collectors. But industry (as in brands, etc) reaction was rather muted. Comments, please.
Alan Wheeler: The issues highlighted in that letter are issues that have been widely reported in the recycling trade press over the years as and when they have arisen. I myself write regular monthly and quarterly market reports for a number of national and international trade journals; so, the news of these issues is not new, but the culmination of them all is what is proving finally to be almost seemingly unsurmountable for many. 

In terms of any reaction by brands, etc, they are not really in a position to do anything that can address this matter in the short term. They put clothing and textiles on the market and on an average it takes about three years for these goods to end up in the re-use and recycling stream. Hence, we are really feeling the pinch in the decline of quality consumed during the pandemic and now. 

What is a particular problem for UK collectors and sorters is the high value that they must pay for second-hand clothing that they collect from charity shops (the unsold donations) or that they have to pay to local authorities or charities collected through clothing and textiles collection banks. In normal business situations with supply outstripping demand these prices would plummet, but businesses in our trade are always looking to survive and maintain their market share for when better times return. 

Hence, the prices are simply not going down now. We had a complete over-heating of the UK market around 10 years back. The causes were different, but the prices remained stubbornly high when they should have gone down. Eventually in 2015 the bubble burst, with one collapsing/sorting business collapsing after another. We lost about 25% of the trade during the first six months of that year and values eventually plummeted overnight.You can see current market values published by LetsRecycle.com and historic prices.

When one talks about a "collapse" it is not always easy to visualise how this would unfold into the streets and into daily life. What do you think this impending collapse will look like?
Alan Wheeler: Apart from a large chunk of businesses closing down, we will see more off-shoring of the expensive operations, which need to be reversed if we want to create green jobs here and deliver a circular economy in the UK

Pardon my harping on the same "collapse" string. If something collapses, it is probably because the foundation was not so solid and robust in the first place. Probably. Do you think so? Where and at what point do you think things went wrong? 
Alan Wheeler: There will still be businesses that collect used clothing/used textiles in the future when it will be possible to make money. Many of the businesses may have changed and as would have many of the markets. Unlike previous times though, we now have the attention of policymakers, media, public, etc. 

We now know what a huge impact the fashion industry has on the environment, and we know what huge benefits the re-use industry unquestionably brings to extending the life of clothing and reducing the need to buy new clothing (see EuRIC research). It is also becoming increasingly apparent what benefits developing more recycling markets for textile fibres and fibre to fibre recycling can bring. 

It is also apparent the support that policies such as Extended Producer Responsibly, product standards for clothing and textiles, minimum recycled content, have wide scale support from across the clothing and textile supply chain. If the UK Government had completed its consultation on EPR during 2022 which they committed to then we may have had this policy in place by now. If we did then the financial cushion that it offered could have been enough to see us through this difficult time.

The Fixing Fashion report of the Environmental Audit Committee was something of a landmark study. One doesn't get to see such studies at the government level. And yet, we have the EPR gap (that you mention in the statement). This indicates a disconnect somewhere and the lack of a coherent/comprehensive policy. Do you agree? 
Alan Wheeler: Yes (see above). We welcome the new commitments made by the UK Government in their Maximising Resources, Minimising Waste strategy towards textiles, but all these focus on collecting more textiles. What our current situation is showing is that we need support, and we need to secure new outlets, to deliver circularity.

In what ways do the export bans of used textiles by France, Denmark, Sweden, Finland and Austria affect the sector in the UK? What numbers are we talking about? For this same reason, wouldn't textile recycling be affected in other countries too?
Alan Wheeler: We heavily trade with the EU, and decisions made there will have significant impact on the way we trade.

This is a classic case of very bad information leading to very bad policy proposals. This proposal put out by the French and supported by the Danes and Swedes is full of incorrect information from beginning to end.

The proposal talks about the increase in textile wastes being exported from the EU and that 1.7 million tonnes of used textiles were exported in 2019. The majority of the 1.7 million tonnes quoted here is second-hand used clothing products and the vast majority of the remainder will be recycling grades that are sold onto specialist manufacturers. Most of this will be mechanically recycled in bedding, insulation, wipers, the automotive industry, etc. The chemical recycling industry is still very small and that is what should be able to deliver fibre to fibre recycling at scale in the future.

What is more, the EU Waste Framework Directive already either places a direct ban on the export of textile waste to non-OECD countries with the notable exception of India and Pakistan who have arguably the most advanced mechanical recycling markets in the world. When the current waste framework directive was established non-OECD countries were asked by the EU if they wanted various waste streams banned, allowed under notification controls only (a de facto ban because of costs, time and practicality) or whether they would be happy to accept the waste for recycling. 

A number of countries responded saying that they did not want the waste and exports to these countries banned. A few countries such as India and Pakistan said that they did want to take the textile waste and they had to prove that they could handle the waste responsibly. This enables us to trade these grades with these countries in a responsible manner. The majority of the countries did not respond and therefore were automatically put on the Amber list controls which require pre-notification (which the French, Swedes and Danes are apparently unaware of) and as I have said is a ban in everything but name.

I also think that what is behind this move is a pre-conceived idea that the amount of used clothing ending up as waste particularly in African countries is ludicrously high. The Or Foundation first started putting out claims about six years ago that around 40% of all clothing going into Accra in Ghana ended up as waste straight away and they were very effective at putting this message out on social media. The estimate was based on a university thesis which was not peer reviewed by anyone with a specialist knowledge of the sector. 

By their own admission, the student was not an expert and did not know what to ask or how to research. He came with the estimate through a series of interviews with traders and through a language barrier. What he did not appreciate was that traders rely on a rapid turnover of stock and what they cannot sell on their stalls after a few days they sell on at highly discounted prices to specialist traders who then sell it on into other markets. The traders call this stock that is not sold at front of store “trash” just because it has not made money from it. 

The researcher did not address these onward markets at all, and they did not make any attempt to perform any kind of waste compositional analysis of the waste leaving the market which is essential in coming up with a reasonably accurate assessment. 

The Changing Markets Foundation have published similar conclusions about goods going into Kenya, and Greenpeace and others have produced similar types of work.  But without actually looking and undertaking the detailed sampling of what is coming in and out of the markets, their estimates do not stand up to level of scrutiny that other organisations put their research through before publication.

More recently, when I spoke to the Or Foundation last summer, they said that they would be finally undertaking some waste compositional analysis. It appears they might have done because in this research published by the Dutch Government recently it says of clothing going into Ghana. “Around 4% is known as asei, meaning ‘under’, and is unsellable and immediately becomes waste. Monitoring by the Or Foundation shows an increase in asei” – Page 39 as printed in the document (click here).

This estimate of 4% ending up as waste in Ghana is dramatically different to the 40% that they have been promoting and is much more closely aligned to the 2% of clothing estimated to end up as waste in Kenya by the Mitumba Association of Kenya.

Further, similar independent research is being commissioned in Uganda and Ghana and I believe that we will see increasing evidence that the true figure of how much waste is exported to Africa is significantly lower than what has been reported. If we only had accurate, scientifically robust, peer reviewed research on which to base these estimates I don’t think that we would have seen headlines suggesting that used clothing exports could be banned.

The TRA statement also mentions fast fashion intensifying "the influx of low-quality textiles into the recycling stream." This is something that is not talked about. What is the evidence that you have seen? And, how serious is it?
Alan Wheeler: As I have mentioned—the influx of poorer quality clothing is mainly felt by the sorters who have to separate out the recycling grades and separate these out from the re-usable quality clothing before it is put up for sale.

Stepping back a bit to get the bigger picture. Do you think there is a problem with prevalent narratives and the current discourse? Only 2 months ago, TRA had to respond to the sweeping statements made in an article in the Daily Mail. Such articles and reports surely have more than one grain of truth, but then they also tend to do more harm than good. Well, often. Do you agree?
Alan Wheeler: Yes, there is a problem. Newspapers have to fill column inches, sensation sells, and the truth is not a binary issue. Journalists are also not as thorough and time pressed and when an NGO puts out “research” with headlines that can sell, it is all too easy for the journalist to accept that everything must be unquestionably true.  I would ask journalists to find out about the organisation publishing the research and whether the research has been peer reviewed by experts with sufficient knowledge and experience of the sector being analysed

So, where do we go from here? 
Alan Wheeler: The UK Government needs to progress with EPR, product standards—e.g. design for durability, design for recycling, minimum recycled content in new products etc, provide other financial support for green jobs in the textile re-use and recycling sector.

The media needs to trumpet the 4% estimate of clothing ending up as waste in Ghana and how much it has been massively revised down (and ask the Or Foundation how this estimate has changed so much) and to publish the estimate from the Mitumba Association of Kenya and findings and proposals from their growing bank of research.