Trade Barriers on Second-Hand Clothing Disrupt a Globally Significant Reverse Supply Chain

Then, there's the other side to the story. While US exporters could lose out on export revenues, it is equally true that many countries are increasingly against—fervently so—importing goods that are seen essentially as dumping of textile waste. Reactions, please.
Brian London: We fully recognise that concerns about textile waste are driving many of the policy conversations around imports of second-hand clothing: and in some cases, those concerns are valid. But the idea that second-hand clothing imports are dumping is often based on incomplete narratives or outdated assumptions. The reality on the ground is more complex, and much more hopeful.

In many of the countries where these goods arrive, local authorities and market participants have made clear that they don’t want to end the trade: they may want to improve it. We’ve heard this firsthand from our partners in Ghana and Kenya, who are asking not for bans, but for better infrastructure, improved quality of new clothing to allow for longer life of garments and shared responsibility in managing the waste that does arise. We agree with them. That’s why SMART has been focused on supporting traceability, helping implement quality benchmarks, and rolling out tools like our Used Clothing Sorters Code of Conduct to promote consistency across the industry.

This isn’t about dismissing the environmental concerns: it’s about addressing them in a way that doesn’t punish the people and communities who benefit most from the trade. We’re committed to working with local governments, market associations, and global policymakers to build systems that prioritise reuse, reduce the small fraction that becomes waste, and create real circularity. It’s not a perfect system yet, but with the right collaboration, it can be one of the most impactful parts of the global sustainability solution.

There'a a corollary question to that. If and when there's a situation that the US (or even other countries of the Global North) are no longer able to export SHC, then they will have to deal with clothing waste in their own countries. How equipped is the US to deal with such a situation? Will we see huge clothing dumps like we see in African countries? 
Brian London: The honest answer is: the US isn’t currently equipped or likely to be equipped to handle the full volume of post-consumer textiles without access to international reuse markets. Our domestic recycling infrastructure simply isn’t scaled to absorb what would otherwise be exported, and in many regions, even basic textile collection systems don’t exist. If we suddenly had to manage all of that clothing internally, we’d likely see a sharp increase in textiles going straight to landfill: something we’ve worked extremely hard to avoid for decades.

And it’s not just about capacity: it’s about systems. We don't yet have nationwide mechanisms for sorting, reprocessing, or redistributing used textiles at scale, nor the circular business models needed to make it economically sustainable. Without careful planning and significant investment, cutting off exports would risk creating exactly the kinds of waste accumulation scenarios that critics accuse the industry of engaging in now.

This is why SMART continues to support both the expansion of domestic recycling solutions and the maintenance of global reuse pathways, with the latter being what has been efficiently keeping these goods out of landfills for decades. When other recycling solutions are available and cost effective, we are ready, willing and able to engage and supply them. Until the infrastructure exists to process everything we discard, international reuse remains not only practical but essential to preventing our own version of the very problem we all want to solve.

The interplay between SHC/waste and global trade is becoming crucial. With increasing calls for self-sufficiency in textile waste management, do you foresee a major shift in global trade flows, or will the current patterns persist despite regulatory pushback?
Brian London: There’s definitely growing momentum around the idea of self-sufficiency in textile waste management: especially in regions like the EU, where policy is quickly evolving. But while the ambition is clear, the infrastructure and market dynamics haven’t yet caught up. As a result, we don’t foresee a viable path to altering the global trade flows of second-hand clothing in the near term. Instead, what we expect is a period of transition: where trade continues, but with more regulation, more scrutiny, and hopefully, more collaboration.

That shift is already happening. Countries are exploring ways to build domestic recycling capacity, and there’s more interest in keeping materials local where feasible. At the same time, the demand for second-hand clothing in much of the world remains incredibly strong and only growing, and the supply from countries like the US continues to far exceed what can be processed or resold domestically. That imbalance means cross-border flows will likely persist for some time, especially if they’re managed transparently and responsibly.

For SMART, this isn’t about choosing between trade and self-sufficiency, it’s about designing a smarter system that balances both. We see an opportunity to align reuse and recycling more closely with local goals, while keeping global pathways open for quality, wearable goods. The future may look different, but the principle remains the same: keeping clothing in use, wherever that use makes the most sense, is a win for everyone.

A related question: With escalating trade tensions between major economies, particularly the US, EU, and China, how do you anticipate the shifting tariff regimes will impact the movement of both second-hand clothing and post-consumer textile waste?
Brian London: While second-hand clothing isn’t usually at the centre of global trade disputes, escalating tensions between major economies (particularly the US, EU, and China) could have meaningful side effects for our industry. Of course, we oppose any obstacle to free trade of our product which provides so much benefit around the world. Importing wiping cloth and other materials into the US is a crucial part of the industry which stands to be disrupted. Retaliatory tariffs in previously open markets are also a concern. Tariffs on related goods, shipping disruptions, or changes in customs classifications can all impact the movement of post-consumer textiles, especially in how materials are handled, valued, and labelled across borders.

What we’re watching most closely is how differing regulatory approaches might create friction. For example, the EU is moving toward stricter definitions of what qualifies as “waste” versus “reusable textiles,” and those classifications could affect exports and imports far beyond Europe. If other regions don’t align, we could see a patchwork of rules that complicate global reuse flows, even if unintentionally.

At the same time, these tensions could accelerate regionalisation in the circular economy: more localised sorting, recycling, and resale. That’s not inherently a bad thing, but we want to make sure second-hand trade doesn’t become collateral damage in larger geopolitical battles. For SMART, the goal is to ensure the circular economy remains a shared international priority. Whether it’s tariffs or environmental policy, our industry thrives when goods can move responsibly and predictably.

Many regions, especially the EU, are tightening regulations under Extended Producer Responsibility (EPR) frameworks. Do you see EPR as a potential threat to the existing second-hand and recycling industry, or can it be leveraged to formalise and expand the sector? How do you expect this to play out in the US?
Brian London: We see Extended Producer Responsibility (EPR) not as a threat, but as a real opportunity, if it’s done right. The key is ensuring that reuse is prioritised within any EPR framework, not overlooked in favour of more costly or less impactful downstream solutions. Reuse should be recognised as the most efficient and environmentally beneficial outcome for post-consumer textiles, and SMART has been advocating for that to be clearly written into policy.

In Europe, we’re seeing EPR evolve quickly, with increasing attention to transparency, traceability, and measurable outcomes. That momentum is reaching the US as well: California recently passed the country’s first textile EPR bill, and SMART was actively involved in shaping it. We’re working to ensure that as other states follow suit, existing reuse and recycling infrastructure, like the networks our members have built over decades is not only protected, but integrated and strengthened.

EPR can be a catalyst to scale the circular economy, bringing in long-overdue investment. But it has to be inclusive of the players already doing the work. That’s where SMART comes in: helping design systems that are practical, effective, and built on what works. We’re not trying to reinvent the wheel: we want to make that wheel turn faster!

Many brands now tout their textile recycling initiatives, yet only a fraction of discarded clothing is actually repurposed. Do you believe major fashion brands are truly committed to circularity, or is this largely a narrative of greenwashing? Is SMART working with brands in the US on this?
Brian London: There’s no question that brand messaging around circularity has ramped up in recent years… everyone wants to talk about “closed loop recycling” and we understand why that is a topic of such interest. But the follow-through still has a long way to go. Most of what’s promoted as textile recycling today ends up being either resale through third parties, downcycled into lower-grade products, or not recycled at all. So yes, there’s been some greenwashing. But there’s also a growing recognition among brands that circularity can’t just be a marketing line, as the public is increasingly scrutinising as are regulators. It has to be built into how they design, collect, and take responsibility for what they produce.

We’re seeing more brands begin to engage more meaningfully, especially as EPR laws gain traction and consumers demand real accountability. SMART members have been involved in conversations with brands and organisations representing them like the AAFA to discuss the realities of reuse and post-consumer textiles. In many cases, our members are the ones quietly powering the back end of brand take-back programs: sorting, grading, and helping route clothing to its next best use.

Our message to brands is simple: infrastructure for circularity already exists: you just need to partner with it. If done right, brand involvement can bring needed resources and scale to the reuse economy. But that starts with transparency and a willingness to work with the people who’ve been doing this work long before circularity was cool. As we love to say “SMART was ‘green’ before ‘green’ was smart!”.