How UNEP’s Used Textile Guidelines Risk Destroying What They Claim to Save

The legitimacy of any global standard ought to rest on the credibility of its evidence. Yet UNEP’s Circularity and Used Textile Trade Project stands accused of advancing guidelines without a transparent empirical foundation. According to the Open Letter, core data on textile waste volumes and non-reusable fractions have been presented without disclosure of methodology, sampling design, or validation procedures. That opacity, it seems, makes independent verification impossible—an untenable flaw for a policy intended to shape international trade and environmental law.

There’s nothing wrong with the ambition of the project; it’s the epistemic shortcuts that are suicidal. The textile waste figures cited by UNEP are “inconsistent with previous studies and established industry observations.” In Europe’s optimised collection systems, the fraction of non-reusable textiles—the true waste that cannot be reused or recycled—is supposed to be on the lower side. Yet UNEP has not disclosed its underlying figures—and this lack of transparency leaves stakeholders unable to assess whether contamination rates have been overstated, potentially leading to the misclassification of legitimate secondhand shipments as “waste.”

This distinction matters. Under international trade law, the classification of a good as “waste” can trigger export bans, tariffs, or sanctions under the Basel Convention. The potential fallout could be severe—especially in countries like Kenya, Ghana, and Pakistan, where trade regulations could inadvertently classify reusable clothing as waste under international law. Data ambiguity, in this sense, is not academic; it’s existential. Mere definitions can throw life out of grear.

The data from UNEP’s own focus countries underscores this complexity. Pakistan operates both as a sorting and export hub, trading $283 million (429 million kg) in used textiles annually, while Tunisia’s imports and exports were valued at $69.4 million and $12.2 million respectively. These flows show that a single “waste” definition cannot capture the diverse functions of these economies.

Equally troubling is the project’s silence on how it defines “waste” at all. It is apparent that UNEP has applied foundational definitions without disclosure or peer review. In doing so, it has risked setting a precedent where environmental categories—supposedly neutral or agnostic—are established without public accountability. The power to define “waste” thus becomes a proxy for the power to decide whose economies are legitimate and whose are polluting.

Critics warn that this technocratic opacity masks a deeper asymmetry. The countries under study—Ghana, Kenya, Pakistan, and Tunisia—are not the world’s main producers of textile waste; they are its recipients. Yet UNEP’s methodology frames them as problem zones rather than as unintended victims of overproduction elsewhere. That inversion shifts the moral burden southwards, letting the Global North escape scrutiny even as it continues to overproduce at industrial scale.

What makes the problem worse is UNEP’s compressed policy schedule. The guidelines are expected to be presented at the UN Environment Assembly next month—an ambitious and rushed deadline that insiders say has forced corners to be cut. Stakeholders describe “rushed timelines” and “limited access to draft materials,” leaving little space for peer review or the incorporation of ground-level data. The result is a bureaucratic exercise that bears the veneer of science but none of its rigour.

UNEP’s circularity timeline coincides with the European Union’s Textile Strategy, which calls for stricter export controls. While this may reflect shared policy objectives rather than coordination, the overlap has raised questions about political influence and timing. By defining what counts as “waste” just in time for European regulatory rollout, UNEP risks appearing less like an independent arbiter and more like an enabler of Northern trade interests disguised as environmental governance.

If “evidence-based policymaking” is the mantra of international governance, then the grandiose UNEP project would serve as a cautionary tale of how shallow evidence is sure to be weaponised. When data is withheld, definitions are malleable; and when participation is selective and simply not inclusive, policy becomes performance. In this case, the performance of “circularity” risks collapsing under the weight of its own contradictions—circular, perhaps, in name only.

If the credibility of UNEP’s data is under question, so too is the grimy way in which it has been collected and discussed. The Open Letter alleges that the consultation process was anything but inclusive. Though UNEP held workshops and surveys in Ghana, Kenya, Pakistan and Tunisia, many key stakeholders—especially small-scale traders, informal collectors, and local recyclers—say they were never meaningfully included. For an initiative that claims to be global and “participatory,” the project has been singularly selective about whose participation eventually counts.

At the heart of this exclusion lies a structural imbalance. Informal actors—those who collect, sort, and sell used garments in markets such as Kantamanto and Gikomba—represent the backbone of the reuse economy. Yet their voices have been marginalised because they lack formal recognition, financial clout and international reach. Instead, the consultation process privileged “centralised organisations”—larger NGOs, Western-funded research bodies and selected corporate stakeholders—who could respond within UNEP’s “rushed timelines” and bureaucratic templates.

The result is a dialogue in name, not substance. Critical grassroots knowledge—about how clothing is sorted, repaired, and resold—is missing from the data pool that now underpins UNEP’s draft guidelines. These guidelines risk being technically elegant but practically disastrous: unworkable in markets where informal systems, not corporate recycling plants, sustain circularity in its truest form.

What makes this procedural exclusion particularly galling is its timing. UNEP’s project is rushing to meet its presentation deadline before the UN Environment Assembly in December 2025, zipping a multi-year consultative process into a matter of months. That urgency, critics content, has produced a simulation of inclusion rather than genuine dialogue. Stakeholders received draft materials too late to comment meaningfully, and feedback loops were either perfunctory or non-existent.

This pattern echoes a broader problem in global environmental policymaking—what scholars call “consultative theatre.” Policies are paraded as participatory, yet the key decisions have already been made. The UNEP project mirrors this pattern: consultation used as a legitimising device rather than as a mechanism of co-creation. Those most dependent on the secondhand economy have been reduced to respondents in a survey, not partners in policy design.

The cost of this exclusion is not abstract. In Kenya’s Mitumba sector, an estimated 2 million people depend directly or indirectly on the trade, with nine in ten households spending less than 1,000 shillings every quarter on secondhand clothing. In Ghana, the Kantamanto Market supports tens of thousands of traders and generates between $5 million and $10 million in daily sales. By throttling these voices from the ground, UNEP has risked dismantling the very circular systems that already function without subsidies—market-driven, community-based, and self-sustaining.

Now, this exclusion is not incidental but symptomatic of how power flows in sustainability politics. When the authority to define “best practice” is centralised in plush UN offices, the messy, local realities of circularity get expunged. The “circular economy” becomes an exportable ideology rather than an adaptive system rooted in context. What UNEP calls “standardisation,” traders in Accra and Nairobi call erasure—the transformation of lived economies into policy abstractions.

This erasure also deepens the legitimacy crisis facing UNEP. If the process excludes those most affected, can the outcome be global? By mistaking consultation for consent, the agency is turning an environmental initiative into a neo-colonial exercise—one that codifies the voices of the powerful while silencing those who make circularity work on the ground. For an institution that champions inclusivity, UNEP’s project is now a case study in how exclusion can masquerade as engagement.

If data opacity and procedural exclusion raised eyebrows, the question of conflict of interest should send out alarm signals. The Open Letter alleges that the research component of the UNEP project in Ghana was implemented by an NGO financially supported by an ultra-fast fashion giant—a company responsible for the very overproduction driving the global waste crisis. For critics, this isn’t just an ethical oversight; it’s a structural betrayal of the project’s own environmental mandate.

The NGO in question, known for its well-hyped waste advocacy campaigns, received financial support from a leading ultra-fast fashion retailer—a link that stakeholders argue creates the perception of a conflict of interest in research independence. That fund is ostensibly meant to support textile recycling and waste reduction. But in Ghana, where the annual value of imported secondhand clothing stands at $150.9 million, the funding gives the corporate sponsor enormous financial leverage—nearly one-third of the entire national trade value under scrutiny.

This obvious imbalance creates the perception that the funder could influence the research agenda, a concern that stakeholders have raised regarding the project’s independence. The NGO’s local dialogues and surveys heavily emphasised the “waste burden” of imports, using the claim that up to 15 million garments arrive at Kantamanto every week. But critics argue this framing omits a crucial context: those imports are overwhelmingly reused or resold, not dumped. The issue is not import volume but global overproduction upstream—a subject that fast fashion brands won’t touch.

By positioning importers as polluters and exporters as “responsible producers,” the research deftly inverts the moral geography of waste. This inversion allows fast fashion brands to claim circular virtue—via recycling or EPR schemes—while externalising the costs of their overproduction to the very markets that reuse their clothes most efficiently. It is a rhetorical sleight of hand that turns Ghana’s reuse economy into a scapegoat for the Global North’s consumption disorder.

The unholy alliance between UNEP, Northern advocacy NGOs and fast fashion capital looks alarmingly familiar. Partnering with groups “beholden to fast fashion interests” risks producing “tainted research” that undermines genuine circularity.

What makes this entanglement particularly corrosive is the way it discredits independent advocacy. When a fast fashion giant bankrolls anti-import research in the Global South, the optics are devastating: the polluter funds the diagnosis, then prescribes itself as the cure. UNEP’s failure to firewall its research partnerships from such influence raises uncomfortable questions about its institutional independence and its susceptibility to donor-driven narratives.

The UNEP project’s framing might unintentionally encourage greater emphasis on high-tech recycling rather than strengthening already-proven reuse systems. Yet global data shows that only 1% of textiles are actually recycled into new clothes, while reuse already diverts millions of tonnes from landfill each year. By undermining reuse economies in favour of unproven recycling technologies, the guidelines risk dismantling the only functioning circular systems we currently have.

Sorry, but this doesn’t look like circularity; it’s outright capture of the narrative. When fast fashion can sponsor the definition of sustainability, the concept itself stands compromised. The danger is that UNEP project, designed to regulate waste, could end up legitimising the very structures that produce it—a closed-loop of policy, politics, and profit strutting around as progress.

If the project began as a technical exercise in defining waste, it has now evolved into a moral and political crisis for UNEP. The agency finds itself accused not merely of mismanaging data but of misrepresenting an entire global economy. By pursuing global definitions through opaque processes, UNEP risks collapsing the fragile ecosystems of reuse that already exist—and replacing them with a bureaucratic fiction of circularity that serves Northern policy convenience more than planetary need.

In countries such as Kenya and Ghana, millions rely on the secondhand trade for work and income—a sector already quantified by multiple national studies as vital to both employment and revenue. Globally, the fashion system’s linear model is estimated to cause an annual economic loss of roughly $500 billion, largely due to clothing that is landfilled or incinerated rather than reused or recycled. This inefficiency underscores the enormous global value at stake in reducing waste—a goal that could be undermined if UNEP’s guidelines unintentionally destabilise thriving reuse economies.

The deeper issue, however, is one of legitimacy. UNEP’s failure to disclose methodologies, consult equitably, or firewall its research from fast fashion influence has eroded its authority as a neutral arbiter. By refusing to publish the definitions and data underpinning its recommendations, it has violated the very principle of transparency that multilateral governance depends on. As the Open Letter argues, such secrecy “undermines the credibility and impartiality of the entire process.”

This credibility crisis is not an administrative glitch. It is a systemic drift in global sustainability governance. The fact that a fast fashion retailer could inject funding into the NGO leading UNEP’s Ghana research shows how the politics of “corporate responsibility” can distort the science of environmental policy. What was meant to regulate industry has become entangled with it.

While UNEP frames its initiative as protecting the Global South from “waste dumping,” its current approach risks diverting scrutiny away from the structural drivers of waste—the 116 million tonnes of fibre produced annually, and the 92 million tonnes of discarded textiles generated by overproduction. These systemic issues originate largely in the Global North’s overproduction patterns, not in importing markets such as Accra or Nairobi.

What this controversy ultimately exposes is the unabashed hypocrisy embedded in global environmental policymaking: sustainability rhetoric flows North to South, responsibility flows the other way. The same institutions that lecture on circularity often preside over supply chains that are anything but circular. And in this case, the very agency tasked with policing global waste may end up legitimising the disposability it claims to fight.

So, either UNEP should suspend and recalibrate the guideline process, as stakeholders have demanded, or it risks losing its moral authority altogether. The credibility of the circularity agenda depends not on grand declarations but on humility—the willingness to recognise that sustainability cannot be imposed from above, nor purchased through the backdoor of fast fashion philanthropy.