Spotlight: Politics of Waste

UNEP’s Textile Waste Guidelines Draw Scrutiny from Kenya’s Secondhand Clothing Sector

Efforts to tighten global definitions of “waste” have sparked a struggle over the future of reuse economies. Teresiah Wairimu Njenga, who leads the Mitumba Consortium Association of Kenya, argues that poorly conceived guidelines risk collapsing viable circular systems under the guise of environmental reform, while the real issue of fast-fashion overproduction remains unaddressed.

Long Story, Cut Short
  • The fight over what counts as “waste” now shapes global trade, determining who may recycle, who may sell, and who loses livelihoods.
  • African secondhand clothing markets represent working circular economies that challenge Western narratives of “waste colonialism” and resource inequality.
  • Global textile policies risk reinforcing economic dependence if they restrict legitimate reuse while ignoring overproduction and corporate responsibility.
Kenya’s mitumba markets form a vital reuse network where millions depend on the trade of secondhand clothing, turning global textile surplus into livelihoods and affordable apparel.
Livelihoods at Stake Kenya’s mitumba markets form a vital reuse network where millions depend on the trade of secondhand clothing, turning global textile surplus into livelihoods and affordable apparel. Mitumba Consortium Association of Kenya

texfash: At first glance, defining “waste” seems like a technical matter. But as this controversy shows, the definition determines who may trade, who may recycle, and who must absorb the world’s excess. How did a word meant to serve environmental clarity turn into a political tool with such far-reaching economic consequences?
Teresiah Wairimu Njenga: The problem is that “waste” has become a political label rather than a scientific one. Once an item is defined as waste, it instantly moves from being seen as part of a legitimate trade to being something that needs to be prohibited, controlled or stigmatised.

In Kenya, where the secondhand clothes trade—known locally as mitumba—employs over 2 million people, including many women and young people, secondhand clothes are a vital form of access to affordable clothing. In real terms, mitumba means a mother being able to feed and clothe her children through the dignity of work.

Mitumba is a commodity, not waste. Yet, under the current UNEP draft guidelines, our livelihoods are merely labelled as dealing in “non-waste” rather than recognised as trading in products of value. This truly does frame the Global South as a dumping ground, when in reality, we embody the global circular economy in secondhand clothes. We don’t import waste or even ‘non-waste’; we import value. The secondhand clothing sector keeps garments in circulation, reduces dependence on ultra-fast-fashion, and saves millions of tonnes of CO₂ every year. So, when “waste” is used imprecisely, it becomes a tool for trade restriction, not environmental protection.

The Open Letter calls for publication of UNEP’s research methods, yet those documents remain inaccessible. In the age of open data, how does withholding methodology align with claims of scientific integrity and transparency?
Teresiah Wairimu Njenga: Scientific integrity depends on replicability and transparency. Without open access to data and methods, we cannot verify whether conclusions about “waste” or “unsellable” garments are grounded in evidence or in perception. This means that stakeholders have had no meaningful opportunity to review and feedback on both the findings and the methodology used in each case study country.

In Kenya, our trade is regulated through strict Pre-Export Verification of Conformity—every bale is inspected by accredited agencies like SGS and Bureau Veritas before it leaves the exporting country. Less than 2% of what we import is waste. Yet, without transparent research methods, UNEP risks basing global policy on assumptions that contradict the verified data from countries like ours.

If global guidelines reclassify a portion of reusable garments as “non-tradeable waste,” how might that reshape the entire geography of the second-hand trade — and who would stand to gain or lose from such a shift?
Teresiah Wairimu Njenga: The losers would be clear: African economies and millions of small traders, mostly women, who depend on this trade. The winners would be large corporations and new garment exporters in Asia who would fill the vacuum with ultra-fast fashion.

Reclassifying reusable garments as “non-tradeable waste” would not stop overproduction—it would accelerate it. If affordable secondhand clothing is restricted, the market will shift to new imports, increasing textile waste and carbon emissions. Ironically, a policy designed to reduce waste would create more of it.

Even if the funding was intended as restitution, the optics are difficult to ignore. Should UNEP have imposed stricter conflict-of-interest rules before allowing a Shein-funded organisation to play a central role in shaping global textile policy?
Teresiah Wairimu Njenga: It is concerning that an NGO with close links to the ultra-fast-fashion industry was selected to lead research on this issue, given its clear pre-existing agenda. Transparency and neutrality are essential if the output is to be credible and trusted by all stakeholders.

Research like this should be conducted by bodies with demonstrable independence and a proven commitment to balanced analysis. Without that, there’s a real risk that findings—however well-intentioned—will appear biased, undermining confidence in both the process and its conclusions.

There’s a growing debate about whether accepting corporate money can ever lead to meaningful reform. In UNEP’s case, has engagement with industry blurred the line between partnership and co-optation?
Teresiah Wairimu Njenga: Industry sits at the core of the circularity challenge; we can’t achieve true circularity without addressing how products are designed, made, and consumed. However, any collaboration requires clear boundaries and transparency so that partnerships don’t compromise independence or credibility.

What lessons should UNEP — and other UN agencies — draw from this episode about the ethical pitfalls of aligning with private-sector actors who have vested interests in the policy outcomes?
Teresiah Wairimu Njenga: We believe policy should be built from the ground up. Start with evidence from the reuse markets that already work, collected by truly independent organisations, and ensure the people most affected are at the table.

This project was commissioned by the EU in response to a misleading narrative originating from an American NGO in Ghana, which reported a now debunked statistic that 40% of secondhand clothes imports into Africa become waste. For UNEP to partner with that same NGO as a research partner to carry out new independent research is a concern.

In markets like Kenya’s Mitumba or Ghana’s Kantamanto, thousands of traders, most of them women, make a living from sorting and reselling second-hand clothes. Why do you think this vast informal economy has been overlooked or undervalued in global sustainability planning?
Teresiah Wairimu Njeng: This vast informal economy has often been overlooked because it doesn’t fit the “waste” narrative. In Western media, it’s easy to label our trade as “waste colonialism,” but that ignores the reality: we are running businesses, buying and selling a commodity, paying import levies, and responding to genuine demand.

Our trade keeps millions employed, extends the life of garments, and provides affordable clothing to millions more. Without it, I know that ultra-fast fashion will flood African markets. There is a demand for clothing, and so the demand will need to be met. Secondhand clothes are true sustainability in action—resource efficiency driven by necessity. Global frameworks risk undermining this vital circular economy if they equate “informal” with “inferior.”

Teresiah Wairimu Njenga
Teresiah Wairimu Njenga
Chairperson
Mitumba Consortium Association of Kenya

Mitumba is a commodity, not waste. Yet, under the current UNEP draft guidelines, our livelihoods are merely labelled as dealing in “non-waste” rather than recognised as trading in products of value. This truly does frame the Global South as a dumping ground, when in reality, we embody the global circular economy in secondhand clothes. We don’t import waste or even ‘non-waste’; we import value.

There’s a fine line between preventing dumping and killing trade. How can global rules distinguish between exploitative waste exports and legitimate reuse without punishing the livelihoods built on them?
Teresiah Wairimu Njenga: The distinction is already built into our supply chains that have developed over decades. Kenya’s Pre-Export Verification of Conformity (PVoC), whereby sorting centres undergo checks before export, ensures that only reusable clothing is shipped here. UNEP could highlight these practices as examples for other countries to learn from.

Problems arise when guidelines are simultaneously vague—leaving room for misinterpretation—and overly restrictive, attempting to dictate market demand and socioeconomic needs. Clothing markets are governed by supply and demand, not rigid rules. For instance, while some assume Kenya only requires clothing for warm weather, there is still demand for coats and jackets during colder months, for those at higher altitudes, or for travel. Circularity frameworks should recognise these realities rather than attempt to regiment dynamic markets that already function efficiently.

Are there examples of locally driven models — perhaps in Ghana, Kenya, or Pakistan — that UNEP could learn from instead of imposing a one-size-fits-all global standard?
Teresiah Wairimu Njenga: Yes—Kenya’s PVoC system is a working model. It combines private-sector certification with government oversight and has achieved compliance levels that many developed countries struggle to match.

But unfortunately, it is a misdiagnosis to suggest that transboundary movements of secondhand clothes need to be regulated. The real issues lie within global overproduction of textiles, specifically the manufacturing of ultra-fast-fashion, and building and developing waste management and recycling infrastructure not just in end market countries in the Global South, but globally.

UNEP doesn’t need to reinvent the wheel—the supply chain already works in Kenya.

From a policy standpoint, how can UNEP address the moral contradiction of rich nations claiming progress while poorer nations shoulder the physical and financial burden of their discarded textiles?
Teresiah Wairimu Njenga: First, we need to recognise that the secondhand clothes trade is a legitimate trade in products of value. Even when described as “discarded textiles,” these garments are valuable to millions of customers in Kenya, providing affordable, quality clothing while supporting livelihoods. There is nothing moral in stripping millions of Kenyans of the dignity of a job or access to affordable clothes.

The moral contradiction is stark: rich nations continue to consume without restriction, and large corporations produce freely, yet poorer nations are to be criticised or restricted from accessing affordable clothing simply because the trade is portrayed negatively in Western media. This framing focuses on appearances rather than the realities of supply, demand, and livelihoods in the Global South.

We must acknowledge where responsibility lies—at the point of production, not reuse. The cost of overproduction should be internalised by the brands and retailers that profit from it through Extended Producer Responsibility (EPR) fees, with funds raised helping to invest in the collection, sorting and reuse supply chain, and for building general waste management infrastructure in the Global South and for building recycling and waste management infrastructure in the Global South — because the problem is not second-hand imports, it’s fast-fashion overproduction and poor waste management systems.

Some activists argue that environmentalism has become the new language of control — that “saving the planet” often means regulating the Global South. Do you think the textile debate exposes that tension?
Teresiah Wairimu Njenga: Yes, it does. When policies made in the Global North start to restrict livelihoods in the Global South under the banner of “sustainability,” that’s not environmental justice—it’s environmental colonialism.

We fully support circularity, but it must be inclusive and fair. True sustainability empowers communities; it doesn’t criminalise their survival.

The secondhand clothes trade is circularity in action. We are the ones extending the lifespan of garments that would otherwise go to waste. We are firefighters of the global textile overproduction. It is astonishing how much the narrative has shifted away from the overproduction of ultra-fast fashion.

Readers from across the globe must stop and question why we are focusing on reusable textiles rather than the overproduction of ultra-fast fashion. They must also ask themselves who gains from that discussion.

For consumers in the Global North, secondhand clothes are a trendy luxury, but in the Global South they are a necessity - a lifeline for millions.

If circularity is to mean justice, not just efficiency, what systemic change—financial, political, or moral—would have to occur for the Global North to truly share the costs of its consumption?
Teresiah Wairimu Njenga: If circularity is to be about justice, not just efficiency, the Global North must take responsibility for the full lifecycle of the products it consumes. We are in support of EPR fees that fund reuse, and recycling infrastructure in the Global South.

It also requires political change - genuinely including Global South stakeholders in the design of standards, definitions, and regulations, rather than imposing rules from afar.

True circularity is achieved when the costs and benefits of production, consumption, and reuse are shared fairly, and when the systems of reuse that already exist in the Global South are supported and respected, rather than penalised.

Trade in Balance
  • Over two million Kenyans depend on the secondhand clothing sector for income, especially women and young entrepreneurs.
  • Kenya’s Pre-Export Verification of Conformity ensures imported garments meet reuse standards before shipment, reducing waste imports to under 2 per cent.
  • Proposed UNEP guidelines may classify reusable garments as “non-tradeable waste,” threatening to disrupt established reuse supply chains.
  • Restricting secondhand imports could increase ultra-fast-fashion demand, worsening textile waste and carbon emissions globally.
  • Local reuse markets illustrate circularity in action, keeping clothes in circulation and reducing pressure on manufacturing and landfill systems.
Policy and Perception
  • The UNEP project’s partnership with a Shein-funded NGO has raised transparency and conflict-of-interest concerns.
  • Stakeholders call for publication of research methods to validate claims about waste levels in secondhand imports.
  • Critics warn of “environmental colonialism,” where sustainability policies penalise Global South livelihoods.
  • Advocates urge the Global North to internalise overproduction costs through Extended Producer Responsibility schemes.
  • African markets like Mitumba and Kantamanto demonstrate that informal reuse systems can outperform formal recycling models in efficiency.
 

Subir Ghosh

SUBIR GHOSH is a Kolkata-based independent journalist-writer-researcher who writes about environment, corruption, crony capitalism, conflict, wildlife, and cinema. He is the author of two books, and has co-authored two more with others. He writes, edits, reports and designs. He is also a professionally trained and qualified photographer.

 

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  • Dated posted 11 November 2025
  • Last modified 11 November 2025