A pioneering research on reforming international textile trade code (HS Code) proposes modern approaches to managing international shipments of recycled textiles and second-hand clothing with the aim to reduce legal ambiguity, lower costs, and incentivise textile reuse and recycling.
THE REPORT: The Centre for Resilience and Sustainable Development (CRSD) at the University of Cambridge, in partnership with the European Recycling Industries’ Confederation (EuRIC) and the UK's Textile Recycling Association (TRA), has launched the research report — ‘Reforming textile trade codes to be fit for purpose for the circular and sustainable textile economy’.
- The report, drafted by Dr Hannah Parris, CRSD, comes at a critical time as the World Customs Organisation, the international organisation that manages HS Codes, prepares for its next review cycle in 2027.
- Through extensive consultation with industry stakeholders and using CRSD’s innovative Cambridge Policy Boot Camp methodology, the research identified seven practical reforms that could be implemented by industry, national governments and internationally at the World Customs Organisation to modernise the Harmonized System (HS) codes.
SOME KEY RECOMMENDATIONS:
National governments should work with like-minded partners within the World Customs Organisation to pursue the following HS code reforms as part of the next review cycle starting 2027:
- Abolish HS 6309 and replace with seven new codes to differentiate waste, recycling, reuse, garment/shoes/accessories, and unsorted originals
- Standardise (legal) terminology to ensure consistent interpretation across languages, legal frameworks and national cultures.
- Define clear contamination benchmarks for textile waste shipments to ensure that unintended inclusion of non-textiles does not lead to shipment rejection.
- Implement a textiles-specific Authorised Economic Operator programme with reciprocal recognition requirements
- Enhance customs training to standardised code interpretation
- Create dedicated HS codes for second-hand clothing within Chapters 61 and 62 7. Develop specific HS codes for recycled-content garments within existing clothing chapter
National governments should be encouraged to work with TRA and EuRIC to consult further with stakeholders in the SHC and textile recycling value chain in the global south to ensure that these reforms align with their needs and do not create future unintended consequences.
- Consultation should minimally include representatives from major textile production, recycling and reuse partners of the EU/UK, Eastern Europe and the Global South: Turkey, Bangladesh, Ghana, Kenya, Romania, Vietnam.
National governments work with TRA and EuRIC, and other industry partners, including those in partner countries, to refine the proposal package and address specific details in policy design. This includes:
- Definition of the contamination benchmark
- Minimum thresholds for use of recycled content to qualify for new product code
- Details of a textile specific Authorised Economic Operator programme
Some talking points
- The economics of the sector dictates that international shipment of SHC, textile recycling and waste will remain an important part of scaling up the circular textile economy.
- The current HS 6309 code — which underpin the logistics paperwork of this trade - creates legal ambiguity for industry, adding to risks and cost for the sector. Specific problems include:
- HS code definitions do not match the practices within the industry
- Codes does not differentiate between waste textiles, textiles for reuse and textiles for recycling.
- Language is ambiguous or undefined — and different customs officers across multiple jurisdictions use different interpretations of key terms -e.g. ‘Worn’ textiles.
- Lack of clarity about recycling or waste textile items outside Chapter 63 .
The recommendations in this brief address these problems with trade codes. Specially reformed codes will:
- Specify if shipments are waste textiles — allowing customs officers to better prevent textile waste dumping in global south markets
- Reduce risks and costs associated with shipments – reducing cost base overall. This can support the sector to attract the £5.7billion /€7 billion investment needed by 2030 to deliver a circular textiles economy in Europe alone (McKinsey, 2022).
- Differentiate products made from recycled content – allowing economic incentives to be developed.
- Implementing the reforms will require minimum financial investment - primarily to support education and training required [add in cost data if available]. The work completed by University of Cambridge, TRA and EuRIC identifies significant existing resources that can be activated to support trade code reform.
About Centre for Resilience and Sustainable Development, University of Cambridge: The Centre for Resilience and Sustainable Development (CRSD) is a transdisciplinary action-research hub with a dynamic team of research-driven methodologists employing a suite of systems-based tools and methods to co-create data and analysis that generate actionable, high-impact knowledge to build resilience against systemic risks.
WHAT THEY SAID:
Current customs trade codes create unnecessary barriers for the textile recycling sector that hinder its transition to a circular economy at a time when sustainable textile management is more crucial than ever. This research project offers practical proposals for HS code reform that we can present to governments to grow this vital sector.
— Julia Ettinger
Secretary General
EuRIC
This trade codes project is yet another example of the power of co-creation and genuine collaboration between academia and industry. We would encourage TRA and EuRIC and other similar associations to work closely with our Centre to apply co-creation methods for collective action.
— Professor Nazia M Habib
Founder & Director
Centre for Resilience and Sustainable Development
This isn't just about changing codes – it's about building the foundation for a more circular textile industry. The recommendations provide a clear pathway for reform that could support the sector's ability to scale up circular economy initiatives.
— Alan Wheeler
Chief Executive Officer
Textile Recycling Association
