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UNEP's Used Clothing Project: Transparency Demanded

A coalition of global stakeholders, representing the used clothing industry, policymakers, and academic institutions across Africa, Asia, Europe, and North America, has issued a public letter addressed to the United Nations Environment Programme (UNEP). The letter voices concerns regarding UNEP's ongoing research into used clothing and textile circularity, specifically calling for increased transparency, verifiable data, and broader inclusivity.

Spearheaded by the Ghana Used Clothing Dealers Association (GUCDA), the coalition includes prominent organizations such as the Mitumba Consortium Association of Kenya, Recycling Europe (formerly EuRIC), and the Secondary Materials and Recycled Textiles Association (SMART). These groups are collectively urging UNEP to enhance the credibility and openness of its Circularity and Used Textile Trade Project, a European Commission-funded initiative.

The timing of the letter is significant, preceding the UN Environment Assembly (UNEA-7), scheduled to take place in Nairobi from December 8-12, 2025. At this assembly, UNEP is expected to present its finalized global guidelines concerning used textiles.

While acknowledging UNEP's efforts to promote sustainable textile management practices, the signatories emphasize that the success of the project hinges on the adoption of transparent methodologies, the use of verifiable data, and the active and meaningful engagement of all relevant stakeholders.

The core objective of the project is to establish global standards that differentiate between used clothing suitable for trade and textile waste.

However, the coalition expresses serious reservations about what it perceives as a consultation process lacking transparency. Specific concerns include:

• Limited Feedback Timelines: Stakeholders report insufficient timeframes for providing feedback on crucial aspects of the project.

• Restricted Access to Draft Materials: Access to draft documents and research materials has been limited, hindering comprehensive review and analysis.

• Presentation of Unverified Data: The coalition claims that the project has presented data without proper verification, raising doubts about its accuracy and reliability.

Reports from stakeholders in Ghana, Kenya, and Pakistan indicate that key definitions, particularly the definition of "waste," have been applied without adequate methodological explanation. This lack of transparency, they argue, restricts independent scrutiny and ultimately undermines confidence in the entire process.

Jeffren Boakye Abrokwah of GUCDA stated, "What we have witnessed throughout this consultation process does not align with the objective inquiry we expect from a UN program. The Circularity and Used Textiles Trade Project has the potential to reshape national trade policies, impacting the livelihoods of millions worldwide. In Ghana, for example, UNEP's research partner is an NGO with a pre-existing waste advocacy campaign funded by the ultra-fast fashion industry. We raised legitimate concerns about national dialogues dominated by affiliated participants and leading questions that may have biased data collection."

Alan Wheeler, CEO of the Textile Recycling Association (UK), echoed these concerns, stating, "We are concerned that the project's findings may not fully reflect the realities of the global textile trade. UNEP's willingness to adopt unverified findings undermines its stated commitment to impartiality and erodes public trust. We urge UNEP to correct course, commission independent research, and reconsider its draft guidelines."

Teresiah Wairimu Njenga, Chair of the Mitumba Consortium Association of Kenya, issued a stark warning: "There's a serious risk UNEP's work will be tainted unless it disengages from activist organizations beholden to fast fashion interests. The potential harm to communities in Kenya, and indeed worldwide, could be profound."

To address these concerns, the coalition's open letter outlines three key demands for UNEP:

• Suspension of Publication: The coalition calls for the suspension of the current draft guidelines until all underlying research has undergone independent verification. This step is deemed necessary to ensure the accuracy and reliability of the guidelines.

• Disclosure of Research Methods and Data: The letter demands full disclosure of all research methods, data, and definitions used in focus countries. This transparency is crucial to enable a comprehensive review and understanding of the project's findings.

  • This includes making available all raw data collected during the research process.
  • It also includes detailed explanations of the statistical methods and analytical techniques used to interpret the data.
  • The definitions of key terms, such as "waste," must be clearly defined and consistently applied throughout the project.

• Inclusion of Independent Local Experts: The coalition insists on the inclusion of independent, local experts in the process. This is to ensure that the project's findings are inclusive, transparent, and accurately reflect real-world conditions.

  • These experts should be individuals with in-depth knowledge of the local context, including the specific challenges and opportunities related to used clothing and textile management in their respective regions.
  • Their involvement should extend beyond simply reviewing the project's findings; they should be actively involved in the research process from the outset.
  • The selection of these experts should be transparent and based on their expertise and experience, rather than their affiliation with any particular organization or agenda.

The coalition emphasizes that UNEP, given its global mandate to protect the environment, must ensure that its policy recommendations are firmly grounded in robust evidence and remain free from bias or undue influence. The integrity of UNEP's work is paramount to ensuring effective and sustainable solutions for textile waste management worldwide.

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