The UK Environment Agency's (EA) new export controls under Article 18 of the Basel Convention are causing substantial disruption to England's used textile export trade. The new rules require exporters to provide evidence that receiving facilities are legally authorized to accept textile waste and recycle it in an environmentally sound manner. However, such documentation does not exist in many destination countries, creating significant practical obstacles.

Key Points

  • The Textile Recycling Association (TRA) says the EA requires exporters to prove receiving facilities hold legal qualifications, but major markets such as India and Pakistan lack corresponding documentation systems, and trade has been severely disrupted.
  • The TRA has requested urgent consultations with the EA, which responded that the matter is under internal review and further arrangements will be announced.
  • The industry is also watching the Basel Convention's potential imposition of additional controls on cross-border movements of used textiles, with the TRA calling for an evidence-based approach that distinguishes reusable textiles from waste.

TRA CEO Alan Wheeler said the current situation in England is a vivid warning of "unintended consequences." He noted that the regulatory goal is understandable, but rules must match the systems and documentation that actually exist in destination countries. He stressed that trade with important markets such as India and Pakistan is being severely disrupted and needs to be resolved urgently. The TRA has requested urgent communication with the EA on this matter, and the EA replied that the issue is under internal study and further information will be provided.

Wheeler added that the industry needs effective regulation, but regulation should target evidence-backed problems and should not unintentionally harm the recycling, sorting, reuse and regeneration systems that are already part of the solution.

Uncertainties at the Basel Convention Level

Beyond the England rules, the textile industry also faces adjustments under the Basel Convention framework. Policymakers are examining how used textiles and textile waste should be handled in international shipments, including possible additional control measures. The TRA calls for an "evidence-led approach" and warns that poorly targeted regulation of the international used textiles trade could undermine the very reuse and recycling systems policymakers seek to support. The association recommends that any amendments to the Convention be based on solid evidence, clearly distinguish reusable textiles from waste, and fully consider the potential impact on existing global reuse and recycling markets. Wheeler concluded that before introducing additional controls, it is necessary to first clarify what problem is being solved, its actual scale, and where in the supply chain it occurs, warning of a real risk that policy is driven by "perception rather than evidence."

The Plight of the Second-Hand Textiles Market

In recent years, the second-hand textiles industry has faced a severe economic environment. The influx of ultra-fast fashion has both lowered the quality of second-hand clothing and increased supply. The traditional UK model involves selling second-hand clothing to "collectors, sorters and processors," which after quality grading is sent to secondary markets in Eastern Europe, Africa and Asia for reuse, while items that cannot be exported are landfilled or incinerated as waste. But the low value of ultra-fast fashion items has shaken this system, and overseas importers have shown declining interest in lower-grade textiles from the UK. Meanwhile, end markets in Eastern Europe and the Middle East have been disrupted by ongoing geopolitical tensions. The EA has recently introduced strict new rules on used textile exports, forcing merchants to invest additional resources in sorting. As a result, the industry has generally cut prices and reduced recycling, including charging gate fees at household waste recycling centres (HWRCs) — a source whose textiles are typically of the lowest quality. The decline in recycling volumes has also led to increased illegal dumping around textile recycling bins, as merchants struggle to maintain normal collections.

For the used clothing export industry, rising policy compliance costs combined with weak end-market demand are simultaneously squeezing profits and the operation of recycling systems. Exporters need to closely monitor documentation compliance requirements and the direction of subsequent Basel Convention negotiations.

Source: TRA: Textile exports facing disruption following EA rule change - letsrecycle.com · Originally published 2026-10-01