A coalition of second-hand clothing industry leaders, policymakers and academic experts has publicly urged the United Nations Environment Programme to strengthen transparency and methodological disclosure in its ongoing research on used textiles and circular economy practices, raising concerns about consultation processes and data integrity that could influence global trade policy affecting millions of livelihoods.
The coalition, led by Ghana’s Used Clothing Dealers Association (GUCDA) and including major industry bodies such as Kenya’s Mitumba Consortium Association, Recycling Europe and the Secondary Materials and Recycled Textiles Association, published an open letter to UNEP on October 15 ahead of the UN’s major environmental assembly scheduled for December in Nairobi.
The signatories commend UNEP’s commitment to textile sustainability but stress that stronger transparency and stakeholder engagement remain essential to the credibility of the “Circularity and Used Textile Trade Project,” which aims to establish global guidelines distinguishing tradeable used clothing from textile waste. The project, funded by the European Commission, carries significant implications for trade policies affecting developing economies where second-hand clothing represents critical economic activity.
The coalition identified several challenges within the consultation process, including compressed timelines for stakeholder feedback, restricted access to draft research materials, and presentation of key data without disclosed methodological foundations. Participants from Ghana, Kenya and Pakistan reported that foundational definitions and critical datasets were applied without sufficient transparency, limiting meaningful participation and independent verification of findings. The signatories argue this opacity undermines both project credibility and eventual acceptance of policy recommendations.
GUCDA Chairperson Jeffren Boakye Abrokwah raised specific concerns about process integrity in Ghana. “The Circularity and Used Textiles Trade project could reshape national trade policies that affect the livelihoods of millions of people around the world. In Ghana, UNEP’s research partner is an NGO with a pre-existing waste advocacy campaign that is financially supported by the ultra-fast fashion industry,” Abrokwah stated. He noted that national dialogues featured participants closely connected to the NGO, with questioning patterns that may have compromised data neutrality.
Kenya’s Mitumba Consortium Association Chairperson Teresiah Wairimu Njenga characterised the collaboration with advocacy organisations as problematic. She warned that UNEP’s engagement with activist groups financially beholden to fast fashion interests creates serious risk of tainted research, with potential consequences for Kenyan communities where the second-hand clothing sector supports over two million people directly and indirectly.
Alan Wheeler, Chief Executive of the Textile Recycling Association in the United Kingdom, expressed concern that project findings may not reflect global textile trade realities. “UNEP’s willingness to adopt unverified findings betrays its stated commitment to impartiality and undermines public trust,” Wheeler stated, calling for UNEP to commission truly independent research and reconsider its guidelines.
The coalition outlined three specific demands: suspending advancement of draft guidelines until underlying research undergoes independent validation, publishing research methodologies and data sources for peer review across all four study countries, and engaging independent regional experts to develop evidence-based guidelines reflecting the complexity of second-hand textile markets.
The concerns centre on data integrity, insufficient stakeholder inclusion, methodological opacity and potential conflicts of interest that the coalition argues compromise the project’s foundation. The textile waste figures cited in the project reportedly conflict with previous studies and established industry observations, yet collection methods and analytical processes remain undisclosed.
UNEA-7, the UN environmental assembly where UNEP is expected to present final global guidelines, will convene in Nairobi from December 8-12, 2025. The timing creates urgency around the coalition’s transparency demands, as global environmental leaders will gather to establish policy frameworks based on UNEP’s research findings.
The controversy reflects broader tensions between environmental advocacy priorities and the economic interests of developing nations whose populations depend on informal textile reuse and recycling sectors. The potential policy outcomes could reshape international trade flows in used clothing, affecting millions involved in collection, sorting and distribution across Africa, Asia and other regions.
The coalition remains open to constructive engagement with UNEP and has indicated willingness to collaborate toward developing fair, evidence-based global textile economy standards that genuinely account for multiple stakeholder perspectives and development contexts.
