Recycling of Low Grade Clothing Waste - Oakdene Hollins

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© Oakdene Hollins Ltd, Salvation Army Trading Company Ltd Nonwovens Innovation & Research Institute Ltd September 2006 The Environment Agency, in a letter to a major textile merchant in August 2005, confirmed that: ………for second‐hand clothes to cease to be waste they must: i. be suitable for continued use as clothes; and ii. be being exported for sale and/or use as clothes. It needs to be emphasised that if the clothes are fit for use as clothes but are exported for shredding/making into dish cloths or for some other application than direct reuse as clothes, then we’d consider that to be an export of waste. As such, if clothes go through a sorting and quality control process to remove unsuitable clothes from the higher grade material the clothes cease to be waste and are therefore not subject to the requirements of the Waste Shipment Regulations 259/93/EC. The legislation is therefore interpreted by the Environment Agency, for used textiles, as follows: • Material from textile banks, either at civic amenity or public sites, is classed as waste since it is discarded by the original user and is assumed to contain considerable amounts of unusable material. Transporting and shipping textile bank material, therefore, is only allowed through a waste carrier’s permit, etc. • Bags of textiles arising from door‐to‐door collections are deemed not to be waste, because it is expected that they will contain all usable (wearable) material. In this case it is assumed that the householder discards clothing with the belief and intention that it will continue to be used as clothing. • The same applies to the surplus textiles, unsuitable for re‐sale in the UK by the charity shops, which are forwarded to the merchants for re‐sale abroad. This is not waste because it is deemed to have been sorted and any unusable material to have been removed. Of course, the definition of what is or is not usable lies with the sorter. • Where a merchant ships used textiles destined for wiper rags or shredding, then this is waste. Telephone discussions with the Agency in November 2005 confirmed that donated clothing, collected from a textile bank, is a discarded material and as such is classified as waste at the point of collection. However, it is noted that clothing donated directly to a charity shop, or through a door‐to‐door collector, is not regarded as waste since it is not deemed to be discarded and is assumed to be suitable for continued use. The classification of textile bank material as waste is disputed by the merchants who argue that ‘waste’ should be defined by the intention in the For Defra Page 26
© Oakdene Hollins Ltd, Salvation Army Trading Company Ltd Nonwovens Innovation & Research Institute Ltd September 2006 mind of the person discarding the material. If it is clearly being ‘donated’ for secondary use, then it is not waste. Furthermore, the Agency argument will depend on the amount waste material in each textile bank load, many of which may contain less waste material than in loads from other sources. Both the Agency and the merchants agree, however, that once sorted the re‐usable portion of textile bank collection is no longer waste. 4.4.2 Local Authority It is the Landfill Regulations that motivate Local Authorities to promote recycling in the household waste stream through the setting up of the Landfill Allowance Trading Scheme (LATS). Targets for the diversion of biodegradable waste from landfilling are driving the move to increasing kerbside collection of a variety of wastes which are suitable for recycling. Because 50% of used textiles are biodegradable, some authorities have either set up schemes for textiles or are co‐operating positively with the existing collection infrastructure. 4.5 Public Perception The key factors directing consumers to donate their used clothing and other textiles for free, rather than to dispose of them to waste, are: • The public perception that the giving of used clothing to a textile bank, a charity shop or to a door‐to‐door collection scheme is a charitable donation to Third World countries. • The growing awareness, through public promotion, of the environmental benefits of the re‐use and recycling of as much household waste as is practical. This in turn is driven by the financial incentives placed on Local Authorities to achieve increasing recycling targets. As noted above, a small amount of clothing may be sold privately rather than donated free to the charities. Some retailers sell second‐hand clothing as agents for the original owner, who then receives a percentage of the sales price once the item is sold. This disposal route is only suitable for relatively high value items and is not considered further in this study. Clearly many charities benefit from the profit made through the re‐sale of donated used clothes. However, it is not widely realised that the ultimate Third World beneficiaries are, in fact, paying for the clothes donated, and that once the materials are passed on from the collecting charity to textile merchants and exporters, trading is carried out purely on a commercial basis. This fact is, of course, a fundamental requirement of merchant’s For Defra Page 27
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Recycling of Low Grade Clothing Waste - Oakdene Hollins

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