A high-profile coalition of second-hand clothing industry leaders, policymakers, and academic experts spanning Africa, Asia, Europe, and North America – led by the Ghana Used Clothing Dealers Association (GUCDA) and including major trade bodies such as, Mitumba Consortium Association of Kenya, Recycling Europe (formerly EuRIC) and the Secondary Materials and Recycled Textiles Association (SMART) – has published an open letter to the United Nations Environment Programme (UNEP), calling for greater transparency and accuracy in the agency’s ongoing research on used clothing and textile circularity.
The statement comes ahead of the UNEA-7, the UN’s major environmental assembly to be hosted in Nairobi from 8–12 December, where UNEP is expected to present the final version of its global guidelines for used textiles.
The signatories, representing stakeholders across the US, EU, Ghana, Kenya, Pakistan, the UK, and the Nordic countries, commend UNEP’s work on textile sustainability but stress that stronger transparency, data integrity, and stakeholder engagement are essential to the success of its “Circularity and Used Textile Trade Project” funded by the EU Commission. The project aims to create global guidelines to help distinguish between used clothing that can be traded and textile waste.
The open letter points to challenges in the consultation process, including short timelines for feedback, limited access to draft materials, and presentation of unverified key data. Stakeholders in Ghana, Kenya, and Pakistan noted that foundational definitions of “waste” and critical data were applied or presented without sufficient methodological disclosure, limiting meaningful participation and independent review. Such a rushed and opaque consultation process, the group argues, undermines the project’s credibility and the acceptance of its eventual findings.
“What we have seen throughout this consultation process is not the objective inquiry that we expect from a UN programme,” said Jeffren Boakye Abrokwah, GUCDA. “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, for example, UNEP’s research partner is an NGO with a pre-existing waste advocacy campaign that is financially supported by the ultra-fast fashion industry. We have rightly raised concerns about national dialogues where many participants were closely connected to the NGO and questions were leading or closed-ended, which may have affected the neutrality of the data collected.”
Signatories emphasise that UNEP, with its global mandate to protect the environment, has an obligation to ensure its policy recommendations are accurate and unbiased and urge immediate action.
The coalition calls on UNEP to:
- Put the current draft guidelines on hold until the research behind them has been independently verified.
- Share all research methods, data, and definitions from the focus countries so the findings can be fully reviewed and understood.
- Bring in independent, local experts to ensure the process is inclusive, transparent, and based on real-world evidence.
“We are concerned that the project’s findings may not fully reflect the realities of the global textile trade,” said Alan Wheeler, CEO, Textile Recycling Association, UK. “UNEP’s willingness to adopt unverified findings betrays its stated commitment to impartiality and undermines public trust. We demand that UNEP correct its course, commission truly independent research, and reconsider its guidelines.”
“There’s a serious risk UNEP’s work will be tainted unless it disengages from activist organisations beholden to fast fashion interests,” warned Teresiah Wairimu Njenga, Chair, Mitumba Consortium Association of Kenya. “The potential harm to communities in Kenya, and indeed worldwide, could be profound.”
