While supporting robust environmental standards, the letter highlights the potential unintended consequences for legitimate reuse and circular textile supply chains if the guidance is applied without significant recognition of operation realities.
The letter calls on DEFRA to provide greater clarity on the application of the guidance, particularly for mixed footwear exports, and to recognise overseas sorting and grading as a legitimate part of global reuse systems. It also urges Government to work with industry to develop proportionate evidence requirements, accelerate textile Extended Producer Responsibility (EPR) and investment in UK sorting infrastructure, and ensure future policy is informed by meaningful engagement with the textile collection, sorting, export and recycling sectors.
Adam Mansell, CEO of UKFT, said: "Our members support the Government's ambition to improve standards, increase transparency and prevent the export of waste under the guise of reuse. Responsible operators have been calling for higher standards and better enforcement for many years. However, we have significant concerns about the aspects of the guidance which fail to reflect the practical realities of the UK's textile reuse and recycling sector.
"The reuse and recycling sector is not the cause of the textile waste challenge. It is the sector managing the consequences of overproduction, declining product quality and unsustainable consumption patterns. We therefore believe that policy should strengthen this infrastructure rather than inadvertently undermine it.
"We would welcome the opportunity discuss these concerns further and work collaboratively with officials to ensure guidance achieves its intended objectives without damaging the UK's textile reuse and recycling sector."
