The group, led by the Ghana Used Clothing Dealers Association (GUCDA), includes trade bodies such as Recycling Europe and the Secondary Materials and Recycled Textiles Association (SMART).
It includes stakeholders from the US, EU countries, Ghana, Kenya, Pakistan, the UK, and Nordic countries.
In an open letter, the signatories stress the need for strengthened transparency and data integrity for the “success” of the Circularity and Used Textile Trade Project.
The project, backed by the EU Commission, seeks to create global guidelines distinguishing tradeable used clothing from textile waste. It will pinpoint key policy, financing, investment, and regulatory priorities necessary to facilitate trade and policy reforms, as well as identify financial options to support these changes.
However, the open letter indicates several challenges within the consultation process, including brief timelines for stakeholder feedback, restricted access to draft documents, and reliance on unverified key data.
Stakeholders from countries such as Ghana, Kenya, and Pakistan have expressed concerns that essential definitions of "waste" and critical data were presented without adequate methodological disclosure.
This lack of transparency hinders “meaningful participation” and independent review, they said.
The signatories argue that UNEP must ensure its policy recommendations are both accurate and impartial. They emphasise that immediate action is necessary to remedy these issues.
Coalition’s key recommendations to UNEP
- Suspend the current draft guidelines until independent verification of the supporting research is completed.
- Disclose all research methodologies, data, and definitions from the focus countries to allow for a comprehensive review and understanding.
- Involve independent local experts to guarantee that the process remains inclusive, transparent, and grounded in real-world evidence.
GUCDA chairman Jeffren Boakye Abrokwah said: “What we have seen throughout this consultation process is not the objective inquiry that we expect from a UN programme. 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.”
Textile Recycling Association, UK CEO Alan Wheeler added: “We are concerned that the project’s findings may not fully reflect the realities of the global textile trade. 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.”
The letter emerges amidst a backdrop of organisational challenges at UNEP, including the recent resignation of Luis Vayas Valdivieso from his position as chair of UN plastics treaty negotiations due to reported internal pressures.
UNEP, which was established in 1972, has served as a global entity on environmental issues, directing efforts to tackle climate change, biodiversity loss, and pollution.
It facilitates international agreements aimed at addressing humanity's most pressing environmental challenges.
