Make Extended Producer Responsibility Globally Accountable!

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The Or Foundation is the facilitator of the Stop Waste Colonialism Campaign, but the Kantamanto Community is the driving force. Kantamanto is demanding to be heard. We are demanding that the Kantamanto community be given the respect they are owed and the resources they deserve. Join us and Stop the EU from writing Waste Colonialism into law!

(1) Read the Position Paper and refer to the FAQs for more information.

(2) Fill out the form here to endorse the paper and stand in solidarity with Kantamanto.

(3) Follow @theorispresent on Instagram and share the campaign with everyone you know.

(4) Stay tuned for upcoming Info-sessions and for more specific calls to action

We are actively meeting with members of the EU Commission and continuing to engage decision makers in France. Calls to action will be updated accordingly.

What is Waste Colonialism?

Waste colonialism is when a group of people uses waste and pollution to dominate another group of people in their homeland. The term was first recorded in 1989 at the United Nations Environmental Programme Basel Convention when African nations expressed concern about the dumping of hazardous waste by high GDP countries into low GDP countries. Waste Colonialism is typically used to describe the domination of land for the use of disposal, also referred to as a “sink” and this is quite visible in the context of Accra’s Kantamanto Market, the largest secondhand market in the world.

  • (1) Kantamanto sees 15 million garments every week and 40% of the average bale leaves Kantamanto as waste, causing a public health crisis and destroying livelihoods and the environment.
  • (2) Girls as young as nine years old perform backbreaking and sometimes fatal work of head-carrying 55kg bales throughout the market, laboring in modern day slavery.
  • (3) The Kantamanto community spends $325M USD on bales every year, $182M of which was paid to the Global North exporters in 2020.
  • (4) The secondhand clothing trade began under colonialism and while 1957 marks the Independence of Ghana, the colonial power dynamics remain with the Global North as the “sender” and the Global South as the “receiver” of secondhand garments.
  • (5) The secondhand clothing trade has decimated Ghana’s textile sector, declining from a high of 25,000 jobs in 1975 to 5,000 jobs in 2000, and taught local citizens that clothing is disposable.

Kantamanto market occupies over 20 acres of real estate in the center of Accra on land that was owned by indigenous people before being “re-assigned” by the colonial government, leaving conflicting claims to the property, claims which make it difficult for members of the market to securely occupy the spaces that they pay for or to improve the market. These 20 acres of space are occupied by foreign material that disproportionately benefits the Global North.

We estimate that the Kantamanto community spends $325Million USD on bales every year, $182M of which was paid to the Global North exporters in 2020. The average retailer makes little profit because they must use their resources to repair, wash and upcycle the clothing they receive while also paying sanitation fees to help cover the cost of waste management.

Roughly 40% of the average bale leaves Kantamanto as waste. This material also dominates settlements like Old Fadama and overruns Accra’s coastline. This waste impacts communities financially, increases the risk of asthma, cholera, malaria and other diseases, changes the relationship that people have with the ecosystem around them,and ultimately this waste is used to displace people, blaming communities closest to the disposal sites for the waste.

When it comes to the global secondhand clothing trade, the flow of material and the space that this material ultimately occupies clearly follows colonial power dynamics with the Global North as the “sender” and the Global South as the “receiver” of secondhand garments. In addition to the domination of land, we see waste colonialism as the systematic erasure of the Global South and of Kantamanto’s self-image, meaning that Kantamanto is only allowed to exist so far as its purpose can be placed within the context of the dominating culture. This is as true today as it was in 1957 when Ghana became an independent nation, after being a British colony.

Under colonial rule, local citizens were required to conform to school, church, and professional dress codes as defined by the British, swapping their local dress for a suit and tie if they wanted to enter certain buildings or to get certain jobs. This created an artificial demand for western style clothing.

At first, access to western clothing was restricted. This changed in the 1950s when the rise of mass produced fashion across the Global North collided to transform clothing from a durable product to a consumable commodity. The secondhand clothing trade was introduced to the Glocal North consumer, marketed as charity, allowing Global North citizens to consume more clothing guilt free because there was now an outlet for their excess stuff.

Between 1960 and today, it became difficult for Ghanaian textile manufacturers and designers to compete with the cheap imports of secondhand goods. The Global North has continued to exert dominance by setting new western fashion trends through media and Ghanaian citizens have subsequently become more dependent on secondhand clothing as a cheap way to subscribe to those trends. Ghana was forced to privatize their textile industry and employment within Ghana’s textile sector declined from a high of 25,000 jobs in 1975 to 5,000 jobs in 2000, the number of large manufacturers declining from sixteen to three. More secondhand clothing began flooding into Ghana because locally made textiles and garments were no longer running at capacity and many of the people who were employed in the local textile industry became secondhand clothing sellers.

If this is all news to you, we are not surprised. Most people living in the Global North have a skewed perception of what life is like in Ghana and across the African continent in part because a legacy of colonialism makes it difficult for people from the Global South to represent themselves and their reality. There are more seamstresses per capita in Ghana than anywhere in the Global North, all busy sewing custom, made-to-measure, clothing. This clashes with the poverty narrative that the Global North has been fed.

The ignorance of the Global North is aided by the fact that the language around clothing donation and recycling is often misleading. Respected charities claim that no garment donated to them will end up in a landfill. Municipal bins have recycling symbols on them and brand-managed take-back programs and clean-out kits claim to be part of a recycling program when much of the clothing that enters these programs will be sold on to the global secondhand market.

From our perspective, waste colonialism is becoming more pronounced. The great acceleration of fast fashion in the 2000’s has only intensified the Global North’s reliance on Kantamanto as an outlet for excess clothing and in turn the lowering quality of fast fashion leaves Kantamanto retailers dependent on a system where they have to sell higher quantities of a cheaper product to stay out of debt, creating a vicious cycle.

Globally Accountable EPR policies are key to breaking this cycle.

Position Paper

What is EPR?

EPR stands for Extended Producer Responsibility. Extended Producer Responsibility is an environmental policy and a form of product stewardship that extends a producer’s responsibility for a product to the post-consumer stage of a product’s life-cycle. This policy was first coined in the 1990s when the German packaging take-back law was passed.


‘‘EPR has yet to reach its potential as a catalyst for the transition from a linear economy to a circular economy.’’

Today there are over 400 EPR programs globally, 35% of which are for electronics, 18% for tires, 17% for packaging, 12% for vehicles / auto batteries and 18% for other sectors such as paint (source: OECD). Only one country has an EPR policy for textiles and clothing – France – and this policy came into effect between 2007-2009, over a decade ago.

This means that:

  1. Most EPR policies have been devised for commodities that have a smaller reuse market and more predictable (functional) lifespans than clothing.

  2. The only textiles EPR policy that exists was developed before conversations about overproduction, overconsumption and circularity were mainstream within Global North sustainability discourse. Reducing production volumes is therefore not core to the French EPR policy.

EPR is intended to stop producers from externalizing the cost of Waste and bad design decisions onto municipalities. This has largely been driven by concerns in the Global North regarding the high cost of waste management and the scarce landfill space in their own countries. EPR has, to date, not been concerned with the impact on communities like Kantamanto, “downstream” from the Global North in the global flow of Waste Streams.

In other words, EPR has largely avoided addressing Environmental Justice and Waste Colonialism, in any sector.

The way that the responsibility of waste management is shifted onto the producer can be physical and/or financial. Physical responsibility might look like a producer being required to tangibly take-back, sort and treat their products once consumers are done with them. Financial responsibility is where producers provide the financial resources required to safely and effectively manage the end-of-life of their products. They can provide these funds individually or collectively through a third party called a Producer Responsibility Organization (PRO).

Most EPR Programs are managed by PROs. Oftentimes there is more than one PRO accessible to a company, creating a competitive market, which has both advantages and disadvantages. Refashion, a non-profit, is the sole PRO responsible for administering the French EPR Policy.

The EPR fee, or “eco-contribution”, paid by producers is determined by the PRO but the PRO sets fees according to the budget and goals set by government directives. In the case of Refashion, their budget, methods of implementation and the objectives are determined by the French Ministry of Ecological Transition.

EPR fees have largely been set with the intention of internalizing the cost of safely and effectively managing the end-of-life of products, often with the focus of funding cost-effective and efficient recycling systems. This “management” may include accounting for the cost of collection, sorting, transport and/or recycling as well as the administration of these activities.

Increasingly, EPR fees are being used to incentivize producers to improve the overall environmental performance of their products. This goal is typically pursued by using a bonus / malus system of eco-modulation, a system that rewards (bonus) producers for doing things like increasing the recycled content in their products, utilizing lighter-weight materials, eliminating complex chemistries in favor of monomaterial products and designing for improved durability, repairability and recyclability.

This is great in theory, but if producers do not feel the burden of waste management then there is little incentive to change entrenched systems, especially that of the overproduction causing Waste in the first place. In addition, eco-modulation has proven to work best, within sectors like packaging, when fees are modulated according to diverse, advanced science-driven criteria that takes into account recyclability within different contexts. Given the universal lack of recycling infrastructure for post-consumer textiles, we believe that eco-modulation is meaningless without clear reduction targets.


What is the status of EPR for Textiles?

In November 2022, our team at The Or Foundation partnered with Vestiaire Collective to host a Kantamanto Delegation of 15 people, including retailers, tailors and former kayayei, in Paris to meet with Refashion, the Ministry of Ecological Transition, brands, clothing collectors and charities to share our position on EPR and to advocate for swift reform to the current framework. Watch the video above to learn how our delegation views EPR.

France is the only country that has an EPR program for textiles and clothing. The Ministry of Ecological Transition sets the directive and Refashion, formerly Eco TLC, is the sole PRO administering the French EPR Program. Here are the key facts you should know.

  1. In 2021 34% of the garments placed on the French marketplace were collected through the EPR Program.

  2. Although garments can qualify for a fee of up to €0.063 (six cents), the average fee paid by brands in 2021 is €0.0116 (one cent) per garment with 81% of items declared being eco-modulated based on durability. With this, Refashion collected €51.1 Million in fees.

  3. In 2021, France exported 80% of tonnages collected under EPR. Of this, France exported 60,000 tonnes to countries across Africa, equal to 599 garments per minute. Ghana is the 12 largest recipient of clothing from France and our neighbor Togo is the second largest destination of secondhand clothing exports from France (the first is Haiti).

  1. Refashion pays registered sorters in France and in other European countries €80/tonne sorted for reuse and €180/tonne sorted for recycling and solid recovered fuel.

  2. In 2020, French sorters / exporters sold sorted clothing to Ghanaian importers for an average of $0.72 per kg or $720 per tonne.

  3. Refashion openly tracks exports to the top 27 receiving countries and yet €0.00 have been distributed to communities, governments or NGOs in these receiving countries.

  4. The French Ministry of Ecological Transition has set a goal of increasing collection to 60% of new garments introduced onto the market by 2028, but the target for reusing clothing within 1,500km of the collection point is only 15% by 2027. France will inevitably continue to export the majority of the clothing that is collected domestically through EPR.

  5. Although it is not prohibited by the policy framework and although the French EPR program pays sorters in other European countries, neither The French Ministry of Ecological Transition nor Refashion have plans to distribute funds to communities like Kantamanto who ultimately manage the end-of-life of clothing bought and worn by French citizens.

While the French Textiles EPR Policy is far from perfect, France has taken action while other countries have stood still and Refashion has published extensive reports that inform our vision for a Globally Accountable EPR Policy. Someone had to get the ball rolling and we are happy there is a body of work to build on.

What could EPR Become?

We believe that EPR has significant potential to catalyze a Justice-led Transition from a Linear Textiles Economy to a Circular Textiles Economy. To do this we call on policy makers to implement EPR programs for textiles based on three key principles.

(1) Internalized Cost of Waste Management

EPR Fees must align with eco-modulated waste management costs throughout the global reverse supply chain and must financially incentivize alternatives to linear waste practices. We call for eco-modulated fees starting at US $0.50 per newly produced garment as a floor rate for EPR programs.

(2) Global Accountability

EPR programs must align with the reality of how waste flows around the world, distributing funds to enable circular infrastructure in the Global South as well as the Global North and to account for the loss and damage already incurred by fashion’s excessive waste sent around the world to under-resourced and climate vulnerable communities.

(3) Disclosures to Drive Circularity Targets

In order to achieve ecomodulated EPR Fees, programs must require companies to disclose production volumes along every eco- modulation tranche. We call for this information to be publicly available on a per company basis and for five year reduction targets for new clothing of at least 40% over five years, balanced with the increase of reuse and remanufacture of existing materials.

As a model for other EU member states and countries establishing EPR policies for textiles, we are also calling for the French Ministry of Ecological Transition and the French PRO Refashion to make reparative payments to Haiti, Lebanon and all the African Countries that France exported clothing to in 2021 to the equivalent of no less than €80 per tonne, in line with the fee paid to clothing sorters in France. This amounts to roughly €5.7 Million. We are calling for the French EPR Program to immediately adopt the above principles, including the creation of an Environmental Fund to support the remediation of current disposal sites such as the Korle Lagoon in Accra.

Kantamanto Demands Change

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The EU Proposal for EPR does not Stop Waste Colonialism.
Stay tuned for Upcoming Calls to Action.

Our Analysis and Targeted Amendments