Make EPR Globally Accountable, starting with France and the EU.
Globally Accountable means that if the Global North continues to outsource the waste management of their overconsumption by exporting clothing to communities like Kantamanto, then Kantamanto would receive their fair share of the EPR fee paid by producers.
Kantamanto is a place, a culture and a community, a community on the receiving end of a colossal problem and a community that is contributing more to circularity than any company in the Global North.
The fashion industry produces more clothing than we can consume and the Global North consumes more than they can use. At the end of fashion’s oversupplied linear economy is Kantamanto Market in Accra, Ghana, the largest secondhand clothing market in the world. If you have ever donated clothing to a charity shop or put your clothing in the “recycling” bin down the street, there’s a good chance your garments ended up here. Key to understanding Kantamanto is to hold two truths in your mind at once:
One, Kantamanto Market is on the receiving end of fashion’s waste crisis. Every week, 15 million garments arrive from countries across the Global North and 40% leave as waste, often within one or two weeks of landing at port. This waste ends up in burn piles around the city, dumped in informal settlements where it pollutes the backyards of Accra’s most vulnerable citizens or it is washed out to sea. This waste has plunged retailers into debt (it is not free), decimated the local fashion ecosystem and created an economy reliant on cheap and dangerous labor, with young women working as kayayei (head porters) literally being crushed to death by the weight of the clothes they carry.
Two, Kantamanto is the most sustainable retail ecosystem in the world. This sprawling market is the largest resale and upcycling economy on our planet, with 30,000 individual entrepreneurs working together to recirculate over 25 million garments per month. These garments are not recirculated in pursuit of marketing language and 2030 KPI targets, these garments are recirculated because Kantamanto is far more than a static retail store. Kantamanto is a lab, a factory, a studio, a community center and a market all in one. Ghanaian shoppers do not come to Kantamanto hoping to find exactly what they want in their exact size, they come looking for material to customize. Sitting next to retailers are rows of tailors re-sizing garments, designers transforming lower quality clothing into luxury garments, graphic designers re-printing millions of single-use t-shirts, cobblers making one-of-a-kind shoes and thousands of people cleaning and dyeing stained clothing. Kantamanto leverages this indigenous sustainability logic to transform millions of garments that were discarded by citizens in the Global North into garments of value.
Discover Kantamanto We Are Circular Economy video by The Or Foundation
Kantamanto is the end of the line.
Kantamanto is also the beginning of the circle.
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”. This is quite visible in the context of Kantamanto.
For one, Kantamanto occupies over 20 acres of real estate in the center of Accra. The Market sits 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 GN 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. While some locally worn clothing and textile may be tailored in Kantamanto, none of the secondhand clothing that is resold in Kantamanto comes from Ghanaian households, thereby displacing opportunities for locally generated “waste” to be managed in ways that benefit Ghanaians.
Two, roughly 40% of the average bale leaves Kantamanto as Waste. This material from the Global North dominates formal dumpsites, taking up space that was not allotted for within the City’s urban plan. Prior to 2019, most of Kantamanto’s formally managed waste was hauled to an engineered landfill called Kpone, but the excess and unexpected clothing Waste caused this landfill to explode in August of 2019, an event that created an environmental disaster of its own. Since then, more and more of Kantamanto’s textile waste has been handled informally, leading much of the clothing to end up on Accra’s beaches.
By the time clothing washes out to sea, it has wrapped around itself, like when you put too much clothing in your washing machine, entangling all sorts of other things in the process like scrap metal and plastic bags while also soaking up industrial and human excrement. We call these tangled masses “tentacles” and we have a beach monitoring team that combs Accra’s coastline every week, counting these tentacles, measuring them and documenting the brands that end up in the Wastestream. We have found tentacles that stretch up to 30 meters long and we have found mounds of textile waste taller than 180cm as well as mounds of textile Waste buried under the sand, reaching over two meters below the surface. What most people don’t realize, because it can’t be seen in the images, is that these tentacles travel in and out with the tide, eventually becoming so heavy that they sink. Whatever we are seeing on the surface of Accra’s beaches represents a fraction of what we believe is sitting on the seafloor.
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. “Development” initiatives often blame the communities closest to the disposal sites for the Waste and use the pollution generated by the Global North to bulldoze the homes of some of the cities most vulnerable people and to “develop” the land, often for the benefit of foreign people and foreign companies.
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, with the “receiving” Global South having little-to-no say in the materials they must accept.
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, which was not that long ago – you probably know someone who was alive when Ghana was a British colony.
Under colonial rule, local citizens were required to conform to professional dress codes as defined by the British. Local ingenuity was suppressed in favor of imported ideas and products that financially and socially benefited the colonizer. People were required to swap their local dress for a suit and tie if they wanted to enter certain buildings or to get certain jobs. The British utilized dress codes within schools and churches to demean, and even demonize, indigenous dress. 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, the normalization of polyester, the mall boom and the introduction of credit cards across the Global North collided to transform clothing from a durable product to a consumable commodity. The secondhand clothing trade was introduced to the GN consumer, marketed as charity, allowing Global North citizens to consume more clothing guilt free because there was now an outlet for their excess stuff. Meanwhile, in Ghana, access to secondhand clothing, a cheaper alternative to new western style clothing, allowed more people to signal proximity to power.
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 fashion trends through the control of media narratives, and Ghanaian citizens have subsequently become more dependent on secondhand clothing as a cheap way to subscribe to those trends.
Under Structural Adjustment in the 1980s, international loan money flowed to infrastructure projects focused on moving raw resources out of Ghana, not to infrastructure projects that fostered trade within the country or across the continent. 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.
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.
Persistent colonial mythology makes it easy for Global North citizens to be willfully ignorant, failing to ask seemingly obvious questions about where their “donations” “end up”.
Because it is difficult for people living in receiving countries across the GS to represent themselves and their reality, most people living in the GN have a skewed perception of what life is like in Ghana and across the African continent. There are not hoards of naked people in need of secondhand clothes. In fact, 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.
This is aided by the fact that the language around clothing donation and recycling is often misleading, if not completely inaccurate and deceptive. 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.
Unfortunately, Waste Colonialism is becoming more pronounced as it takes on new dimensions. Global North brands are considering setting up sorting facilities in Ghana, facilities that would require importing more secondhand garments to be sorted for the benefit of GN companies seeking cheap feedstock for recycling to continue mass producing more clothes than we need, creating more Waste and expanding the carbon footprint as a result.
If France does not reform their EPR Policy, and if the EU and other Global North countries do not make EPR Globally Accountable, then EPR will codify Waste Colonialism and exacerbate the problem from an environmental, social and political perspective.
Want to learn more about Waste Colonialism in other sectors as well as in fashion? Check out the following resources:
Economic Diplomacy, Global Waste Trade: The African Perspective since the 20 th Century by Dominic A. Akpan and Bassey Inyang
Anti-Colonial Methodologies course on SlowFactory Open Edu Platform, taught by Max Liboiron
The History of Resale Markets course on SlowFactory Open Edu Platform, taught by Liz Ricketts
When it comes to fashion’s Waste Crisis, and more specifically Waste Colonialism, everyone wants to pin the blame on a singular villain, to find the one person or one company that is most responsible. But Kantamanto is not a factory on the receiving end of decisions made by one consolidated brand. The clothing that Kantamanto receives represents the sum of all the decisions made by every actor that came before Kantamanto including marketers, consumers, brands, suppliers, clothing charities and resale platforms.
Yet when we talk to brands, they pass the blame to consumers. When we talk to consumers, they blame charities. When we talk to charities they blame the clothing sorters and exporters. When we talk to clothing exporters they blame brands, consumers and Ghanaian importers.
This runaround is useless and highlights the larger issue within sustainability discourse, where the focus is on critique and blame, instead of on collective responsibility and action.
Yes, there are brands creating more Waste than others, but clothing Waste itself is a byproduct of a culture of disposability and of an economic system that incentivizes a linear, or hierarchical, accumulation of value. We need to stop wasting time pointing fingers up and down the supply chain and call for collective acknowledgment.
EPR is a mechanism for collective accountability, where everyone along the value chain must acknowledge Kantamanto and communities like it, and where the brands producing the highest volumes of non-recyclable clothing (that would be most garments on the planet today) contribute the most money to cleaning up this mess.
EPR stands for Extended Producer Responsibility and 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.
The term “Extended Producer Responsibility” was first coined in the 1990s when the German packaging take-back law was passed. 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). But only one country has an EPR policy for textiles and clothing – France.
France’s policy came into effect between 2007-2009, over a decade ago and is often cited as the roadmap to a wider policy framework that other EU member states must adopt according to the EU Sustainable Textiles Strategy. If adopted as is on a wider level, without making EPR Globally Accountable, this would put Waste Colonialism law across the EU.
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.
Resources on EPR (not textiles specific):
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.
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).
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.
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.
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.
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.
The funding is available and data needed to justify where the funds should be directed is also available. There is no technical barrier to distributing funds to receiving communities.The barrier is simply one of willingness to prioritize the prosperity of people outside of the EU, to prioritize the prosperity of the people who have been made most vulnerable by fashion’s waste crisis.
Yes! Nearly every country in the Global North exports clothing to the Global South. The USA is the largest exporter of secondhand clothing globally. The UK is the largest exporter to Ghana. China now also sends significant quantities to Ghana and other African countries. You can see which countries export and which countries import via OEC here (some importers are also re-exporters).
California, the UK and Canada have all begun the discussion about EPR for textiles.
If you live in the Global South, especially on the African continent, you have likely seen similar environmental and social impacts to what we see here in Ghana.
This is a global problem. The reason we are beginning with France and the EU more broadly is because France already has a policy and because the EU will be proposing a harmonized policy in June.
We will continue to update this website with news about emerging policies and focal regions. No matter where you are in the world, your voice matters. Endorse the position paper here!
Retailers spend a lot of money to purchase bales of secondhand clothing, anywhere from $75 to $500+, which in Ghana may represent several months of income ($475/year is the legal minimum wage in Ghana) and they buy these bales blind to the quality of goods inside. They do not have the ability to return a bale if it is moldy or full of garments in unsellable condition. Our research has found that the average retailer is $1.58 in debt per garment by the time she opens her bale due to the high prices of bales and the fees associated with her business. We also found that less than 20% of retailers make a profit on the average bale, with most retailers taking out loans to pay off other loans, operating in a cycle of subsistence debt.
Clothing leaves Kantamanto as waste because fast fashion has lowered the quality of clothing overall, turning clothing into a disposable commodity and thereby driving down the value. Secondhand retailers do not receive enough high value or “first selection” clothing to make a profit, leaving them without the resources to invest in the rehabilitation of lower quality items through washing, mending or tailoring. Retailers have to pay rent to store the clothing that they cannot sell and at some point they can no longer afford to keep the clothing lying around taking up space in their stalls.
With debts to pay off retailers must send unsold clothing to “The Away” (burn piles and the ocean), while they continue to gamble on the next bale, hoping that it will yield enough high quality garments for them to pay off past bales. Such hopes are rarely realized. It is not uncommon for one bad bale to end a retailer’s career overnight because they are unable to dig out of debt.
When we say that Kantamanto is on the front lines of fashion’s waste crisis, we mean that everyone working in Kantamanto exists in a constant state of crisis, laboring in survival mode. The more debt, the more waste.
Debt relief is key to ensuring that Kantamanto can continue to resell, repair and upcycle garments. EPR is one mechanism for reducing the debt burden.
We, at The Or Foundation, do not advocate for a ban on secondhand imports into Ghana. Any Kantamanto retailer would tell you that they are tired of being dumped on, but this same retailer would also say that they do not want a ban. Why is there a tension between these two truths?
First, an estimated 30,000 people work in Kantamanto and there’s not yet the infrastructure in place for the majority of these 30,000 people to transition to alternative industries. Is this the same as saying that the Global North has created jobs in the Global South through the secondhand clothing trade? No, the secondhand clothing trade is a business, not charity. The 30,000 people working in Kantamanto have created jobs for themselves, paying hefty sums for bales of secondhand clothing and investing in their businesses with zero support from the Global North.
Second, the secondhand clothing trade destroyed the local textiles economy decades ago, leaving little local industry to fill the void that would be left by a ban. Add to this the fact that the secondhand clothing trade has lowered the value of clothing overall, slowly teaching Ghanaian citizens that clothing is a disposable commodity, and it becomes clear that a ban would open the floodgates for foreign fast fashion to replace foreign secondhand goods. Not only is secondhand clothing environmentally preferable to new clothing, but replacing the secondhand products with new products would likely not allow for the same distributed economy that underpins the sustainability of Kantamanto.
Kantamanto is not defined by where the clothing comes from. Kantamanto embodies the skillset and mindset of circularity, it’s just that this skillset and mindset have rather forcefully been applied to a foreign waste management problem instead of applied to sustain itself. Kantamanto is defined by a culture of upcycling, informed by indigenous sustainability logic and fueled by a respect for sewing as a necessary life skill. The average Kantamanto retailer and consumer views clothing as material to be customized, in part because it is secondhand. New fast fashion products are likely to be treated with more authority, stripping Kantamanto of its creative agency and thus shifting the way consumers engage with fashion overall.
So, what’s the solution? We advocate for an incremental decrease in the amount of clothing coming into the market coupled with EPR funds that can be used to uplift the remanufacturing already taking place in Kantamanto and to build infrastructure for recycling and decomposition. Globally Accountable EPR would provide the investment necessary for “sender” countries in the Global North, as well as “receiving” countries like Ghana, to develop localized circular economies, both becoming less dependent on the export / import of material to fuel these circular ecosystems.
Our hope is that over time, through Globally Accountable EPR, Kantamanto will evolve to thrive as a market that primarily resells, repairs, remanufactures and recycles locally worn clothing, revitalizing the local textiles industry in the process. For more on how we are working towards this vision you can email us at email@example.com
It is common for the Global North to refute the claim that the secondhand clothing trade is a form of waste colonialism because the stated intention of Global North charities and exporters is to send “usable” clothing that is not “waste”. Indeed, most of the clothing that arrives in Ghana has been sorted by non-profit and for-profit organizations in the Global North who claim that all “waste” is removed during sorting.
There are several issues with this argument:
Quality is contextual. It will always be more accurate for someone in Ghana to sort by their own standards than it will be for someone from the UK to judge what a customer in Ghana desires. Kantamanto itself is a sorting “facility”. When retailers open their bales the first thing they do is sort the contents of the bale into four piles based on culturally relevant criteria. Not all 100% of the material in a bale that is exported from the Global North labeled “Grade A Ladies Tops” will ever be considered Grade A by the Kantamanto retailer who purchases it.
The sorting process is labor intensive whether you are in the Global North or in Kantamanto and neither side is being supported to the degree necessary. Due to a lack of adequate financial support, Global North sorters work at a pace that inevitably lends itself to mistakes. When a human being is standing for hours, sorting thousands of garments per shift, it is understandable that even highly-skilled workers will miss some un-re-wearable garments.
Textile “Waste” is also contextual, perhaps much more so than other materials that are managed under EPR schemes. Sorting out clothing “waste” is not the same as sorting plastic bottles, for example.
The reuse of bottles occurs primarily within the home, so sorting bottles is largely to determine recyclability. Sorting bottles for recycling depends on criteria such as color, whether the cap and label are attached and if there is liquid inside. While sorting bottles is not a simple process, this criteria is straightforward. But clothing? Clothing has far more reuse potential outside of the home compared to a plastic bottle. This means that the sorting of clothing in the Global North is intended to identify both reuse and recycling streams. The criteria for what makes a garment reusable is not as cut and dry as what makes a bottle recyclable. Some people prefer holes in their jeans, and color preferences are subjective, not to mention the fact that each item is far more diverse in shape, color, texture and construction than a plastic bottle. Sorting technology can assist with identifying feedstock for recycling, but better sorting will not solve the problem of “waste” ending up in Ghanaian markets, landfills and beaches.
Unlike a plastic bottle, which is a commodity defined by function, clothing is imbued with emotional durability and cultural value. What becomes “Waste” in Ghana may therefore always be different from what becomes “Waste” in the Global North further underscoring the fact that Kantamanto is a sorting facility.
The Global North is exporting their excess to countries without landfills, let alone recycling infrastructure. The bottom line is that even “better sorted” clothing will be disposed of eventually, if not right away, so exporting excess to “receiver” countries that lack waste management systems comparable to those of the “sender” countries is never going to end well. Roughly 15 million garments are entering Kantamanto every week and all of them will eventually become waste, some right away and some years later. Given that there is no waste management infrastructure to deal with this inevitable waste, it does not matter how the material was “sorted” in the Global North. What’s more, resale of foreign secondhand clothing displaces the opportunity to build infrastructure for the resale, repair and re-manufacture of locally worn clothing, thus leading to more household waste, also with no waste management system.
While there is more than enough clothing in the world, there is not enough “better” or “high quality” or “grade A” clothing in the world to support an economically and environmentally sustainable secondhand economy. When our delegation visited France, we went to fast fashion stores, including H&M and Decathlon, to see the “new” version of the garments they receive. One delegate, Pat, walked out of H&M saying “that place is full of borla”. “Borla” means trash. Pat and the other delegates realized that the clothing they receive is low quality before it is even purchased and worn.
This is compounded by the fact that Ghanaian consumers have higher quality standards than the average Global North consumer, thanks to the Ghanaian familiarity with garment construction and bespoke tailoring.
Fast fashion garments are not made to have a long life, at least not without value add processes such as repair and re-manufacture, all of which cost money. The more Kantamanto retailers go into debt, the less resources they have to keep fast fashion garments in circulation. “Better sorting” in the Global North won’t provide the resources Kantamanto needs to make fast fashion garments valuable within the Ghanaian context.
“We will improve sorting” is an out-of-touch response to the demands of the Kantamanto community, disconnected with the fact that Kantamanto is itself a sorting facility, and ignoring the reality that with increased collection targets under EPR schemes, even improved sorting will still see a total volume increase in materials exported into global secondhand markets.
No, this is not true. We have seen waste arrive in bales from every country that exports to Ghana. But the larger point is that regardless of intentions, many of the items shipped by Global North exporters as wearable garments will inevitably end up as waste in Kantamanto and places like it. Please see the previous questions on sending “better” clothing and the question “what does debt have to do with waste” for more background on why the Global North’s understanding of “waste” does not reflect reality.
Demand? Yes many Ghanaians choose to buy secondhand clothing and yes, importers (many of whom are not from Ghana) pay to import containers of secondhand goods. But this does not mean that the “demand” is comparable to the way Global North shoppers buy clothing. An importer cannot go to a website and see the clothing items that will be packed in their bales. Even at a bale level, importers can ask for a certain number of Grade A versus Grade B bales, but they do not have full agency over the contents of the container. They cannot request a container with 200 bales of Grade A t-shirts and 150 bales of Grade A Men’s Suits, for example. Importers can only buy what the Global North decides to purchase, wear and “donate” or “recycle”.
The supply is entirely determined by the Global North.
Demand from Ghana does not dictate supply.
What’s more, a retailer buys bales without knowing what is inside. She will only know what country it was exported from and the type of garments inside — ladies’ blouses, for instance. If a retailer opens a bale and finds that it is full of unsellable items, she does not have the ability to return it or to get a refund.
Without ensuring that receiving countries have pathways for returning or rejecting the clothing they purchase from sender countries, it is misleading to claim that the Global North only sends clothing because there is demand.
Please also see the section on Waste Colonialism for the history of how the demand for secondhand clothing is tied to colonial compliance.
The French EPR program uses the term “eco-contribution” to describe the fee producers pay per garment. The term “eco-modulation” describes the process of developing a multi-tiered system of fees.
Under “eco-modulation” producers are not charged a flat fee across all of their products. Instead, they are charged different fees based on a specific set of criteria that reflects the positive and negative consequences of different material and design choices. For plastic packaging the criteria may be color, chemistry (type of plastic) and weight, factors which can influence the economic and technical recyclability of plastic packaging.
The majority of EPR programs, across sectors, are moving towards an “eco-modulation” fee model with the intention of influencing the design and manufacture of garments from day one, before they become waste, so as to ensure that the waste management, or circularity potential, of garments is factored into the manufacturing process.
Reduction targets are not abnormal for EPR policies. For example, the French Packaging EPR Program set an objective to reduce packaging volumes by 100,000 tonnes over 5 years – an objective that was met.
Our reduction target of 40% over 5 years pertains to the production of new clothing. Per our position, each producer’s progress towards this goal would be measured individually against their own production volumes for the year prior, but if not all brands achieve a 40% reduction in their production volumes, the fees would raise for the overall industry thus incentivizing collective action and collective accountability. The 40% reduction goal is based on the following statistics:
Per our research, 40% of the average bale that is opened in Kantamanto leaves the market as waste. We have documented this statistic consistently from 2016 to now, through surveys, interviews and detailed waste data analysis on the ground in Kantamanto. Kantamanto is abundant in the mindset and skillset necessary to resell and re-manufacture clothing, but this skillset is no match for the relentless onslaught of clothing. If Kantamanto cannot keep up, then no one can.
This is especially concerning when you consider that a majority of clothing on the planet currently does not even pass through the secondhand supply chain and is instead disposed of via landfill or incineration (the collection rate in France is 34% and only 15% in the USA, for example). As the EU works to increase collection rates across all member states, and while no country in the world has the technical capacity to facilitate fiber-to-fiber recycling at scale, the overall volume of clothing diverted to markets like Kantamanto so as to be kept out of landfills in the Global North will grow exponentially.
The infrastructure for a truly circular, closed loop, textiles industry does not exist anywhere in the world, the fashion industry has not developed reverse supply chains that come anywhere close to meeting the acceleration of garment manufacturing. The production of new clothing must be reduced to allow for adequate systems – social, financial and physical – to catch up.
Until we slow down production volumes, the efforts of Kantamanto will be overshadowed and the millions of dollars thrown into recycling technologies will not deliver impact, burning money on a burning planet.
Global North closets are filled with inactive clothing. For example, WRAP found that less than 30% of UK wardrobes are estimated to be actively in wear (WRAP, 2020) and a similar study (Maldini et al., 2017) found that the average share of unused garments was 28% in the Netherlands and 30% in Germany. Reducing production of new clothing by 40% will therefore not have a negative impact on the ability for supply to meet demand.
In a circular economy where waste becomes a “resource”, inactive closets can be considered “idle assets”, or “missing feedstock”. From this perspective, reducing production volumes may encourage consumers to keep more of their clothes in active use by replacing linear consumption models with sharing economy models such as renting and swapping, ensuring that they get their money’s worth in wears per garment, a behavior that is also good for the environment.
Clothing production doubled from 2000 to 2014, surpassing 100 Billion garments for the first time in 2014; nearly 14 items of clothing for every person on earth in just one year alone, not to mention the clothes that already exist. Between 1996 and 2012, the average amount of clothing purchased per person in the EU increased 40% (Šajn, 2019). Meanwhile estimates suggest that doubling the number of times a garment is worn would, on average, reduce GHG emissions associated with clothing by 44% In other words, there is a direct relationship between clothing utilization, consumption rates and climate targets.
More specifically, to be on the 1.5-degree pathway by 2030 the fashion industry would have to reduce emissions to 1.1 billion tonnes of carbon dioxide, equivalent (CO₂e), corresponding to a reduction in greenhouse gas emissions of nearly 60% compared to levels in 2018.
The Hot and Cool Institute’s report “Unfit, Unfair and Unfashionable” makes it clear that the easiest way to reduce CO₂e , given the infrastructure available, is to reduce consumption, stating that “we need to aim for a per capita fashion consumption footprint target of 128.7 kg of CO₂e by 2030 to comply with the Paris Agreement”. The Hot and Cool Institute determined that ‘If no other actions are implemented, such as repairing/mending, washing at lower temperatures, or buying secondhand, purchases of new garments should be limited to an average 5 items per year for achieving consumption levels in line with the 1.5-degree target.” The report defines a sufficient wardrobe as 74 active garments (including shoes) in a two-season country and 85 garments for a four-season country.
The Hot and Cool Institute also assessed consumption targets across regional and class boundaries to establish the following estimates:
A. “The footprint gaps between current fashion lifestyles and the target show that footprints need to be reduced by 60% on average by 2030 among the G20 high-income countries (Australia, Canada, France, Germany, Italy, Japan, Saudi Arabia, South Korea, the UK and the United States). The upper middle-income countries (Argentina, Brazil, China, Mexico, the Russian Federation, South Africa and Turkey) need to reduce their footprints by over 40% by 2030.”
B. To ensure that reduction targets fairly reflect current consumption patterns, “the richest 20% would have to reduce their footprint by 83% in the UK, 75% in Italy and Germany, and 50% in France, considering a few representative countries”
C. “To bring down fashion consumption emissions to levels compatible with the 1.5-degree target, the needed reductions range from 12% for France to 74% for Australia (Figure 1). Excluding France, reductions in high-income countries range from 49% (Italy) to 74% (Australia). Most upper middle-income countries are above the 1.5-degree budget for 2030. For these (South Africa, Mexico, Argentina and the Russian Federation), the needed reductions are estimated in the range of 35% to 61%. Emissions in all lower middle-income countries are below the 2030 budget.”
Yes and No.
There’s more than enough clothing in circulation globally to fuel circular economies in every region, and while resale is increasing in the Global North, secondhand clothes represent only around 9% of closets (ThredUp 2021 Report). As collection rates increase across the Global North, the amount of clothing entering the global secondhand clothing market is almost certainly set to increase.
That being said, if EPR is not Globally Accountable and if investments overall continue to be uneven, favoring the Global North, we may end up in a situation with the following injustices and inefficiencies:
Without an EPR policy that internalizes the true cost of waste management, or a subsidy of another kind, the Global North will turn to markets like Kantamanto as sources of cheap feedstock, exploiting the desperation of people who have gone into debt buying the Global North’s trash. This is already happening. Our team at The Or Foundation receives many requests from Global North companies including brands, development orgs, exporters and fiber-to-fiber recyclers asking us to help them “locate the waste” because there is a “shortage” of feedstock in the Global North.
Wait…the clothing comes from the Global North so how can there be a “shortage”? The shortage is entirely economic. A Global North charity, collector, aggregator or “recycler” can sell “cotton rich” material to a fiber-to-fiber recycler for $0.10 to $0.30 per kg. Compare that to the price of secondhand goods and it is clear why Global North exporters are not incentivized and, in many cases, cannot afford to sell material to recyclers. For example, in 2020, UK exporters were selling clothing to Ghanaian importers for an average of $1.26 per kg, French exporters for an average of $0.72 per kg, German exporters for an average of $1.03 per kg, Italian exporters for an average of $0.81 per kg, Dutch exporters for an average of $0.94 per kg, Canadian exporters for an average of $1.06 per kg and USA exporters for an average of $1.47 per kg. The importer then increases the price for retailers in order to cover duties and to bring in a profit. This means that the clothing “waste” that companies seek to transform into “feedstock” is more expensive if sourced from here than from the Global North. The reason that feedstock for fiber-to-fiber recycling is priced so low is because many fast fashion brands will only switch to recycled or “circular” textiles if the price is competitive, meaning that it is the same price, or less, than a virgin, or “linear” textile. The economics of fiber-to-fiber recycling have also been skewed by the fact that most innovation in this space has been piloted with pre-consumer feedstock, which is entirely different from post-consumer feedstock in terms of the logistics, and thus the cost, associated with collecting, transporting, sorting, disassembling, cleaning etc.
Neither Global North nor Global South secondhand dealers can afford to efficiently provide feedstock based on fast fashion economics.
If EPR is applied in a way that increases recycling infrastructure in the Global North but that does not address these economics and global dynamics, then recyclers will continue to attempt extraction from places like Kantamanto. Extraction, in our opinion, includes the establishment of foreign owned sorting and recycling facilities in Ghana that are set up to exploit the extremely low minimum wage in Ghana, especially if the financial models of these facilities rely on increasing the amount of waste coming to Ghana and plan to cut out communities like Kantamanto from the value chain in order to ensure that circularity disproportionately benefits the Global North.
If EPR is used to benefit Global North fiber-recyclers without also enabling the development of recycling technologies in Ghana, the Global North may divert preferred materials to Global North recyclers. Given the technologies available right now, this would consist of cotton rich materials (90% or above). This would undermine the waste hierarchy of the secondhand supply chain by interrupting opportunities for reuse, repair and upcycling prior to recycling, and would result in higher concentrations of toxic materials, such as blended synthetic fabrics with no recycling pathway available, ending up in the export stream to places like Kantamanto, thus making it even more difficult for Kantamanto, and for Ghana more broadly, to develop solutions.
If, on the other hand, EPR policies are implemented through Globally Accountable frameworks, infrastructure would develop more evenly, leveling the playing field, allowing for regional specialization and ensuring that materials, especially in regards to cotton versus synthetic, flow through the waste hierarchy and between countries in ways that yield environmental benefits and that more accurately reflects demand and economic potential.
For more on this please refer to the question above on “what does debt have to do with waste” and read our co-founder, Liz Ricketts’, Open Letter entitled “This Is Not Your Goldmine, This Is Our Mess”.
The fee we are proposing is an eco-modulated target between $0.50-$2.50 per garment. We arrived at this fee by considering the fact that Kantamanto retailers are $1.58 in debt per garment, and by comparing EPR to VAT, a tax that is applied to a garment at point of sale. Common sales tax and VAT rates in the Global North fall between 5% and 25% with a €10 t-shirt carrying a €2.00 tax (20% VAT) in Paris, France, for example. VAT is often regarded as the tax necessary to support the infrastructure that allows a sale to take place. If EPR is to support the infrastructure to manage the waste generated by the sale then it must be inline with the true cost of Waste.
A fee of $0.50-$2.50 per garment only seems high because the historical fee structure established by Refashion in France, which, in 2021 was an average of 1.16 cents, is far too low to be impactful on any level. It’s clear that the French government also feels that their EPR program must expand substantially in order to yield meaningful results. The French Ministry of Ecological Transition, which sets the directive for ReFashion, has dramatically increased Refashion’s budget target to over €1 Billion across 6 years ReFashion has yet to announce the new fee structure under this budget, but in a meeting between The Or Foundation’s Kantamanto Delegation and the Ministry of Ecological Transition on November 24th, 2022, a Ministry Representative told us that the fee would likely fall between €0.10 - €0.50 per garment.
The increase in fees follows a general trend across all sectors. This is because whereas EPR was once used primarily to cover waste management costs, EPR is now being considered a mechanism for circularity, including through eco-modulation of fees to incentivize a shift towards preferred materials. A complete overhaul of the waywe consume, use and dispose of products with the goal of eliminating waste all together requires far more funding than simply “managing waste”.
Second, given that only one country has EPR for textiles, the approach to regulating textiles is largely underdeveloped compared to other sectors. Most Global North governments that have been focused on pollution related to plastics for decades are only now considering the environmental and social consequences of fast fashion. It is no surprise then that the EPR fees for other sectors have undergone more scrutiny and more evolution over the years. EPR fees for plastic packaging, for instance, reflect a more urgent agenda compared to the fees Refashion has applied.
For example, Italian PRO CONAI’s 2020 fee structure for plastic packaging is eco-modulated across 4 levels, the first level being €150 per tonne for packaging with an effective and consolidated sorting and recycling chain and the fourth level being €660 per tonne for packaging with experimental sorting/recycling activities in progress of not sortable/recyclable with current technologies. This ratio between level 1 and level 4 supports our call for a wide range of $0.50-$2.50.
Given the current recycling landscape for fashion, the majority of garments in circulation would fall under level 4, which equates to €0.66 per kg, which, according to Refashion’s average weight of ~4 garments per kg would equal a comparable fee of €0.16 per garment. While this is not as high as the fee we are proposing, the comparison is informative given that the majority of clothing in circulation is also plastic but recirculating clothing is far more complex than packaging because there is a larger reuse and upcycling market outside of the household and because garments come in a much broader range of colors, styles, sizes, materials, construction etc. In addition to this, emotional durability is a factor that is far more likely to influence garment valorization and lifespan than packaging.
Lastly, if you, like us, believe that clothing should not be priced as if it is a disposable commodity, then a fee of $0.50 - $2.50 per garment (which does not apply to resale), should not be considered high.
Refashion has, to date, set base-rates, or “eco-contribution”, in regards to the weight of items. This is in part due to the current payment structure of the EPR scheme, which pays sorters by tonne and does not currently relate to the actual cost of managing textiles based on the varying pathways available for garment construction and fiber types. From there, Refashion has eco-modulated the fees based on a) durability (primarily based on wash cycles) and b) the integration of recycled materials from either post-consumer waste or pre-consumer waste. The 2023 directive has added additional criteria but Refashion has yet to announce the eco-modulation structure.
We believe that more research is needed, especially in regards to chemicals, in order to develop an eco-modulation strategy that reflects the complexity of fashion’s supply chain. We also believe that there is a rather clear need to design out materials that have no viable recycling pathway. For this reason, we have taken the stance that creating criteria based on fiber-content carries the most integrity within the current landscape. Given the recycling technology available currently, cotton garments and monomaterial garments have far more pathways available to them after first-use, compared to mixed-fiber garments. Kantamanto retailers and customers prefer cotton garments over synthetic garments and our ongoing research into microfiber pollution across water, air and sediment samples here in Accra indicates that synthetic fibers persist in the environment much longer than cotton microfibers, likely causing increased harm and necessitating more resources to detoxify, clean up and regenerate disposal sites.
While there is a growing body of research on the life-cycle of different fiber-types and on durability, including emotional durability, very little of this research has taken into account the quality standards, fiber preferences or waste management pathways in receiving countries like Ghana, which represent the true end-of-life and thus should be considered in the Life Cycle Analysis of garments. This is something we are learning more about ourselves through ongoing ecotoxicological research, some of which will be published in 2023, and through a decomposition pilot we are leading in Accra as part of a Laudes funded project in collaboration with the Biomimicry Institute and our scientific advisors.
We welcome inquiries from collaborators who would like to assist with developing eco-modulation criteria that incorporate the reality of communities like Kantamanto. If this sounds like you, please send an email to firstname.lastname@example.org.
Positively. The measures laid out in our position paper would increase the amount of money that could go to all facets of the reuse, upcycling and recycling industries in the Global North. In fact, Vestiaire Collective, a prominent resale platform with headquarters in France, is our lead endorser and they are working in solidarity with us to ensure that our position paper is widely circulated.
We want the Global North secondhand clothing trade to thrive and we want citizens the world over to replace purchases of new garments with pre-loved garments. We understand the labor involved. We have visited charities, sorters and recyclers, we have worked with multiple resale platforms and we have been invited to speak at events like the Goodwill International Delegate Assembly. We have seen and heard firsthand how the majority of people in this business are struggling to cope with the growing quantities of lower quality product, and we know that many collectors, sorters and exporters in the Global North need additional resources to ensure safe and dignified jobs and to ensure clothing is passed through environmentally and socially responsible pathways. For example, a leading not-for-profit collector and sorter operating in France told us that the current per ton rate paid by the French EPR scheme of €80.00/ton covers only 1/6th of the total costs involved in their operations. These economics do not disincentivize the continued reliance on export markets to cover the remaining costs.
Our position is that every entity working to replace new with pre-loved, deserves support. All we are asking is for the Global North resale community to acknowledge and prioritize Kantamanto and communities like it and then to work in solidarity with us to ensure that wealth and power are more equally distributed across the global resale market, afterall, there is enough clothing for all of us.
No. Globally Accountable EPR is only one step of many but it is absolutely necessary. Globally Accountable EPR gives frontline communities like Kantamanto the agency to invest in the future and until this is done, circularity will not be grounded in reality and will repeat the exploitative patterns of the linear economy.
EPR policies that are not Globally Accountable, that openly reward the sender, deny the reality of the receiver and attempt to erase decades of harm…these policies are the definition of Waste Colonialism.
First and foremost, the Kantamanto community has never been more in debt, more exploited or more devastated. Kantamanto’s demise comes at a time when the world most needs to learn from this community of skillful individuals who have, for decades, put into action, at scale, the very practices that the Global North aspires to adopt and espouses as “circular”. Without urgent intervention Kantamanto will truly become nothing but a pitstop on the way to the dump.
Second, as more resources are made available through the broader adoption of EPR, there must be a plan to ensure that these resources are fairly distributed. The French Ministry of Ecological Transition has set the budget of €1 Billion over 6 years to improve collection, sorting, reuse and recycling in addition to funds for repair. The Ministry has also set the goal of increasing collection to 60% by 2028 but the target for reusing clothing within 1,500km of the collection point is only 15% by 2027. This means that France will inevitably continue to export the majority of the clothing collected, likely in even larger volumes than today. With the increase in budget, we must ensure that these funds are distributed to the true end-of-life destinations such as Kantamanto.
Many countries are considering EPR for textiles. The Netherlands is set to announce a policy in July 2023, Sweden has already announced a policy but is rolling it out over several years (very slowly) and the EU is working on announcing a strategy for a harmonized policy by June 2023. In addition, the EU is revising the Waste Framework Directive in 2023. As an organization we also serve on an advisory committee for EPR in California and are hopeful that the USA will take steps to implement EPR policies for textiles within the next year.
To be clear, if we are successful in making EPR Globally Accountable, it will likely take a couple years for funds to tangibly become available to communities like Kantamanto because of the time it takes to onboard producers, roll out the framework, and because fees are paid based on the previous year’s production volumes. But if we do not act now, before emerging policies write Waste Colonialism into law, reversing the harm done will take much much longer.
We support all measures to improve transparency across the industry, including Digital ID, although the use case for this technology has yet to be developed within Kantamanto and markets like it across the Global South. That being said, no, we do not need to wait for Digital IDs and increased traceability to responsibly and rationally send funds across international borders.
The global flow of secondhand clothing is readily traceable via UN Commercial Trade Data using HS code 6309, so there is no secret as to who is sending the clothes and who is receiving the clothes. Trade data, however, is not enough to reflect where money should be directed. To this end, we created the Circular Finance Factor (CFF) , which is based on measuring “GDP Per Capita Per Garment Per Capita” (a mouthful…hence the term CFF). This tells us which countries receive the most secondhand clothing per citizen and have the least financial resources to deal with it. It is these countries that should be prioritized within a Globally Accountable EPR program.
Globally Accountable EPR funds distributed to countries like Ghana would share the primary objectives of the French EPR Program – support reuse, repair, upcycling and recycling infrastructure, prevent waste and improve design.
In the case of Kantamanto, funds could be used to upfit the market and alleviate the debt burden, thereby enabling retailers and tailors to apply their skills with greater freedom and effectiveness.
Funds would also improve the collection and management of waste from markets like Kantamanto as well as from households. This would include the development of local recycling systems, across both fiber-to-fiber and other sectors.
Similar to Refashion, funding could also flow to local advocacy, local research & development projects, including entrepreneurs working in digital resale or upcycling and continued research into emotional durability within the Ghanaian context as well as the research into impact of specific types of waste on the environment and on human health.
Given the decades of damage caused by the secondhand clothing trade here in Accra and elsewhere, we have also called for the creation of an environmental fund dedicated to the remediation of current disposal sites such as Accra’s coastline and Korle Lagoon.
These are all activities that The Or Foundation is currently engaged in and has committed resources to based on the feedback of Kantamanto retailers, tailors and kayayei.
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.
This is an evolving long-term project.
Our 2023 goals are:
Support the Kantamanto community in their fight against waste colonialism.
Grow a network of advocates who are committed to putting Kantamanto’s concerns and reality front and center when it comes to circularity.
Ensure that our position paper is prioritized in all discussions related to textiles EPR.
Shape EU, UK and California EPR Policy to benefit Kantamanto and communities like it.
Work with the Ministry of Ecological Transition and PRO Refashion to secure funds for 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. By way of comparison, in 2021 Refashion spent €23.5 Million on sorting in France and Europe, €2.5 Million on communications and €622,000 on an Innovation Challenge.
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Stay tuned for 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. We will update this website accordingly.
We plan to release additional statements and research, delving into the nuances of the position paper and the mechanics of implementation.
Right now, our focus is on making sure that Kantamanto is heard before additional EPR policies, outside of France, are established, while also continuing with our many programs on the ground in Accra.
Please join us in this effort!