Whose Loop Is It Anyway?

Is Recycling Policy Serving the Public Interest or Private Constraints?

In the context of the European Union's ambitious sustainability agenda, the Ecodesign for Sustainable Products Regulation (ESPR) represents a landmark framework for advancing circularity across product value chains. Among its most debated provisions are the proposed thresholds for recycled content in textiles. The T2T Alliance, composed of a consortium of textile-to-textile recycling companies, has issued a position paper offering recommendations for how these thresholds should be defined, sourced and verified. While the document is positioned as a constructive contribution to policy design, a closer reading reveals a number of unresolved contradictions, convenient assumptions and policy risks that merit close examination.

The paper urges the inclusion of post-industrial textile waste from manufacturing countries such as India, Bangladesh, Morocco and Tunisia in the definition of recycled content eligible to meet EU targets. The rationale provided is twofold. First, this waste stream is described as clean, abundant and already embedded in efficient industrial collection infrastructures. Second, it is suggested that relying solely on post-consumer textile waste within the EU will not be feasible in the short term due to infrastructural constraints and delayed policy implementation under the revised Waste Framework Directive.

At first glance, this proposal appears pragmatic. However, its implications warrant closer scrutiny. The most pressing question is whether it is appropriate or desirable for the European Union to meet its recycled content obligations by extracting post-industrial waste generated in the Global South. These are regions that are often under pressure to manage their own waste and are in the process of developing domestic reuse and recycling ecosystems. By defining EU circularity achievements based on waste sourced from textile production hubs outside the Union, the policy risks reinforcing existing asymmetries in global resource flows. In effect, the EU would be importing the benefits of clean and processable waste while shifting the systemic costs of circular transition onto other regions.

This is not merely a logistical or efficiency issue. It raises questions of environmental justice, sovereignty and long-term system design. Many Global South nations have introduced restrictions or outright bans on the import of foreign waste precisely to avoid becoming externalised repositories for the by-products of wealthier economies. In this context, creating new commercial channels through which their own waste is exported to serve regulatory goals of the Global North risks repeating the very dynamics such countries have sought to transcend.

There is an additional concern. If Europe builds a recycled content compliance mechanism that depends structurally on post-industrial waste from abroad, it disincentivises the urgent investment needed to scale domestic post-consumer waste recovery. The T2T Alliance's position suggests that Europe lacks sufficient volumes of post-consumer textiles to meet the proposed 2028 threshold of ten percent recycled content. This claim, however, is difficult to reconcile with the publicly stated readiness of T2T technologies themselves. These technologies are often promoted on the basis that they are viable, ready to operate, and only require stable demand signals and financial support to scale. If that is true, then why is post-consumer waste being portrayed as inaccessible or inadequate?

Available data suggests that EU textile waste is close to seven million tonnes annually. While not all of this material is immediately suitable for recycling in its current form, the issue is less about overall volume and more about factors such as fiber variability, contamination, and the cost of collection and sorting. Importantly, based on the current scale-up plans and announced developments of textile-to-textile recycling facilities across Europe, the volumes of post-consumer waste already being sorted for recycling should be sufficient to meet their projected input needs. In other words, the challenge lies not in the scarcity of feedstock but in the limited capacity of existing technologies to process complex and heterogeneous materials at scale. The reluctance to address these material limitations directly, and the redirection of attention toward cleaner and simpler pre-consumer inputs, appears to sidestep rather than solve the technological barriers that must be overcome for a truly circular textile economy to emerge.

This brings us to the question of verification. The T2T Alliance proposes a combination of Chain of Custody systems and mass balance accounting, similar to the one used in the Better Cotton certification schemes. This approach would allow producers to account for recycled content at a systemic level without requiring physical traceability in each final product. While this may appear administratively efficient, it introduces serious risks of consumer misinformation and weakens the credibility of circularity claims. Under a mass balance model, a garment may be labeled as containing ten percent recycled material even if it contains none at all, provided that an equivalent volume of recycled input was introduced somewhere else in the production system.

The BCI system has been repeatedly criticised for enabling greenwashing, precisely because it allows claims of responsible sourcing without material confirmation at the product level. Applying the same logic to textile recycling means that the visibility of circular flows is decoupled from their material reality. This undermines the transparency that both regulators and consumers increasingly demand. Textile supply chains, already among the most opaque in the global economy, are uniquely ill-suited to volume-only verification mechanisms. The inclusion of digital tracking tools does not solve this problem unless they are embedded within enforceable and physically verifiable systems. This remains an aspirational condition at best.

Another point in the T2T Alliance’s argument relates to the claim that post-industrial textile waste cannot be reduced below ten to fifteen percent, even under best practices. The only evidence offered in support of this claim is a master’s thesis which cites an anonymous source. While early-stage academic work is valuable, this particular citation lacks the transparency and replicability required for regulatory credibility. The thesis itself does not provide a peer-reviewed methodological framework, nor does it disclose any data on sampling or industry validation. If policymakers are to base durable definitions of “unavoidable” waste on such figures, the evidentiary standard must be significantly higher.

It is not unreasonable to suggest that some post-industrial waste is structurally inherent to current production methods. However, the degree to which this is immutable is both under-researched and context-dependent. Process innovation, lean manufacturing principles and better fabric cutting algorithms have all demonstrated potential to reduce production spill rates. To enshrine ten to fifteen percent as an accepted baseline without clear, peer-reviewed evidence risks baking inefficiency into the definition of circular compliance.

The broader concern is that this entire suite of proposals presents a vision of circularity that is technically legible but strategically regressive. It offers operational feasibility in the short term at the expense of system transformation in the long term. By relying on clean, offshore post-industrial waste, the EU can meet performance thresholds without confronting the full complexity of designing a resilient, equitable and materially closed textile economy.

Circularity is not just a question of volume flow. It is a question of ownership, responsibility and infrastructure. If the EU is serious about building a textile system that reflects these values, it cannot afford to externalise the burden of waste management, nor rely on verification tools that obscure the provenance and material integrity of recycled content. It must confront the inconvenient reality that building circular systems is hard, expensive and politically difficult. But it is precisely through that difficulty that credibility is earned and change becomes real.

This is not a dismissal of innovation. It is a demand for honesty, between what is being promised and what can actually be delivered. The technologies promoted by T2T recyclers are often described as transformative, yet too often they are shielded from scrutiny behind vague assurances and selective optimism. If these solutions are to play a credible role in the future of circular textiles, they must be embedded in systems that enforce transparency, rely on post-consumer inputs as a baseline, and acknowledge the geopolitical realities of where and how materials are sourced. Anything short of this is not a circular economy. It is a carefully packaged illusion.

Link to the original position paper: T2T position paper