The European Commission’s Proposal for Extended Producer Responsibility does not Stop Waste Colonialism

Accra, GHANA, JULY 11, 2023 –

The proposed amendments to the Waste Directive released on July 5th by the European Commission do not stop Waste Colonialism. The keystone interventions of the Proposal as currently written are not based on a sound understanding of the structure and practices of the global secondhand clothing trade. While the intention to address rampant overproduction and overconsumption is made clear within the Proposal, what’s missing is a willingness to incorporate the realities of the people most deeply impacted by fashion’s waste crisis and to support the solutions taking shape in those communities. The Proposal fails to make Extended Producer Responsibility Globally Accountable. Moreover, in the absence of targets for volume reduction, the proposal fails to rigorously challenge the overproduction that is inherently linked to waste, environmental devastation and climate change. The Or Foundation, which has organized three delegation trips to bring retailers and upcyclers from the world’s largest secondhand clothing market, Kantamanto Market in Accra, Ghana, to Europe to meet with members of the European Commission and members of the European Parliament along with brands and ally organizations, calls on MEPs to seek targeted amendments to the Proposal before signing it into law.

Joining The Or Foundation in this call is Engineer Solomon Noi, Director of Waste Management for the Accra Metropolitan Assembly, who is charged with managing the waste flowing through Kantamanto Market and who has toured other secondhand clothing markets throughout the African Continent. Eng. Noi warns that “if passed without amendment, the Proposal will make Waste Colonialism an official EU doctrine, undermining efforts to improve working conditions in global secondhand markets, to create necessary infrastructure for circularity, and to mitigate environmental damage already caused by decades of overflowing volumes of clothing waste. If EPR is intended to manage the end-of-life of clothing, then EPR programs must move money to where the clothing ends up here in my country and other countries throughout the Global South. No program can claim to be extending responsibility if it does not extend to where the actual waste management is performed.”

The Or Foundation released the Stop Waste Colonialism position paper and campaign in February of 2023 with the endorsements of Eng. Noi, the Mayor of Accra, thousands of people working within Kantamanto Market to recirculate an estimated 25,000,000 secondhand items every month, and over a dozen allied organizations from across the Continent of Africa and the EU, including Lagos Fashion Week, the African Circular Economy Network, RoundAbout Community, Buzigahill, Vestiaire Collective, Fashion Revolution, Circle Economy and the European Environmental Bureau. The Or Foundation’s position paper has been shared with members of the European Commission working on the Waste Directive amendment, and a member of the European Commission met The Or Foundation delegation in Brussels. Unfortunately, the Commission’s proposal fails to incorporate the framework laid out in the Stop Waste Colonialism position paper, missing three key points:

  1. Sorting in the EU does not eliminate waste.The vast majority of clothing entering Kantamanto Market and other markets like it around the world is already sorted and labeled with the granularity stipulated by the Proposal, yet waste persists because the definition of waste can only be determined when and if individual items are purchased for re-use. Bales of secondhand clothing are not the product of re-use, rather the decisions of secondhand retailers, upcyclers and their customers are critical in defining which of the individual items inside of a bale will be re-used and which will be discarded as waste.
  2. Transferring EPR funds to final destination markets is critical to close the finance gap for circularity. The Proposal declares that closing the finance gap for circular infrastructure and environmental health is an intended outcome of the proposed EPR programs, but without explicitly moving funds to the countries and communities handling the end of life of the garments for which producers are to be held responsible, the Proposal misses the mark on closing the biggest gap. The Circular Finance Factor gap between Ghana and France, for instance, is 1 to 36, representative of the fact that Ghana has far fewer internal resources to manage textile waste than any EU member state.
  3. Reducing production volumes is the strongest method of fighting waste.Through production volume disclosures and eco-modulation for EPR fees, the carrot and stick to set reduction targets and strongly push fashion’s biggest producers to reach them are built into the structure of EPR, yet the proposal fails to put them to use. Information that the industry may regard as trade secrets cannot be guarded at the expense of the climate and the communities carrying the weight of overproduction.

The Or Foundation plans to release a detailed analysis of the Proposal and suggested amendments by the end of July, and subsequently intends to host a webinar to share how the realities of the trade within Kantamanto Market and other receiving markets around the world can be incorporated into the Proposal to not just acknowledge the problem of fashion’s waste crisis, but to actually solve it. More details will be announced via the campaign website StopWasteColonialism.org.


Stop Waste Colonialism Position Paper: https://stopwastecolonialism.org/stopwastecolonialism.pdf
Stop Waste Colonialism FAQs: https://stopwastecolonialism.org/frequently-asked-questions/
The Or Foundation’s Waste Landscape Report: https://theor.org/newsroom/post/60
The Or Foundation Delegates reflect on their November trip to Paris and why Globally Accountable EPR is critical: https://youtube.com/playlist?list=PL9MlUgj6K-_ihjD1IlNvjS4uKI6Q--xjP

About The Or Foundation
The Or Foundation is a USA and Ghana-based not-for-profit organization that has been working between the two countries at the intersection of environmental justice, education and fashion development since 2011. The Or Foundation has brought global awareness to fashion’s waste crisis through extensive research and action around the secondhand clothing trade as it manifests in Accra, Ghana, home to the largest secondhand clothing market in the world. To learn more about The Or Foundation, visit www.theor.org.

Press Contact: press@theor.org