New OECD Report: Due Diligence on Recycling Process in the Garment and Footwear Sector (February 2026)

Full report HERE

Key findings:

First, the textile recycling rate remains low in the garment and footwear sector. As the OECD report noted, the market share of recycled fibers remained at approximately 7.6% in 2024 within total textile fiber production.  Meanwhile, “of all recycled fibers, more than 90% was recycled polyester made from open-loop plastic bottles and less than 10% from actual post-consumer textiles.” For apparel sourcing, this means that using recycled input remains limited, fragmented, and often costly, challenging scalability for brands with large-volume sourcing models.

Second, the recycling supply chains are not immune to social responsibility and compliance risks. According to the OECD report, “Child laborin recycling processes is a key area of concern.” Meanwhile, a 2024 International Labor Organization (ILO) study cited in the report found that workers in waste management and recycling typically earn far less than in other sectors. Additionally,  since “textile waste collection, aggregation and sorting are often performed manually, especially in contexts where automated systems are not common,” working conditions could be an issue. Informal workers could also be hired in the recycling supply chain. For example, the ILO estimates that about 80% of jobs in the recycling sector are informal, and in Dhaka alone, around 100,000 women and children work as informal waste pickers. Overall, for fashion brands and retailers that source clothing made with recycled textile materials, this means that due diligence must go beyond traditional Tier 1 or Tier 2 suppliers to include waste and recycling networks. Additionally, recycling activities could occur in regions different from those of garment manufacturing hubs.

Third, the large-scale export of used textiles has implications for recycling outcomes. The OECD report noted that textile waste often crosses borders for sorting or recycling. However, such textile waste trade could undermine domestic recycling capacity (e.g., in the Netherlands, half of the collected textiles are sorted abroad, and the local sorting capacity is used to sort textiles from Germany) and create environmental burdens on textile waste-importing countries. The debate over managing the used clothing trade could continue (e.g., how to avoid shifting environmental burdens from apparel-consuming countries to textile-waste-importing countries, especially those in the developing world).

Fourth, regulatory shifts are reshaping global trade related to textile recycling. The OECD report highlights the EU’s Ecodesign for Sustainable Products Regulation, the revision of the Waste Framework Directive, and the expansion of Extended Producer Responsibility (EPR) schemes. These measures, either already adopted or under development, mandate the separate collection of textiles from mixed household waste, require sorting prior to export to prevent misclassification of waste as reusable goods, and shift the financial responsibility for end-of-life management to producers. For fashion brands and retailers, these changes are likely to raise compliance costs and demand greater traceability throughout supply chains, including post-consumer waste. They also create stronger incentives to redesign products for durability, recyclability, and lower environmental impact, as regulatory fees and trade restrictions become directly tied to “product characteristics.”

Additionally, due diligence for fashion brands and retailers must be adapted to the era of circularity. The OECD report recommends that fashion companies prioritize:

• scoping new high risk actors (waste pickers, sorters, informal workers),
• identifying “choke points” in waste flows (e.g., large sorting hubs, major aggregators, or recycling facilities that process high volumes of textile waste and therefore have leverage over upstream practices)
• evaluating how their own purchasing practices may contribute to downstream impacts (e.g., low pricing pressure or rejection of unsold goods can push waste handling into informal and unsafe channels).
• meaningful engagement with workers and informal sector representatives, particularly in contexts where recycling activities occur in small workshops, open-air settings, or home-based units with limited regulatory oversight.

Summarized by Sheng Lu

For FASH455 class: When writing your blog comment, you may consider addressing the following aspects. Students are strongly encouraged to read the full report before leaving their comments.

• Does global textile trade enable circularity or export waste burdens?
• Should countries restrict used textile imports and exports?
• Should brands prioritize textile-to-textile recyclability even if it increases costs or limits design flexibility? How might this shift sourcing geography or supplier selection?
• To what extent should fashion brands and retailers be financially and legally responsible for post-production and post-consumer waste? Should waste costs be integrated into retail pricing?