A coalition of second-hand clothing industry leaders, including Kenya's Mitumba Consortium Association of Kenya (MCAK), has called for greater transparency and accuracy in the United Nations Environment Programme's (UNEP) ongoing research into used clothing and textile circularity. The lobbies have published an open letter to UNEP Executive Director Inger Andersen, urging the suspension of draft textile circularity guidelines until the underlying research is independently verified.

The coalition, which also includes the Ghana Used Clothing Dealers Association (GUCDA), Recycling Europe, and the Secondary Materials and Recycled Textiles Association (SMART), expressed concerns over what they term an "opaque" consultation process. They cite short feedback timelines, restricted access to draft materials, and the use of unverified or biased data, particularly regarding the definition of "waste."

Historical and Political Context

The second-hand clothing industry, popularly known as 'mitumba' in Kenya, plays a significant role in the country's economy and provides affordable clothing options for a large segment of the population. The trade was initially banned in Kenya from the mid-1960s to the early 1980s to promote domestic production. However, these restrictions were eased in the mid-1980s, allowing second-hand clothes as donations for refugees, and the ban was fully lifted in the early 1990s with trade liberalisation.

Despite its economic contributions, the mitumba industry has faced criticism for its alleged impact on local textile manufacturing and environmental implications. There have been calls for a balance between the local textile industry and the importation of second-hand clothes.

Laws, Policy, and Governance

While there is no specific statutory framework solely regulating the trade of used clothes in Kenya, the industry is governed by importation protocols published by the Kenya Bureau of Standards (KEBS) and regional and domestic trade laws. KEBS regulations require second-hand clothes and shoe importers to fumigate their merchandise and ensure consignments are accompanied by a health certificate from the country of origin. Importers must also register with KEBS and obtain a Certificate of Conformity (CoC) for each shipment. In March 2020, KEBS temporarily banned mitumba imports as a precautionary measure against the spread of COVID-19, lifting it in August 2020 with new safety protocols.

Stakeholders and Testimonies

The Mitumba Consortium Association of Kenya (MCAK) represents over two million individuals involved in the second-hand clothing supply chain, from traders to tailors. Teresiah Wairimu Njenga, Chair of MCAK, expressed concerns that poorly informed global guidelines could stigmatise or restrict the trade, crippling small businesses that rely on used clothing imports for survival. Jeffren Boakye Abrokwah, spokesperson for the Ghana Used Clothing Dealers Association (GUCDA), highlighted that the UNEP project could reshape national trade policies affecting millions of livelihoods worldwide.

Evidence and Data

The mitumba sector is a significant contributor to the Kenyan economy:

• In 2023, 24.2 million Kenyans bought second-hand clothing.
• The sector generated approximately KSh 16 billion in revenue in 2023.
• It employs an estimated two million Kenyans, representing about 10% of the national extended labour force.
• Kenya imported 197,000 tonnes of second-hand clothing in 2023, equivalent to 8,200 containers.
• The government collected an estimated KSh 16 billion in taxes from these imports in 2023.
• Between 2015 and 2018, the wholesale trade of second-hand garments involved an estimated 741,000 tonnes of used items.
• The annual value of this trade was reported in 2019 to be on average KSh 18 billion.

Risks and Implications

The coalition of second-hand clothing dealers fears that the UNEP project's methodological flaws, limited consultations, and unverified data risk undermining its legitimacy. They also raise concerns about UNEP's partnership with NGOs allegedly funded by fast-fashion companies, suggesting potential conflicts of interest. Restrictive guidelines could negatively impact the livelihoods of millions who depend on the mitumba trade for income and affordable clothing.

Unknowns and Controversies

The coalition has urged UNEP to suspend its draft textile circularity guidelines until the underlying research is independently verified. There is an ongoing debate about the environmental impact of the second-hand clothing industry versus the production of new garments. Some argue that importing second-hand clothes is less harmful to the environment than producing new garments locally due to high water and energy consumption, pollution, and carbon emissions associated with new textile production.

Timeline and Next Steps

The global guidelines on used textiles are expected to be tabled at the UN Environment Assembly (UNEA-7), scheduled for December 8–12, 2025, in Nairobi.

What to Watch

The upcoming UNEA-7 meeting in Nairobi will be crucial in determining the future of global guidelines for used textiles. Stakeholders will be closely watching for how UNEP addresses the concerns raised by the second-hand clothing industry coalition regarding transparency, data integrity, and inclusivity in the policymaking process. The outcome could significantly impact Kenya's mitumba industry and the livelihoods it supports.