EIA Submission to Basel Convention Secretariat

Submission by the Environmental Investigation Agency (EIA) in response to the Basel convention secretariat’s information request on textiles

EIA is a non-governmental organisation (NGO) with more than 40 years of experience investigating environmental crime and supporting effective policy development and implementation at the international, regional and national levels, including the Basel Convention and the European Union (EU) Waste Shipment Regulation (WSR).

For years, our work has identified systemic weaknesses in the global trade and management of waste streams, documenting how loopholes, misclassification and poor enforcement enable environmental harm. Drawing on our experience exposing illegal trade in electronic waste (e-waste) and plastic waste, EIA has developed expertise in data review and trade analysis, combining customs data, shipping records and field investigations to identify areas for strengthened governance.

Drawing on this experience, EIA’s position on textiles is all textile waste should, as a minimum, be presumed to be an “other waste” controlled under Annex II and subject to the Prior Informed Consent (PIC) procedure. This reflects the real composition of modern textile waste, which is almost entirely synthetic or blended, chemically treated and shed microplastics and contaminants through use, disposal and recovery. These characteristics make recoverable textiles indistinguishable from mixed or unrecoverable waste.

Hazardous textile waste must also be appropriately listed under Annex VIII. Large volumes of post-consumer textiles contain hazardous chemicals, including per-and polyfluoroalkyl substances (PFAS), brominated flame retardants (BFRs), chlorinated paraffins and azo dyes. Studies have identified textiles (including carpets, upholstery and garments) with concentrations exceeding persistent organic pollutant (POP) thresholds and present risks consistent with hazardous waste classifications.

This approach aligns with the Basel Convention’s core objective to protect human health and the environment from the adverse effects of hazardous and other wastes by preventing the unregulated export of difficult, contaminated and low-value waste to countries without the capacity for environmentally sound management (ESM). It reflects the Convention’s core principles of control, transparency and precaution. Where the nature or risks of a waste stream cannot be reliably assessed at the border, where chemical composition is unknown and where waste is routinely mixed, the Convention defaults to oversight through the PIC procedure.