Don ' t O v e r 1 oolc Text, i 1 es !
Few p e o p l e o u t s i d e o f t h e t e x t i l e r e c y c l i n g i n d u s t r y r e a l i z e
t h a t t h e I n t e r n a t i o n a l Association o f Wiping C l o t h Manufacturers i s
t h e t r a d e a s s o c i a t i o n r e p r e s e n t i n g one o f t h e o l d e s t and m o s t
established o f the recycling industries.
More t h a n 1,000
b u s i n e s s e s and o r g a n i z a t i o n s e m p l o y i n g many t e n s o f t h o u s a n d s o f
w o r k e r s d i v e r t some 2,000,000
tons o f t e x t i l e waste from t h e s o l i d
waste stream. M i l l i o n s o f i n d i v i d u a l s b e n e f i t f r o m t h e p r o d u c t s ,
o p e r a t i o n s , and programs c r e a t e d b y t h e r e c y c l i n g o f t e x t i l e w a s t e .
A s t e x t i l e r e c y c l e r s , a l l t h e i s s u e s b e i n g addressed.
c o n c e r n i n g r e c y c l i n g , r e c y c l a b i l i t y , source r e d u c t i o n , e t c ; have
I t i s hoped t h r o u g h e d u c a t i o n
relevance t o t h i s diverse industry.
and t h e , c o o p e r a t i o n o f government a g e n c i e s t h a t t h e consuming
p u b l i c w i l l r e c o g n i z e t h e n e e d and i m p o r t a n c e o f r e c y c l i n g
d i s c a r d e d a p p a r e l i n t o secondhand c l o t h i n g .
Acceptance of t h e s e
d e f i n i t i o n s as p a r t o f " r e c y c l i n g " w i l l h e l p e n c o u r a g e t h e maximum
r e c y c l i n g o f t e x t i l e w a s t e s and t h u s m i n i m i z e t h e amount o f
m a t e r i a l t h a t goes i n t o t h e w a s t e s t r e a m .
T e x t i l e w a s t e c a n b e c l a s s i f i e d as e i t h e r pre-consumer o r
post-consumer.
Pre-consumer t e x t i l e waste c o n s i s t s of: b y - p r o d u c t
m a t e r i a l s f r o m t h e t e x t i l e , f i b e r and c o t t o n i n d u s t r i e s .
Each y e a r
750,000 t o n s o f t h i s w a s t e i s r e c y c l e d i n t o new r a w m a t e r i a l s f o r
t h e automotive, f u r n i t u r e , mattress,
c o a r s e y a r n , home
f u r n i s h i n g s , p a p e r and o t h e r i n d u s t r i e s .
Through t h e e f f o r t s o f
t h i s i n d u s t r y a p p r o x i m a t e l y 7 5 p e r c e n t o f t h e pre-consumer t e x t i l e
w a s t e t h a t i s g e n e r a t e d i s d i v e r t e d f r o m o u r ' l a n d f i l l s and
r e c y c 1 ed.
Post-consumer t e x t i l e w a s t e c o n s i s t s o f any t y p e o f g a r m e n t s
o r h o u s e h o l d a r t i c l e , made of some m a n u f a c t u r e d t e x t i l e , t h a t t h e
owner no l o n g e r needs and d e c i d e s t o d i s c a r d .
These a r t i c l e s a r e
d i s c a r d e d e i t h e r because t h e y a r e worn o u t , damaged, o u t g r o w n , o r
h a v e gone o u t o f f a s h i o n .
They a r e sometimes g i v e n t o c h a r i t i e s
b u t m o r e t y p i c a l l y a r e d i s p o s e d o f i n t o t h e t r a s h and end u p i n
municipal l a n d f i l l s .
The F i b e r Economics B u r e a u r e p o r t s t h a t f o r 1989 t h e p e r
c a p i t a c o n s u m p t i o n o f m a n u f a c t u r e d c o t t o n , wool, and o t h e r f i b e r s
S t a t i s t i c s c o l l e c t e d by the Council f o r T e x t i l e
was 6 7 . 9 pounds.
R e c y c l i n g i n d i c a t e t h a t on a n a t i o n a l b a s i s t h i s i n d u s t r y r e c y c l e s
a p p r o x i m a t e l y 10 pounds p e r c a p i t a o r 1,250,000 t o n s o f p o s t consumer t e x t i l e w a s t e a n n u a l l y .
However, t h e s e 10 pounds
r e p r e s e n t l e s s t h a n 25 p e r c e n t o f t h e t o t a l post-consumer t e x t i l e
waste t h a t i s generated.
A c c o r d i n g t o t h e E P A ' s 1988 s t u d y on t h e
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United States Generation o f Solid Waste, textiles account for some
3.9 million tons of the solid waste stream. A number o f waste
composition studies indicate that this unrecovered textile waste
accounts for approximately 4 percent of the content o f our
landfills.
Almost half (48 percent) o f the post-consumer textile waste
that is recovered is recycled as secondhand clothing, which is
typically sold to third-world nations. It is through our
industry's efforts that the world's poorest are clothed.
Secondhand clothing is all that is affordable to an individual
Industry members are capable of delivering
earning $200 annually.
a pair o f pants in clean, damage-free condition to the east coast
o f Africa for 3 . 3 4 a pair and sweaters to Pakistan for $ . 1 2 each-less than the cost of mailing a letter. These prices include not
only the garment, but the cost of transportation as well.
Association members are able to do this because of their investment
in equipment and facilities to process efficiently and economically
the huge volume of material that i s handled. Approximately 20
percent of th.e material processed becomes wiping and polishing
cloths. Finally, 26 percent of this post-consumer waste i s
converted into fiber to b e used in products similar in nature to
those manufactured from pre-consumer textile waste.
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The current state of the post-consumer textile waste industry
is qyite perplexing. At a time of record demand the industry has
been downsize their operations as a result o f insufficient supply
o f raw product that i s recovered.
This is all the more curious
considering the relatively high value of post-consumer textile
waste as compared with the negative values often associated with
other, more thoroughly collected waste products, such a s newsprint.
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The firm of G 8 6 Solid Waste Management Consultants of Falls
Church, Virginia has prepared comparisons of recycling system
revenues and costs, both with and without post-consumer textile
waste, for the County of Anne Arundel, Maryland and for t h e town o f
Islip, New Y o r k . T h e findings indicate t h e recovery of postconsumer textile waste would not only reduce landfill deposits, but
would also significantly reduce the per-ton cost of both these
recycling programs. Furthermore, all indicators point t o continued
increases in the demand for post-consumer textile waste. Members
o f the textile recycling industry are currently working to double
the amount of post-consumer material that is being recovered.
While it is felt this i s a realistic long-term goal, much education
and assistance from federal, state, and local government will
determine this industry's ability to achieve this goal.
The goals of the Council for Textile Recycling are to increase
the amount of textile waste that can be recovered and at the same
time develop new uses, products and markets for products derived
from pre-consumer and post-consumer textile waste. Our alms are
identical with EPA's "overriding goals . . . to encourage the trends
toward ( 1 ) increased use of recycled materials in products and (2)
the increased recovery o f material for recycling."
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The success of this industry's effort at waste reduction and
recycling i s the result of the normal course of our business
activities. Industry members have not used environmental concerns
to market their products, but have marketed products that have
benefitted the environment long before this issue was popular,
fashionable, and profitable.
The textile products recycled today are mostly or entirely
recyclable, and in most cases they become are 100 percent recycled.
Regarding the question of "recyclable" claims, it is agreed
that programs should be undertaken by the Federa.1 Trade Commission
(FTC) and the Environmental Protection Agency (EPA) to prevent
marketers from creating a false impression as t o the recyclability
o f a product o r container.
It is understood that if recyclability
rates are labelled, the consumer will be able t o make a better
purchasing decision. However, these benefits may actually hold
little value if the labeling of exact national recovery rates
functions to diminish the consumer's interest t o recycle.
It is
our concern that anything other than high recyclable rates may
cause consumers t o reduce their recycling efforts. Recovery-rate
labeling may also create confusion where differences between
national and local recovery rates exist.
For example, an individual located in an area where clear
glass bottles are recovered at an 80 percent rate, may lose some of
his incentive to recycle when he reads that this material i s
recovered at a national rate of only 20 percent.
The converse can
occur when high national recovery rates result in frustrated
efforts t o recycle material for which little local demand exists.
While representatives of this industry desire a voice in
establishing a minimum recycling rate for textiles, it i s felt that
the foilowing type of qualified claim will have the most beneficial
effect o n recycling: "Garments of this type are recyclable. For
specific information contact your local recycling coordinator."
most critical t o our industry concern the questions o f whether
"recycled content" should include both pre-consumer and post
consumer materials and the actual definition of "recycle".
It is believed the proposed EPA definition of "recycled
materials" is correct and appropriate in including both pre-and
post-consumer materials. Nothing would be achieved by excluding
pre-consumer textile waste, since most o f this material is used in
stuffrng and padding applications while most recycled post-consumer
textile waste becomes secondhand clothing. These two materials
generally do not compete. Encouraging the recycling of postconsumer waste at the expense of pre-consumer waste would neither
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Our industry recycles most, but not a l l , of the pre-consumer
textlle and fiber waste generated in the United States.
In most
cases, wastes that are not recycled are in fact usable by-products
for which there are not adequate markets. This industry is
striving to utilize its unused processing capacity. It makes
little sense for the E P A to favor post-consumer textile waste
recycling when current markets for these fiber products are already
fully satisfied.
This industry recycles the cloth cutting waste
from apparel manufacturing to produce a fiber raw
material for padding and stuffing applications. While in
excess of 50,000 tons of this material is recycled
annually, probably an equal amount is deposited into
landfills due t o limited markets. Some post-consumer
waste is now used for this same purpose, but due to
economics, the majority of the material used in this
market area is pre-consumer.
EXAMPLE:
Any preference given to post-consumer material would not
increase the total amount of material recycled, nor would t h e
It is pointless t o
amount of material being dumped decrease.
attempt to set up artificial competition that cannot achieve any
worthwhile purpose and may in fact, hinder the total amount of
textile waste that our industry is able to recycle.
A second example related by an industry member demonstrates
how arbitrary manipulation of markets can be wasteful.
In order to
meet California's 10 percent post-consumer content requirement, a
buyer requested that used white sheets be included to produce a
low-value raw material for his process. These used white sheets,
typically in great demand as polishing cloths, have a much higher
value than the pre-consumer material they replaced. California's
requirements forced the manufacturer to waste a valuable postconsumer material that could have readily been sold.
At the same
time this requirement prevented the cheaper pre-consumer material
from being used, and it was ultimately dumped into a landfill.
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The proper action would be to call the reprocessing of both
pre and post-consumer textile waste "recycling" so that t h e
industry competes by developing new markets and products, not by
arguing over definitions. Any textile waste, whether new or o l d ,
that is not recycled goes into some landfill. All recycling needs
to be encouraged.
In spite of our longstanding success in the recycling of postconsumer textile waste, our industry is quite troubled by the
effect EPA'S definition of recycle" may have on this industry's
ability to continue and improve upon our efforts. Certainly our
work entails the "collection, separation, and processing, b y which
products or other materials are recovered from or otherwise
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diverted from the solid waste stream." However, while postconsumer textile waste is "in the form of raw materials rn the
manufacture of new products" of recycled fiber, polishing, and
wiping cloth, it might be argued that technically secondhand
clothing does not meet this criterion.
It is hoped that the waste industry accept this definition of
post-consumer textile waste as no longer clothlng, but in fact a
raw product, which is termed "mixed rags." From these raw mixed
r a g s , a new product--secondhand clothing--is created.
It is
important to nota that new and secondhand clothing differ markedly
in their respective sources, purposes, and markets. work in
producing secondhand clothing encompasses the spirit and the letter
of the recycling effort, avoiding by-products in a labor-intensive
industrial setting in the creation o f new and necessary products.
As stated previously, the textile recycling industry i s
undertaking efforts to encourage the recovery o f an additional one
million tons o f post-consumer textile waste. The focus o f this
recovery effort i s directed at the municipalities that are
currently dumping this valuable material into landfills.
If the
majority of: this work is not regarded as recycling, it may prove
very difficult to enlist the efforts of these municipalities t o
recover this textile waste, no matter how financially beneficial.
The central two questions of definition that have been brought
to your attention are of critical importance both to the continued
operation of a unique industry as it now exists and in determining
its future ability to reduce further the amount of waste being
deposited i n our nation's landfills.
Including both pre and postconsumer w a s t e in your proposed definition o f "recycled material"
and recognition that the recycling of mixed rags into secondhand
clothing is a valid form of recycling will be an important step in
reaching this mutually desired goal.
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