Don't Overlook Textiles!
Few people outside of the textile recycling industry realize that the Secondary Materials and Recycled Textiles (SMART) is the trade association representing one of the oldest and most established of the recycling industries. More than 1,000 businesses and organizations employing many tens of thousands of workers divert some 2,000,000 tons of textile waste from the solid waste stream. Millions of individuals benefit from the products, operations, and programs created by the recycling of textile waste.
As textile recyclers, all the issues being addressed concerning recycling, recyclability, source reduction, etc; have relevance to this diverse industry. It is hoped through education and the cooperation of government agencies that the consuming public will recognize the need and importance of recycling discarded apparel into secondhand clothing. Acceptance of these definitions as part of "recycling" will help encourage the maximum recycling of textile wastes and thus minimize the amount of material that goes into the waste stream.
Textile waste can be classified as either pre-consumer or post-consumer. Pre-consumer textile waste consists of by-product materials from the textile, fiber and cotton industries. Each year 750,000 tons of this waste is recycled into new raw materials for the automotive, furniture, mattress, coarse yarn, home furnishings, paper and other industries. Through the efforts of this industry approximately 75 percent of the pre-consumer textile waste that is generated is diverted from our landfills and recycled.
Post-consumer textile waste consists of any type of garments or household article, made of some manufactured textile, that the owner no longer needs and decides to discard. These articles are discarded either because they are worn out, damaged, outgrown, or have gone out of fashion. They are sometimes given to charities but more typically are disposed of into the trash and end up in municipal landfills.
The Fiber Economics Bureau reports that for 1989 the per capita consumption of manufactured cotton, wool, and other fibers was 67.9 pounds. Statistics collected by the Council for Textile Recycling indicate that on a national basis this industry recycles approximately 10 pounds per capita or 1,250,000 tons of post-consumer textile waste annually. However, these 10 pounds represent less than 25 percent of the total post-consumer textile waste that is generated. According to the EPA's 1988 study on the United States Generation of Solid Waste, textiles account for some 3.9 million tons of the solid waste stream. A number of waste composition studies indicate that this unrecovered textile waste accounts for approximately 4 percent of the content of our landfills.
Almost half (48 percent) of 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 earning $200 annually. Industry members are capable of delivering a pair of pants in clean, damage-free condition to the east coast of Africa for $.34 a pair and sweaters to Pakistan for $.12 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 is handled. Approximately 20 percent of the material processed becomes wiping and polishing cloths. Finally, 26 percent of this post-consumer waste is converted into fiber to be used in products similar in nature to those manufactured from pre-consumer textile waste.
The current state of the post-consumer textile waste industry is quite perplexing. At a time of record demand the industry has been downsize their operations as a result of insufficient supply of raw product that is 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 as newsprint.
The firm of GBB 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 the town of Islip, New York. The findings indicate the recovery of post-consumer 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 to continued increases in the demand for post-consumer textile waste. Members of the textile recycling industry are currently working to double the amount of post-consumer material that is being recovered. While it is felt this is 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 aims 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 of material for recycling."
The success of this industry's effort at waste reduction and recycling is 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 Federal Trade Commission (FTC) and the Environmental Protection Agency (EPA) to prevent marketers from creating a false impression as to the recyclability of a product or container. It is understood that if recyclability rates are labelled, the consumer will be able to 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 to recycle. It is our concern that anything other than high recyclable rates may cause consumers to 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 is recovered at a national rate of only 20 percent. The converse can occur when high national recovery rates result in frustrated efforts to 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 is felt that the following type of qualified claim will have the most beneficial effect on recycling: "Garments of this type are recyclable. For specific information contact your local recycling coordinator."
Of all the issues and definitions being addressed, the two most critical to our industry concern the questions of 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 of this material is used in stuffing and padding applications while most recycled post-consumer textile waste becomes secondhand clothing. These two materials generally do not compete. Encouraging the recycling of post-consumer waste at the expense of pre-consumer waste would neither result in additional materials being recycled nor reduce landfill deposits.
Our industry recycles most, but not all, of the pre-consumer textile 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 EPA to favor post-consumer textile waste recycling when current markets for these fiber products are already fully satisfied.
EXAMPLE: 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 to 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.
Any preference given to post-consumer material would not increase the total amount of material recycled, nor would the amount of material being dumped decrease. It is pointless to 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 post-consumer 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.
The proper action would be to call the reprocessing of both pre and post-consumer textile waste "recycling" so that the industry competes by developing new markets and products, not by arguing over definitions. Any textile waste, whether new or old, that is not recycled goes into some landfill. All recycling needs to be encouraged.
In spite of our longstanding success in the recycling of post-consumer 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, by which products or other materials are recovered from or otherwise diverted from the solid waste stream." However, while post-consumer textile waste is "in the form of raw materials in 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 clothing, but in fact a raw product, which is termed "mixed rags." From these raw mixed rags, a new product--secondhand clothing--is created. It is important to note 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 of new and necessary products.
As stated previously, the textile recycling industry is undertaking efforts to encourage the recovery of an additional one million tons of post-consumer textile waste. The focus of this recovery effort is 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 to 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 in our nation's landfills. Including both pre and post-consumer waste in your proposed definition of "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.