Closing The Gap: Why Textiles Are The Missing Piece

South Africa's extended producer responsibility ("EPR") framework already covers paper, packaging, certain single-use products, batteries and electrical and electronic equipment. Yet textiles remain outside the net.

At present, garments attract EPR obligations only in respect of their packaging; the clothing itself is unregulated, meaning fast-fashion volumes, originating outside South Africa, spill into second-hand markets and what does not sell ends up in landfill with no producer funded mechanism to finance collection, sorting or recycling.

The scale of the issue is significant. In 2022, approximately 1.1 million tonnes of waste were disposed of in South African landfills, including 70 300 tonnes of textiles. By comparison, plastics accounted for just under 200 000 tonnes. These figures also exclude private landfill volumes. Only about 13% of textiles are recycled and less than 1% is recycled back into clothing, highlighting a largely linear system.

Cape Town illustrates the urgency. More than 70 000 tonnes of textile-related waste are available for beneficiation in the city alone. Meanwhile, the City of Cape Town’s Waste Strategy warns that Coastal Park Landfill could reach capacity by 2027 if diversion efforts do not improve. Bringing textiles into the EPR framework is no longer optional, it is necessary.

A gap South Africa does not face alone

Internationally, textiles are increasingly being addressed through EPR systems. France introduced the first mandatory textile EPR scheme in 2007 through Refashion (formerly Eco-TLC), funding collection and recycling through eco-modulated fees.

The Netherlands has operated a voluntary textile collection covenant since 2012 and is now moving towards mandatory EPR under the revised EU Waste Framework Directive (Directive (EU) 2025/1892), which requires all Member States to establish mandatory textile EPR schemes by April 2028. In the United Kingdom, the Waste and Resources Action Programme (“WRAP”) Textiles 2030 Voluntary Agreement has brought together major brands to reduce the environmental footprint of clothing.

These policy tools clearly exist. What South Africa requires is a textile EPR notice that:

• brings apparel and home textiles into scope,
• sets realistic collection and recycling targets, and
• assigns clear EPR responsibility across the value chain.

Fast fashion, second-hand markets and cross-border e-commerce

The fast-fashion-to-charity-shop pipeline is now a defining feature of the local market. Low-cost garments are purchased online, worn briefly for a season and donated, often overwhelming charity shops with low-quality clothing that cannot be resold and ultimately ends up in landfill at the municipality's cost.

Cross-border e-commerce compounds this problem. Platforms such as Shein and Temu distribute goods via third-party logistics providers, historically utilising low-value parcel thresholds to minimise duties. SARS has now tightened the rules: VAT applies to clothing imported via e-commerce from 1 September 2024 and full customs duties of approximately 45 per cent from 1 November 2024. Yet the EPR gap remains.

Transport documentation often lists the courier or the consumer as the importer, leaving these platforms outside the regulatory net. Under the existing EPR framework, the "producer" definition covers any person who manufactures, imports or distributes a product in South Africa, so a platform placing goods on the South African market should in principle qualify. In practice, these platforms argue that the courier is the importer of record and that the platform has no local presence.

A textile EPR scheme should close this gap by assigning liability upstream:

• first to the local brand owners,
• then to the courier as importer of record (noting that an importer must have a registered business in South Africa, where it does not, the retailer or individual who places the product on the market is deemed the producer), and
• Ultimately to the online marketplace as backstop.

Compliance could be enforced by linking EPR registration to customs clearance and platform listings.

A clear path forward

1. South Africa already has the legislative foundation under the National Environmental Management: Waste Act 59 of 2008. The missing piece is clear: textiles.
2. Bringing them into scope would not only align South Africa with global regulatory trends but also unlock investment in collection, sorting, and recycling infrastructure.
3. Textiles are the missing piece in South Africa’s EPR framework - it is time to bring them in.

GreenCape and WRAP, with support from the Anglo American Foundation, have already taken concrete steps towards a voluntary circular textiles initiative, and have published a Potential Pathways and Value Proposition paper dated May 2026. The critical question, is whether a voluntary system will be enough to move the problematic linear system to a circular system, in time.

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