Uganda
SMART has obtained official documentation from the Ugandan government indicating that it intends to impose a licensing scheme on secondhand clothing imports (HTS 6309), with the stated goal of gradually phasing out and eventually banning these goods. A June 5, 2025 letter from the Ugandan Ministry of Trade, Industry and Co-operatives, followed by a June 16, 2025 communication from the Uganda Revenue Authority to all customs officials, confirms that import permits will be required immediately and explicitly states that the intent is to “gradually phase out importation of used/second clothing and apparels.”
This policy direction follows President Museveni’s 2023 remarks promoting new garment factories, many backed by Chinese foreign investment, and signals a clear and coordinated effort to prioritize domestic and foreign-owned apparel manufacturing at the direct expense of U.S. exports. SMART views this action as a direct violation of Uganda’s obligations under the African Growth and Opportunity Act (AGOA), which requires participating countries to maintain open markets for U.S. goods, including secondhand clothing. It also undermines the terms of the 2016 settlement negotiated with the United States that successfully reversed an earlier East African Community attempt to impose such a ban.
On June 20, 2025, SMART formally raised these concerns in a letter to USTR Jamieson Greer, urging the U.S. government to press Uganda to honor its AGOA commitments and maintain open market access for secondhand clothing. As outlined in that letter, any pursuit of a ban would not only harm U.S. exporters and the global textile reuse industry, but also reduce access to affordable clothing for millions of Ugandan consumers.
SMART strongly opposes Uganda’s actions and supports USTR engagement to hold Uganda accountable under AGOA. More broadly, SMART continues to advocate for recognition that textile reuse and recycling is a vital global industry that supports jobs, reduces waste, and provides affordable clothing to communities around the world.
Revisions to definition of reusable and waste textiles
The United Nations Environment Programme (UNEP), the leading global environmental authority within the UN system, is carrying out its One UNEP Textile Initiative, which coordinates the organization’s efforts to accelerate a just transition toward a sustainable and circular textile value chain. As part of this work, UNEP has launched the Circularity and Used Textile Trade Project, which is focused on developing global guidance to establish criteria that distinguish reusable textiles from waste. The aim is to clarify what products can move across borders as used textiles and what should be treated as waste—supporting legitimate reuse and recycling while reducing the risk of environmental harm from poorly managed exports. UNEP has been convening multi-stakeholder dialogues and workshops to inform this process. SMART has already provided feedback and will continue to engage to ensure that the expertise of the textile reuse and recycling industry is reflected in any final guidance.
At the same time, the Basel Convention, the primary international treaty governing the cross-border movement and disposal of hazardous and other wastes, has formally begun examining how to address textiles within its framework. At its April–May 2025 COP-17 meeting in Geneva, parties agreed to launch intersessional work on textile waste, a step that could eventually lead to new classifications and trade controls. Textiles were highlighted as a rapidly growing waste stream of global concern, particularly in developing countries. SMART is working to secure a more formal role in these discussions and is actively engaging key U.S. government agencies and allied European organizations to advocate for fair, practical approaches that recognize the value of reuse and recycling and preserve open markets for secondhand textiles worldwide.
El Salvador
SMART has been actively engaged on an emerging trade issue in El Salvador, where government authorities have recently misinterpreted the rules of origin as they apply to used clothing (HTS 6309). Instead of recognizing that secondhand clothing qualifies as U.S.-origin goods when collected and prepared here, El Salvador has taken the position that origin is tied to the country where the clothing was first manufactured. This interpretation has created barriers for U.S. exporters of used textiles, despite the clear intent of U.S. trade agreements to allow secondhand clothing to move freely as U.S. goods.
SMART has raised this concern directly with U.S. trade officials and is pressing for clarification to ensure El Salvador corrects this misinterpretation. We continue to advocate for recognition that secondhand clothing is a legitimate U.S. export, critical to both our domestic industry and to consumers in Central America who rely on access to affordable apparel.
AGOA (African Growth and Opportunity Act)
exporters of secondhand clothing and other reclaimed textiles, products that consistently rank among the top U.S. textile and apparel exports by volume. AGOA has been instrumental in ensuring fair and reciprocal trade for our industry.
When East African Community countries previously attempted to ban imports of secondhand clothing in 2016, SMART, working with the U.S. government, helped secure a reversal under AGOA. The agreement has served as both a deterrent against unfair trade practices and a reminder that access to the U.S. market is contingent upon fair treatment of U.S. goods. Without renewal at the end of September, this critical accountability mechanism would lapse, leaving U.S. exporters vulnerable to renewed restrictions. For these reasons, SMART urges swift reauthorization of AGOA to preserve open markets, support American jobs, and strengthen U.S. trade leadership in Africa.
