Who are we?

Research and advocacy interns dedicated to improving textile waste management in California. 

Letter writing was led by Justin Roeske, senior in Fashion Merchandising and Management, and Asha Birdi, senior in Environmental Sciences. The work was supervised by Emily Oertling, PhD, at CSU, Sacramento.

Why is the time to act now? 

On July 17th, 2025, CalRecycle will host its first public meeting on textile stewardship.

From CalReycle: The purpose of this workshop is to introduce the Responsible Textile Recovery Act of 2024 (SB 707, Newman, Chapter 864, Statutes of 2024), producer responsibility organization requirements, and California’s rulemaking process. 

This is an opportunity for citizens to provide commentary early in the implementation and regulation process for the Responsible Textile Recovery Act. 

What's our goal? 

To tell CalRecycle to implement appropriate waste hierarchies, standards for reuse and repair, and viable and accessible textile recovery solutions.

What's at stake? 

We've spent the summer reading, analyzing, and studying the Responsible Textile Recovery Act and other Extended Producer Responsibility laws that exist globally. Evidence indicates that these laws, without proper regulations, will not support people or the planet. The law, as it is, creates opportunities for companies to self-evaluate, self-manage, and self-fund. To have real, sustainable solutions, CalRecycle must have effective and transparent implementation strategies. 

What am I signing? 

To read our letter with full citations visit: Letter to CalRecycle

Additionally, our letter with in-text citations can be read here:

_______________________________________________________________

Dear CalRecycle,

In Fall 2024, SB707, the Responsible Textiles Recovery Act (RTRA), was passed. Producers are scheduled to join or form a Producer Responsibility Organization (PRO) starting next year. In this letter, we discuss our concerns and make suggestions regarding the implementation of the reuse, repair, and recycling schemes (Section 42984.1). We invite you to consider these recommendations as you implement and regulate the Responsible Textile Recovery Act. This letter addresses: 

• Issues with CalRecycle’s waste hierarchy and the need to deprioritize recycling to meet zero-waste goals
• The implementation of standards for textile and garment reuse and repair to stop waste colonialism  
• Supporting socially, environmentally, and economically viable sustainable textile recovery solutions
• Ensuring accessibility and equity in the implementation of the RTRA

Issues with Waste Hierarchies: Deprioritizing Recycling 

Textile recycling is not the answer.

The most common form of textile recycling is mechanical recycling (MR) (Undas, et al., 2023). While MR ideally recycles natural fibers efficiently, the sorting process hinders the entire system. Manual sorting is still widely used, which is “time-consuming and cannot ensure qualitative reorganization of fiber origin”. The unknown and blended contents of many textiles hinder the system, as natural and synthetic fibers react differently to MR (Nemeša, et al., 2024). In textiles specifically, Geyer et al. found no significant recycling rates and suggest that they are incinerated or discarded with other municipal solid waste. An alternative to mechanical recycling is advanced recycling (AR); however, this process also has numerous issues that make it a less-than-ideal solution. AR uses extreme heat to process plastics, including synthetic fibers. When heated, the amines, dyes, and metals used in textiles create harmful byproducts. These end products have little to no value (Geyer, et al., 2017).

Additionally, in MR and AR, synthetic textiles release microplastics and continue to release them at a high rate once incorporated into new fibers. Laborers working in the shredding process are exposed to high levels of microplastics; this increased inhalation risk can lead to the accumulation of plastics in various organs (Manivannan et al., 2025). Managing blended fabrics, such as cotton/polyester, also yields alarming outcomes. Manivannan et al. have demonstrated that the chemical recycling of these blended fabrics releases microplastic fibers (MPFs) at every stage of the process, with dye removal and acid hydrolysis releasing up to 23,000 MPFs per gram. Fiber particles often become surface-modified, making them more likely to absorb toxins and persist in ecosystems (Undas et al., 2023; Weiss et al., 2023).  

Textile composition is a significant driver of pollution, even during the recycling process. While recycled plastic fibers, such as polyester, appear to be a solution, it’s ultimately a hazardous way for brands to avoid adopting truly sustainable practices. Using recycling as an indicator for circularity allows brands to inflate their sustainability claims while continuing to contribute to the ecological crisis. For these reasons, we suggest you deprioritize and de-incentivize recycling as a strategy for RTRA PRO members. Further, funding from the PRO cannot be allocated to MR or AR industries whose work has failed to scale to meet the rates of disposal and has not contributed to zero waste or circular goals. 

Standards for Reuse and Repair

Our waste, our problem.  

A circular fashion system must effectively and ethically prioritize reuse and repair.  As part of the regulatory process to implement the RTRA, we urge CalRecycle to adopt clear, enforceable regulations for the reuse, repair, and recycling sectors that fully reflect the legislation’s intent to reduce textile waste and shift end-of-life responsibility onto producers. See: 

The intent of this chapter is to establish a statewide extended producer responsibility program for apparel and textile articles that emphasizes repair and reuse, and minimizes generation of hazardous waste, generation of greenhouse gases, environmental impacts, environmental justice impacts, and public health impacts.
— California Public Resources Code, Section 42984.05(a)

Without precise guidance, there is a significant risk that producers will meet only the minimum requirements through superficial action that fails to reduce environmental harm or waste generation. Research from the Ellen MacArthur Foundation reveals that fast fashion companies frequently exploit vague “reuse” claims to justify overproduction, thereby flooding resale markets with low-quality garments that are quickly discarded. To prevent this, CalRecycle must establish and enforce high standards for what qualifies as reusable, whether through repair, refurbishment, or direct resale. Garments should be eligible for reuse only if they meet regulated criteria for quality, durability, and cleanliness.

Maintenance is among the most effective ways to retain the value of materials and reduce carbon impacts (Stahel, 2016). Similar to reuse, and to ensure repair businesses are not overburdened by textile waste, there needs to be strong standards for what garments can enter repair programs. Efforts must be made to address the source of the problem: garments aren’t designed to be repaired or to last. They’re designed to become trash.

Reuse and repair are valuable strategies, but they run the risk of becoming a loophole for waste disposal. Discarded low-quality garments and textiles, which account for the majority of what is produced by the fashion industry today, are exported from the United States to developing countries. The forced exportation of our clothing and textile waste into these communities is waste colonization. In the past 15 years, countries like Kenya, Uganda, and Tanzania have been threatened by the U.S. that their duty-free export privileges would be revoked when they attempted to raise the import duties on U.S. consumers' unusable clothing (SMART, 2017). This trash, designated as a consumer good, is a global problem because the U.S. refuses to have standards, is unable to manage its waste effectively, and regularly leans into trade organizations that claim financial hardships (Brooks, 2015). 

Californians, residents of the 5th largest global economy, do not want to be waste colonizers. For these reasons, we recommend that CalRecycle establish strict standards for reuse and repair and implement adequate management of the RTRA infrastructure to ensure our communities thrive without compromising the vitality of others. 

Supporting Viable Solutions

Effective implementation strategies that can benefit both people and the planet.  

Repair-focused solutions can yield environmentally, socially, and economically beneficial outcomes. However, “repair” must go beyond intention and reflect tangible services that are financially accessible to citizen-consumers. These services must also be provided by individuals who are participating in a dignified work environment. Current circular economy (CE) education programs often overlook this need. Most CE courses emphasize product design and remanufacturing, while neglecting practical and service-based skills needed to support a functioning repair program (Hoffman Trevisan et al., 2025). These gaps highlight the need for targeted investment in people-centered training programs that focus on sorting, alterations, and tailoring, and enable repair at the scale necessary for implementing the RTRA.

The lack of commercial repair services is an issue. However, there are examples of good in our great state that could thrive with continued investment. One example is SUAY, a LA-based sewing and production shop that offers community-forward repair services. Since 2017, SUAY has championed responsible textile recovery and, in doing so, diverted 3.5 million pounds of textiles from landfills (SUAYLa, 2025). This company is a clear example of how investment grants can be effective. The California Climate Investments evaluated the company’s use of the Recycled Fiber, Plastic, and Glass Grant Program in 2022, stating:  

SUAY has diverted more than 382 tons of textiles from landfills, and their positive environmental impact continues to grow year-by-year. The expansion activities [funded] by this grant are expected to divert 1,500 tons of textiles from landfills and reduce greenhouse gas emissions by 3,750 MTCO2e (CCI, 2022). 

Their model, unlike mechanical and advanced recycling, has seen success. By providing funding to community-focused companies that demonstrate textile recovery and prioritize workers’ well-being, CalRecycle can foster regional textile economies and contribute to achieving the RTRA’s goal of reducing textile waste, as outlined in Section 42984.1 of the CPRC. For these reasons, we urge CalRecycle to carefully consider how the implementation of the RTRA and funding from the PRO can foster outcomes that allow people and the planet to thrive. 

Accessibility

Our communities must have access to solutions.

For the RTRA to be successful, citizen-consumer behavior must also be taken into consideration. It is essential to have transparency and accountability throughout the recovery process. The public must have clear information about the location of collection sites, the number of sites in operation, and what happens to items after they are sorted. If citizen-consumers remain unaware of the RTRA or perceive alterations and clothing repairs to be expensive the program will have limited success (Potdar et al., 2023). New operations must be financially and geographically accessible to people of all socioeconomic backgrounds to ensure widespread participation, thereby advancing the RTRA’s goals of environmental justice and waste reduction. For these reasons, CalRecycle must take steps to ensure the schemes supported by the RTRA are available and effectively communicated to the public. 

We hope that our suggestions provide actionable strategies and stimulate thoughts that will enable the RTRA to drive meaningful environmental outcomes, supporting the citizens of California and beyond. By deprioritizing recycling, setting clearer reuse standards, strengthening repair infrastructure, and ensuring access for all, CalRecycle can prevent the RTRA from greenwashing our people and deliver real positive impacts.

Thank you for your attention to this matter.