Strengthening approach to household recycling collection services: consultation analysis

2. Household Collection of Textiles

Chapter 2 analyses respondents’ views on whether to make kerbside collection of textiles a mandatory service by local authorities. The consultation paper notes that no local authority in Scotland currently accepts textiles for household kerbside recycling collection. Residents around Scotland currently use recycling centres, third sector recycling banks, donations to charity and reuse shops or resale websites, among others, to dispose of unwanted household textiles. Textiles that are hard to recycle are put into landfill, which, according to the consultation paper, “are a major source of waste sector emissions”.

This section asked respondents to provide views on 11 questions in open and closed formats. Respondents were asked about their current and future textile recycling options and preferences, and any potential benefits and barriers related to proposed changes to the current system. This chapter also includes respondents’ suggestions for alternative approaches.

Overall responses were split as to whether current options for textile recycling are efficient. Among those answering, 42% believe they are efficient and 44% believe they are not, while 13% were unsure. Organisations were more likely than individuals to feel that current options are efficient (50% compared to 35% respectively), whereas individuals were more likely to think current options were inefficient (54% compared to 35% of organisations). Local authorities and waste management organisations were more likely to describe current measures as efficient (64% and 67%, respectively), whereas reuse and resale organisations were more likely to feel they were not efficient (71%).

Again, among those answering Q1b, views were mostly split: 50% believed that current options for textile recycling are accessible, 42% felt they were not, and 8% were unsure. Organisations were more likely than individuals to consider the current options as accessible (62% compared to 38%, respectively). All respondents from waste management organisations believed that current options are accessible, as did 71% of local authorities, compared to 29% of reuse and resale organisations.

Q1c. If you do not consider your current options for textile recycling to be efficient and/or accessible, what improvements would you recommend?

More textile banks

Two thirds of respondents suggested improvements at the open question; this included respondents who felt that existing options were either efficient or accessible at the closed questions but still felt they could be improved.

Several respondents felt that providing more textile banks or drop-off locations to communities could improve textile recycling uptake by making it more efficient and accessible for people. A few individuals mentioned that they felt clothing banks were inaccessible as they were difficult to travel to. One individual suggested putting textile banks in highly accessible areas, such as community centre car parks.

“Increase collection options: Expanding collection points and providing more drop-off locations for householders can significantly enhance accessibility. This includes considering kerbside collection to make recycling more convenient.” – NHS Scotland

Respondents frequently commented that existing textile banks were not well maintained. Some complained that the banks were regularly overfilled, which made adding further donations more difficult or impossible. There was also a recommendation that banks or community bins be kept in better condition to ensure that the textiles meant for recycling are protected from bad weather, for example.

Public awareness campaigns

Some respondents felt that the public needed more information about the quality and types of items that are recyclable, where they can be taken and what happens to those items when they are recycled. Scotland Excel suggested that this could be done through a government campaign, and NHS Scotland suggested that the fashion industry participate by informing their customers about reuse and recycling options.

A few respondents noted their concern with the possibility of contaminated textiles being left at textile banks, which may impact the onward recycling of textiles in banks.

Extended Producer Responsibility (EPR)

Placing the responsibility on producers and manufacturers to create accessible, efficient and sustainable methods of recycling and reuse for textiles used in their products was mentioned by some respondents across local authorities, reuse and resale organisations, an environmental nonprofit and an individual.

“LARAC would like to see a UK-wide Extended Producer Responsibility (EPR) scheme introduced for textiles, similar to what has been brought in for packaging, to drive the industry in designing more recyclable products and investing in infrastructure for accepting, processing and recycling these items.” - LARAC

“The most useful system would start with the producers, who should be ensuring that only high-quality, repairable and recyclable items are put into the market. They are best placed to then run a take back service, ensuring that materials are returned to their point of sale/production and treated appropriately.” - Orkney Islands Council

ApparelXchange CIC (Community Interest Company) suggested using a mandatory postal take-back scheme, and Comhairle Nan Eilean Siar, among others, noted that the EU is introducing mandatory textile EPR schemes.

Kerbside collection

Some respondents supported kerbside collection to improve accessibility. Of these, almost half did not provide further details as to why they supported kerbside collection. Among those who did, two individuals suggested combining textile collection with another type of bulky waste collection for efficiency.

Collaboration

Greater collaboration between key stakeholders, including local authorities, the third sector and central government, was recommended by some respondents. Suggestions for collaboration included collection bags and recycling services being provided by charities, and local authorities providing transport and promoting clothes donations within their communities. Two local authorities highlighted that charities in their area planned to stop collections from textile donation banks. While this was seen as potentially detrimental, it was also suggested that it could lead to greater collaboration or the use of existing charity shop recycling and reuse by the local authorities.

The Salvation Army Trading Company Ltd and the Charity Retail Association suggested local authorities do more to support charity shops, such as providing people in their areas with bookable collection services. They also felt that the current policy disadvantaged charity shops, as waste management services were paid to handle textiles that are not appropriate for reuse, whereas charity shops did it for free. A few other respondents expressed the view that charity shops needed more support in managing donated clothing that is not reusable

Satisfaction with existing processes

Some respondents, predominantly organisations, suggested that the current systems for textile recycling were working effectively. These respondents felt there are several options available to people looking to recycle their textiles, from charity shops to resale websites, and it was unnecessary to change the existing system.

“The current system includes various options. Members of the public can take unwanted textiles to charity shops, drop off at textile banks at locations such as supermarket carparks and via direct, ad-hoc charity collections from households (via bags posted through the door that are later collected). There are also online options such as resell and local share sites. In addition, local authorities will generally offer the opportunity to dispense at household waste recycling centres.” – Scotland Excel

Lesser mentioned themes

The following themes were mentioned by a small number of respondents:

• Calls for greater investment, including funding for advanced sorting technologies or chemical methods for recycling textiles.
• Focus instead on reducing and reusing textiles, as a few respondents felt that reducing the need for recycling would be the best option.
• Enforcing legislation to ensure that people are not stealing donated textiles from community textile banks or illegally soliciting them from residents.

Of those answering, 61% agreed that household collection of textiles would benefit householders, 22% did not, and 17% were unsure. Individuals were more likely than organisations to see benefits in household collection (69% compared to 54%). Waste management organisations all agreed that households would benefit, as did 67% of public bodies, compared to 43% of local authorities and reuse and resale organisations.

Q3. What potential benefits do you consider household collection of textiles would provide to householders?

Increased participation

Three quarters of respondents answered Q3. Of those, the most common benefit, highlighted by many respondents, was that household participation in textile recycling could increase. Respondents felt that people would be less inclined to put textiles into landfill waste, as no travel would be required to recycle textiles, and it would be more accessible for people who were unable to get to charity shops or other donation centres.

“Kerbside collection simplifies the recycling process for residents, likely increasing participation and reducing textile waste to landfill/incineration.” – Stirling Council

A few respondents felt it could positively change people’s perspectives on recycling, encouraging those who may not otherwise have recycled.

Positive environmental impact

Some respondents expressed a view that household collection of textiles could positively impact the environment by reducing textiles being sent to landfill. A few respondents provided further explanation as to why they believe this, including that it could:

• decrease greenhouse gas emissions by removing textiles from residual waste.
• remove those textiles comprised of polymers from incineration.
• decrease the carbon emissions from those who drive to recycling centres.

“Most textiles now are fossil fuel based (polymer) so we need a better option than burning for energy as the Energy Trading Scheme will come in force too. Which is a good thing we must move away from fossil fuel and find way to reuse what resource we already have in circulation.” - Individual

Negative impacts

Although not directly answering the question, many respondents raised concerns or highlighted potential negative impacts of household collection at this question. As Q9 asks respondents to consider barriers and unintended consequences, negative impacts listed at Q2 have been included in the analysis of responses to Q9.

Respondents were more likely to disagree that household collection of textiles should be a service supplied by local authorities, with 53% of those answering disagreeing or strongly disagreeing (22% and 31% respectively). In contrast, 37% of those answering agreed or strongly agreed (17% and 20%, respectively). While individuals were more likely to agree (62% in total), organisations were more likely to be unsure or disagree (11% were unsure, 29% disagreed, and 46% disagreed strongly). All organisations that answered either disagreed or were unsure, except two local authorities, one public body and one environmental nonprofit.

Concerns with the proposal

Just over three fifths of respondents expanded upon their quantitative responses at Q4. Many respondents did not believe that household collection should be a service supplied by the local authorities, expressing a range of reasons for this view. These concerns were also raised at Q2, which asked about the benefits of household collection, and at Q9, where the barriers and unintended consequences of household collection are explored. Concerns raised at Q4 by some respondents included the negative impact that household recycling may have on charity shops and resale markets, and the increased costs that may be incurred by local authorities. These are described in greater detail at Q9.

Agreement with the proposal

At the open question, some who agreed with the proposal at the quantitative question provided caveats to their agreements or highlighted concerns in their detailed responses, as listed above and described in more detail at Q9. Two respondents simply agreed with the proposal, but did not provide further details why.

Unnecessary

A few respondents felt that household collection would complicate currently functioning systems. These respondents felt the current options – collection banks, charity shops, third sector collections, recycling centres and resale websites – were working well. Aberdeenshire Council felt that the collection of textiles by service providers and collection points allowed textiles to be recycled without local authority input.

“This collection service means no bulking of textiles by a local authority which runs the risk of material getting wet/dirty at waste transfer stations due to the many streams of waste that the local authority has to collect and bulk. In the instance of textile collections, where the material stream has to be kept dry and clean, there is less risk of contamination and downgrading of the material stream by keeping this a service provided by the textile trade and not involving the local authorities.” Aberdeenshire Council

Other suggestions

As mentioned in Q1, some respondents suggested legislating for an Extended Producer Responsibility scheme rather than creating new processes for household textile collection provided by local authorities. Respondents felt this would help ensure producers consider the composition of textiles and how their products can be reused.

A few respondents suggested that greater modelling would be needed to assess the costs and implications of introducing a mandatory household collection service.

Respondents supported the proposal that all local authorities should be required to offer textile recycling through Household Waste Recycling Centres or other bring facilities. Among those answering, 83% were in favour, 9% were against, and 8% unsure. Individuals and organisations were both supportive, with 88% and 78%, respectively, in favour. Support was higher among local authorities (86%) and reuse and resale organisations (83%), compared to 50% among waste management organisations and public bodies who answered.

Agreement with the proposal

Just over half of respondents left an open comment at Q5. Of those responding, several agreed with the approach of local authorities offering textile recycling through Household Waste Recycling Centres (HWRCs) or other bring facilities, including many local authorities. While some respondents did not expand on why they agreed, others felt that textile recycling at HWRCS was already common practice in many places and should be standardised across Scotland.

Considerations for implementation

Some respondents who agreed with this approach provided other considerations and caveats. A few felt that local authorities should provide the service through HWRCs or similar facilities, but advocated for public awareness campaigns or coordinated strategies between local authorities and the third sector or resale shops, which focused on promoting the reuse of textiles before they are recycled. Two respondents asked for more transparency on how textiles given to recycling centres are processed.

“Yes, but the focus should be on reuse first and recycling second. To promote reuse, local authorities should be encouraged to partner with charities that are able to offer a resale route within the UK for re-wearable clothing.” - Salvation Army Trading Company Ltd

Consideration of the charity and resale sector

Some respondents supported this approach as they felt it would maintain a source of reusable textiles for charity shops and circular economy enterprises compared to kerbside collection. Conversely, a few others raised concerns that people may overuse the recycling centres to the detriment of reuse shops. As noted above, they suggested that a preference for reuse be made clear to people to ensure good-quality textiles are not unnecessarily recycled.

Costs for local authorities

A few respondents felt that offering textile recycling through HWRCs was preferable to kerbside collection as it would be less costly or resource-intensive for local authorities. However, ApparelXchange CIC noted that this approach could be beneficial if local authorities could partner with resale or charitable organisations to service the textile collection areas of HWRCs.

In contrast, Orkney Islands Council raised an issue with the costs associated with onward recycling facilities due to low demand and physical distance from processing plants.

“The provision of containers also presupposes access to onward reprocessing facilities, which would be challenging for a small rural area like Orkney, given both the relatively low volumes of material that are likely to be collected and the distance from the reprocessing markets. Without an EPR scheme, the costs of this would be unaffordable.” – Orkney Islands Council

Accessibility concerns

Access to HWRCs was a concern raised by a few respondents due to either remote location or physical difficulty in accessing the centres.

“Our local recycling centre is 60 miles and a ferry journey away (Shetland and this applies to several thousand residents). People would be reluctant to take their textiles there. As well as local charity shops, there are options on the islands to deposit textiles in textile banks.” - Yell for Cancer Support Charity Shop

A few others felt that local authorities should decide on statutory services as they are best placed to understand what is feasible and economically viable in their areas.

Three quarters of respondents answered Q6. Of those answering, respondents most commonly recycle between 6 and 30 textile items a year, with 22% recycling between 6 and 15 pieces and 24% recycling between 16 and 30. Individuals mostly recycled between 1 and 30 items annually, although 8% did not recycle, 8% recycled over 50, 8% recycled between 31 and 50, and 4% were unsure how many textiles they recycled annually.

Certain organisations were more likely to be unsure about their annual textile recycling, with 67% of waste management organisations and 50% of public bodies saying they did not know.

Q7 provided respondents with a list of services and asked them to select all the services that were currently available in their local authority area. The multiple-choice nature of this question means the table above is based on all respondents.

Among all respondents, 78% have access to charity shops that accept in-store donations, 75% can access local textile banks in supermarkets or car parks, 63% have access to household waste recycling centres, and 43% are offered household collection services for charity shops.

Individuals were more likely to have access to in-shop charity donations (92%) than to a charity shop’s household collection service (31%), and 85% had access to textile banks. Fewer respondents had Household Waste Recycling Centres available in their area (65%).

Organisations had relatively equal access to all the services asked about, with 68% having access to textile banks, 68% having access to in-store charity shops, 62% having household waste recycling centres in their local authorities, and 53% having access to charity shop household collection services.

Q8 provided respondents with the same range of services and asked which they currently use in their local authority area. The multiple-choice nature of this question means the table above is based on all respondents.

Among all respondents, more than half use in-shop charity store donations (52%), and just over a third (37%) use textile banks. Recycling centres (25%) and a charity shop household collection service (10%) are less used. A quarter of respondents (25%) noted they used another service, with details provided in the open responses (see below). Individuals were more likely than organisations to use all services, although organisations were slightly more likely to use other forms of recycling, with in-store donations to charity shops being particularly common among individuals (85%).

Other services

Three in ten respondents left an open comment at Q8. Alongside the services already asked about in the closed element of Q8, respondents provided further details about how they recycle or dispose of their textiles. These included, from most to least prevalent:

• Other community-benefitting options, such as wardrobe libraries e.g. Revolving Wardrobe. One individual mentioned using their community textile banks to raise money for the local community, but did not explain how.
• Resale websites, such as Gumtree, Facebook Marketplace, eBay, or Vinted, or websites to distribute free things, like Freecycle.
• Personal reuse, such as repurposing textiles, passing along to family or friends or passing along to local crafting clubs.
• General waste for items that cannot be donated.
• Personal compost bin.

Among those answering, almost all (92%) anticipated barriers or unintended consequences to the proposal, 6% believed there would be none, and 2% were unsure. All organisations responding believed there would be unintended consequences, compared to 85% of individuals.

Just under 9 in 10 respondents left an open comment in response to Q9. Many respondents had already raised potential barriers and negative impacts in response to other questions in this section of the consultation, particularly at Q2 and Q4. To minimise repetition, the analysis below includes comments from other questions reflecting unintended consequences. Where themes were unique to other questions, it has been noted in the analysis.

Increased costs

Many respondents, including most of the local authorities and public bodies responding to the consultation, highlighted potential increased costs to the local authority as an unintended consequence or barrier associated with kerbside collection becoming a statutory service. Respondents highlighted that any new scheme would likely require new bins for households, increased manpower and collection vehicles, and increased organisational and management resources. Respondents expressed the view that local authorities are currently under financial stress and were concerned that a new service could be unaffordable or lead to reductions in other services.

“The high cost of collection of textiles for dispersed populations across the Highland Council area, would be unlikely to yield an economy of scale that would justify the investment in time and infrastructure. In addition, there are significant live issues with the secondary textiles market, which would produce issues for Councils to access, procure and to maintain stable affordable offtake arrangements.” – The Highland Council

Impact on charity and reuse shops

Reiteration of the concern about the impact of textile recycling changes on the charity and reuse sector was mentioned by many respondents at Q9 and throughout the questions in this section. Respondents felt that a kerbside textile collection could decrease the amount of textiles donated to shops, as reusable textiles may be put in a household recycling bin if it is seen as easier than taking them to a charity shop or donation bank. It was noted that this could decrease the income of these shops and may also impact people who depend on charity shops to buy good quality second-hand clothing and home goods.

“It will deprive local charities of much-needed donations. Charities are already struggling to provide a sticking plaster for inadequately provided Government services, and many people are living in poverty.” – Individual

“We believe there is ample opportunity for residents to re-use and recycle textiles through textile banks, charity shops, market place and other online platforms to sell old items keeping them in direct use and extending the life of them. [Local Authorities] do not have the ability to sort and sell, so this may result in good quality items being sent for recycling as opposed to re-use, which should be the preferred option given it's position in the waste hierarchy.” – Moray Council

Others felt this issue could also present challenges for nonprofit and community projects created to promote the circular economy through textile resales. Again, respondents thought this would impact not only the income of these third-sector organisations but also the communities they support and the people who use the resale services.

Quality of textiles being recycled

Some respondents mentioned concerns that household collection could result in higher-quality textiles being mixed with unusable textiles, making them unsuitable for recycling or reuse. They felt households may stop separating their textiles due to the ease of using a kerbside bin, which would create greater textile waste. Some raised a concern that this would lead to a perspective shift, where people habitually stopped donating or looking into reuse options for their textiles.

“Kerbside collection increases the risk that higher quality textiles will be disposed of at kerbside due to increased convenience, [which] may see it mixed with poorer quality material, reducing the likelihood that the higher quality material could be recycled. It may also reduce these items being sent for reuse or repair. Additionally, charities and organisations currently in receipt of these types of items risk seeing a drop in donations and, as such, income.” – LARAC

Some respondents advocated for clear communication about what can be recycled, where textiles end up, and promotion of options associated with the circular economy, such as resale and reuse organisations, as a way to combat potential misuse of kerbside bins. A few respondents also felt that standardising practices across local authorities would help clarify the aims and goals of any new statutory services.

“Consideration should be given to the type and quality of textiles residents will be advised to deposit in kerbside collections, and a clear message on the purpose of kerbside collections being recycling. This could be an opportunity to engage with residents around repair and reuse, extending the life of textiles, and other options to consider before recycling. This could also help decrease adverse impacts for third sector/charities and ensure textiles are kept in use at their highest value and higher up the waste hierarchy, before reaching the recycling point.” – Glasgow City Council

Space concerns

Throughout the consultation, some respondents raised concerns about the space households would need to store another bin. This concern was not only for the individuals housing the bins but also for the fact that too many bins on a street could impede accessibility for pedestrians, people who need accessibility tools and vehicles, and families with prams. One individual mentioned concern that if bags were used rather than bins, they could be stolen.

Other concerns and barriers

Small numbers of respondents raised lesser-mentioned concerns and barriers. These included the potential for limited uptake, as a few respondents felt a household collection service was unnecessary, and concerns that increases in consumerism could be driven by the increased ease of disposal of unwanted textiles.

At Q2, a small number of respondents highlighted that a lack of infrastructure to manage recycling could negatively impact the rollout of recycling plans and proposals. They suggested that household collection should not be offered until there are mechanisms for sorting and processing the collections to enable effective recycling once collected.

At Q10, 59% of respondents who answered indicated that they were likely to use a household collection service offered by local authorities, with 41% very likely and 18% somewhat likely to do so. Given the focus on household collection, twice as many individuals answered the question as organisations. Almost three quarters of individuals (73%) indicated they were likely to use the service (50% very likely and 23% somewhat likely). In contrast, 23% of individuals were unlikely (4% somewhat unlikely and 19% very unlikely), and 4% were unsure.

Q11. Do you have any additional views, regarding household collection of textiles or what you would expect a useful service to look like?

Public education and clear communication

Just under two thirds of respondents provided additional views at Q11. Of those, the most common theme, mentioned by some respondents, was a suggestion that clear communication from local authorities or the Scottish Government would be needed to educate people about any new recycling procedures and the best ways to dispose of unwanted textiles. A few respondents also suggested that more information about the negative impacts of fast fashion could be helpful.

“A successful kerbside textile collection service should include clear guidelines for residents on what textiles are acceptable, regular collection schedules to encourage consistent participation, public education campaigns, collaboration with charities and other recycling organisations.” – Stirling Council

Increased investment in circular economy

Promotion and support for reuse and repair options for textiles was called for by some respondents. Suggestions included further promotion through education and communications as mentioned above, but also by using existing infrastructures. LARAC, for example, suggested that HWRCs could be used to support textile repair and reuse programmes. ApparelXchange CIC suggested that this be built in partnership with local authorities.

“If there is a responsibility for a local authority to provide this type of service, they really must consider how this is done in partnership, contracted out to local organisations. The potential social and environmental impact of a service by a responsible social circular enterprise would reap huge rewards for any local authority, driving circularity, net zero, social impacts and utilising resources which benefit our communities. I also think local authorities as large as Glasgow, working with others, should be advancing the opportunity towards material sorting in Scotland. While I am aware of private sector textile reuse/recyclers already looking at this next investment, it is not in Scotland.” - ApparelXchange CIC

Other suggestions

Some respondents supported introducing EPR schemes to combat textile waste, which was described in greater detail at Q1. As described in Q9, a concern about the costs associated with a new statutory service, particularly for local authorities, was raised again by a few respondents at this question.

Other considerations and suggestions mentioned by a small number of respondents are listed here from most to least prevalent:

• A call for recycling and collection policy standardisation across Scotland, which was also supported by Dundee City Council and CIWM Scotland, who recommended a common standard with best practices, such as a position paper written by EuRIC entitled “Textiles Handling & Sorting Specifications - For re-use and recycling of used textiles”.
• A suggestion to offer a range of different services, such as increased recycling banks and some kerbside collection, collection of textiles alongside other types of waste, like bulky waste, or charging for textile waste collection as with garden waste in some local authority areas.
• A request for further clarification of the purpose of the proposed textile collections.
• Reconsideration of proposed statutory textile recycling services once the deposit return scheme is introduced and the impacts of that change are understood by local authorities.
• Understanding of mitigation procedures to stop theft of textiles from textile banks when the textile prices are high.