Who is SMART?                                      Small and medium-sized
                                                   businesses creating thousands
                                                   of jobs and contributing to local
                                                   economies.

                                                   The world’s oldest recycling
                                                   industry and truly “green”
                                                   alternative.
Founded in 1932, SMART is a non-profit
trade association that represents some 200         Net exporters supporting U.S.
small and medium-sized companies involved          economic growth.
in using, converting and recycling pre- and
post-consumer textiles and other secondary
materials.                                         Companies making the world a
                                                   better place for those in need.
This nearly $1 billion industry’s activities are
very diverse. Some SMART members
recover and process “pre-consumer” by-
                                                   Although the industry is still relatively unknown
products from the textile and fiber industries
                                                   by the general public, as you’ll see below, we
to be used in new materials for automobiles,
                                                   are actively supporting national priorities such
home furnishings, and a variety of other
                                                   as promoting sustainability/green, small
products. Other SMART businesses buy and
                                                   businesses, exports, jobs creation and growth.
sell “post-consumer” second hand textiles.
Our companies buy excess donations
collected by charities like the Salvation Army
and Goodwill, thereby serving as a critical        SMART WAS GREEN
source of operating revenue for these              BEFORE GREEN WAS SMART
groups. Member companies then sort these           Textile recycling, the world’s oldest form of
goods and grade them based on condition.           recycling, is an often overlooked but important
Some of these recovered textiles become            contributor to the green movement. Each year,
wiping and polishing cloths used in                the industry collectively prevents more than 2.5
institutional and industrial settings while        billion pounds of textile waste from entering the
others are reprocessed into fibers for             solid waste stream. Its processes rely largely
furniture stuffing, upholstery, insulation,        on human labor and are far less
building and other materials. The items that       energy/water/resource-intensive or polluting
can be used as apparel are usually exported,       than other reclamation or so-called
typically to least developed and developing        “environmentally friendly” industries. In fact, a
countries where demand for second hand             Lockheed Martin study concluded that
clothing is especially high.                       recovered textile wiping products have a lower
                                                   overall environmental impact, contribute less
                                                   landfill waste, and pose less risk to the
                                                   environment and human health than their not-
                                                   so-environmentally friendly alternative,
                                                   laundered shop towels.


                                                    WWW.     SMARTASN.ORG
SMALL BUSINESSES CONTRIBUTING JOBS AND GROWTH
Each year, the domestic textile recycling sector makes a big contribution to the local tax base by generating some $1 billion
in gross revenue.2 Meanwhile, in contrast with other manufacturing/reprocessing industries, which are heavily dependent
upon mechanized production, this sector uses mainly human labor, thereby creating jobs for some 15,000-20,000 workers.
Most of our member firms, in fact, are family-owned businesses which have operated for decades, and many have fewer
than 500 employees. We respect our workers, who others may regard as semi-skilled or marginal, and we offer a safe
respectful environment, as well as attractive benefits that include health care, retirement packages and more.


NET EXPORTER
International trade is a critical component of our industry’s success. Year-in and year-out, SMART members export far more
than they import and make a positive impact on the U.S. trade balance and domestic GDP. In 2009, the United States
exported more than 60 percent of its recovered textile waste, some 1.4 billion pounds of
used clothing (Harmonized Tariff Schedule heading 6309) valued at nearly $375 million and nearly 250 million pounds of
rags and wiping cloths (HTS 6310) valued at some $86 million.


MAKING A DIFFERENCE
Charities like the Salvation Army and Goodwill praise the second hand clothing segment, which provides a critical source of
revenue by purchasing their unsold donations. These sales generate more than $100 million each year, according to
Goodwill, money that provides job training and other career services.3 Meanwhile, international aid organizations like
Oxfam laud the industry, which ships the bulk of its second hand clothing to impoverished nations in Asia, Africa, Latin
America, and the Caribbean where low-cost, quality used apparel is desperately needed. Meanwhile, Oxfam points out, it
“supports the livelihoods of hundreds of thousands of people in developing countries who work in trading, distribution,
repairing, restyling, washing, etc.”4

POLICY ISSUES
Customs Border Protection’s (CBP) Interpretation of Used Clothing: Depending on availability of domestic supply,
SMART members sometimes import used clothing from Canada for eventual re-export or for other textile recycling.
Although these shipments should be allowed to enter the U.S. duty free, a flawed CBP interpretation has resulted in their
being charged the same duties applied to new items of clothing (as high as 32 percent), despite the obvious differences in
profit margins, therefore threatening the industry’s future viability. Although the industry has attempted a variety of legally
intact administrative challenges, CBP has repeatedly dug in its heels. SMART is now trying to build support for a legislative
remedy among members of Congress.

EPA “Wiper Rule”: EPA has been working for more than two decades to develop hazardous waste regulations governing
the management of solvent-contaminated industrial wiping products, including non-laundered recycled textile rags and
laundered shop towels. If finalized, this rule would reduce unfair regulatory disparities between the two different types of
wipes, more strictly regulate the highly toxic sludge created when shop towels are laundered, increase recycling of
industrial solvents, and offer greater regulatory certainty for the thousands of manufacturers that are using wipes in their
facilities. Yet despite these clear benefits, not to mention broad support from SMART and other industry groups, organized
labor, lawmakers and more, EPA continues to drag its feet, with the agency’s most recent projections placing the final rule’s
publication sometime in mid-2012. It has been more than 20 years – it is time that the EPA finish this rulemaking once and
for all.

Textile recycling: Astonishingly, the more than 2.5 billion pounds of textiles that the industry is diverting from the waste
stream each year is a mere 15 percent of the total that Americans are throwing away each year. Yet, insufficient and
fluctuating supply is a constant threat for the industry, and has forced many textile recycling companies to downsize in
recent years. The non-profit Institute for Local Self-Reliance has advocated for municipal textile recycling noting that such
efforts would, “divert additional waste from landfills and incinerators, and enable textile recycling companies to expand their
operations, sustain more jobs, and clothe more of the world’s peoples.” At a time when cash-strapped local economies and
charitable organizations are leaving no stone unturned in their quest for new funding sources, SMART encourages public
officials to explore policies that encourage textile recycling, which could lead to a new source of revenue for these non-
profits and struggling community agencies.
1
  U.S. Environmental Protection Agency, “Textiles-Common Wastes & Materials”, http://www.epa.gov/osw/conserve/materials/textiles.htm.
2
 Institute for Local Self-Reliance, “Weaving Textile Reuse into Waste reduction http://www.ilsr.org/recycling/textilereport.pdf
3
  May 5, 2006 letter to U.S. Customs and Border Protection Deborah Spero
4
  “The Impact of Second Hand Clothing Trade on Developing Countries,” Oxfam, 2005.


Secondary Materials And Recycled Textiles (SMART) Association
2105 Laurel Bush Rd., Ste. 200 Bel Air, MD 21015
Tel: 443.640.1050 Fax: 443.640.1086 SMART@ksgroup.org                                         www.smartasn.org

Reuse #3 SMART Congressional Outreach Flyer

  • 1.
    Who is SMART? Small and medium-sized businesses creating thousands of jobs and contributing to local economies. The world’s oldest recycling industry and truly “green” alternative. Founded in 1932, SMART is a non-profit trade association that represents some 200 Net exporters supporting U.S. small and medium-sized companies involved economic growth. in using, converting and recycling pre- and post-consumer textiles and other secondary materials. Companies making the world a better place for those in need. This nearly $1 billion industry’s activities are very diverse. Some SMART members recover and process “pre-consumer” by- Although the industry is still relatively unknown products from the textile and fiber industries by the general public, as you’ll see below, we to be used in new materials for automobiles, are actively supporting national priorities such home furnishings, and a variety of other as promoting sustainability/green, small products. Other SMART businesses buy and businesses, exports, jobs creation and growth. sell “post-consumer” second hand textiles. Our companies buy excess donations collected by charities like the Salvation Army and Goodwill, thereby serving as a critical SMART WAS GREEN source of operating revenue for these BEFORE GREEN WAS SMART groups. Member companies then sort these Textile recycling, the world’s oldest form of goods and grade them based on condition. recycling, is an often overlooked but important Some of these recovered textiles become contributor to the green movement. Each year, wiping and polishing cloths used in the industry collectively prevents more than 2.5 institutional and industrial settings while billion pounds of textile waste from entering the others are reprocessed into fibers for solid waste stream. Its processes rely largely furniture stuffing, upholstery, insulation, on human labor and are far less building and other materials. The items that energy/water/resource-intensive or polluting can be used as apparel are usually exported, than other reclamation or so-called typically to least developed and developing “environmentally friendly” industries. In fact, a countries where demand for second hand Lockheed Martin study concluded that clothing is especially high. recovered textile wiping products have a lower overall environmental impact, contribute less landfill waste, and pose less risk to the environment and human health than their not- so-environmentally friendly alternative, laundered shop towels. WWW. SMARTASN.ORG
  • 2.
    SMALL BUSINESSES CONTRIBUTINGJOBS AND GROWTH Each year, the domestic textile recycling sector makes a big contribution to the local tax base by generating some $1 billion in gross revenue.2 Meanwhile, in contrast with other manufacturing/reprocessing industries, which are heavily dependent upon mechanized production, this sector uses mainly human labor, thereby creating jobs for some 15,000-20,000 workers. Most of our member firms, in fact, are family-owned businesses which have operated for decades, and many have fewer than 500 employees. We respect our workers, who others may regard as semi-skilled or marginal, and we offer a safe respectful environment, as well as attractive benefits that include health care, retirement packages and more. NET EXPORTER International trade is a critical component of our industry’s success. Year-in and year-out, SMART members export far more than they import and make a positive impact on the U.S. trade balance and domestic GDP. In 2009, the United States exported more than 60 percent of its recovered textile waste, some 1.4 billion pounds of used clothing (Harmonized Tariff Schedule heading 6309) valued at nearly $375 million and nearly 250 million pounds of rags and wiping cloths (HTS 6310) valued at some $86 million. MAKING A DIFFERENCE Charities like the Salvation Army and Goodwill praise the second hand clothing segment, which provides a critical source of revenue by purchasing their unsold donations. These sales generate more than $100 million each year, according to Goodwill, money that provides job training and other career services.3 Meanwhile, international aid organizations like Oxfam laud the industry, which ships the bulk of its second hand clothing to impoverished nations in Asia, Africa, Latin America, and the Caribbean where low-cost, quality used apparel is desperately needed. Meanwhile, Oxfam points out, it “supports the livelihoods of hundreds of thousands of people in developing countries who work in trading, distribution, repairing, restyling, washing, etc.”4 POLICY ISSUES Customs Border Protection’s (CBP) Interpretation of Used Clothing: Depending on availability of domestic supply, SMART members sometimes import used clothing from Canada for eventual re-export or for other textile recycling. Although these shipments should be allowed to enter the U.S. duty free, a flawed CBP interpretation has resulted in their being charged the same duties applied to new items of clothing (as high as 32 percent), despite the obvious differences in profit margins, therefore threatening the industry’s future viability. Although the industry has attempted a variety of legally intact administrative challenges, CBP has repeatedly dug in its heels. SMART is now trying to build support for a legislative remedy among members of Congress. EPA “Wiper Rule”: EPA has been working for more than two decades to develop hazardous waste regulations governing the management of solvent-contaminated industrial wiping products, including non-laundered recycled textile rags and laundered shop towels. If finalized, this rule would reduce unfair regulatory disparities between the two different types of wipes, more strictly regulate the highly toxic sludge created when shop towels are laundered, increase recycling of industrial solvents, and offer greater regulatory certainty for the thousands of manufacturers that are using wipes in their facilities. Yet despite these clear benefits, not to mention broad support from SMART and other industry groups, organized labor, lawmakers and more, EPA continues to drag its feet, with the agency’s most recent projections placing the final rule’s publication sometime in mid-2012. It has been more than 20 years – it is time that the EPA finish this rulemaking once and for all. Textile recycling: Astonishingly, the more than 2.5 billion pounds of textiles that the industry is diverting from the waste stream each year is a mere 15 percent of the total that Americans are throwing away each year. Yet, insufficient and fluctuating supply is a constant threat for the industry, and has forced many textile recycling companies to downsize in recent years. The non-profit Institute for Local Self-Reliance has advocated for municipal textile recycling noting that such efforts would, “divert additional waste from landfills and incinerators, and enable textile recycling companies to expand their operations, sustain more jobs, and clothe more of the world’s peoples.” At a time when cash-strapped local economies and charitable organizations are leaving no stone unturned in their quest for new funding sources, SMART encourages public officials to explore policies that encourage textile recycling, which could lead to a new source of revenue for these non- profits and struggling community agencies. 1 U.S. Environmental Protection Agency, “Textiles-Common Wastes & Materials”, http://www.epa.gov/osw/conserve/materials/textiles.htm. 2 Institute for Local Self-Reliance, “Weaving Textile Reuse into Waste reduction http://www.ilsr.org/recycling/textilereport.pdf 3 May 5, 2006 letter to U.S. Customs and Border Protection Deborah Spero 4 “The Impact of Second Hand Clothing Trade on Developing Countries,” Oxfam, 2005. Secondary Materials And Recycled Textiles (SMART) Association 2105 Laurel Bush Rd., Ste. 200 Bel Air, MD 21015 Tel: 443.640.1050 Fax: 443.640.1086 SMART@ksgroup.org www.smartasn.org