HUMANA Kleidersammlung GmbH

We collect, sort and sell used clothes and shoes in Germany since 1988.

Lobbying Activity

Response to Social Economy Action Plan

26 Apr 2021

HUMANA Kleidersammlung GmbH is a German SME and a social business according to the definition of Nobel laureate Prof. Muhammad Yunus, who coined the term. Since the 80’ies we collect, sort and sell used clothes and use the profits entirely for the common good - partly for reinvestment and partly for development cooperation - as laid down in our company founding documents. Members of the Federation HUMANA People to People run over 1,200 development projects in 45 countries. We welcome the European Commission’s initiative to boost the social economy and we agree with the understanding of the problem and possible solutions expressed in the roadmap as well as the feedback provided by other stakeholders such as Catalyst 2030, Euclid Network, Ecopreneur.eu, Concord and Samaritan International. Our feedback builds mainly on our own experience in Germany and partly on what we learned from our partners across Europe and the Global South. The Social Economy has indeed a great potential to change the world for the better. This is important not only when building back better after the setbacks by the COVID-19 pandemic but also in the face of climate change and its disastrous consequences yet to come. It is the poor that suffer and will suffer the most, especially in the Global South. The variety of businesses, organisations and legal forms that the Social Economy encompasses demands special attention. It will help to provide a definition under which this variety can unite and recommendations to Member States about the legal framework to support the Social Economy. It will help to raise awareness about the Social Economy and its benefits for society at large. One of the questions most frequently put to us over the 35 years of our activities in Germany was “are you a charity or are you a business?” A business for a good cause was unheard of. A business like ours could not (and can still not) be recognized as charity in Germany, even though its sole purpose is the common good. In Germany, social businesses like ours must pay full taxes, both on the revenue and VAT. This leads to unfair competition with merely commercial business who externalize some of the costs they cause. All this is now on the move in Germany. Many people understand and support the concept of social business and most parties in the German Parliament have declared their support to the Social Economy / Social Entrepreneurship / Social Innovation. As a first step, we advocate for lower VAT on sustainable products and services such as second-hand clothes and repair services and for a broader support to the Social Economy including better access to finance, facilitation of training and dialogue.
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Response to EU strategy for sustainable textiles

1 Feb 2021

EU strategy for textiles, feedback to roadmap, January 2021 A. Context, problem definition and subsidiarity check Concerning the context and the problems the initiative aims to tackle we agree to the bigger picture but feel we have relevant comments to the figures: re-use has a considerable size and impact. See full version in the attached document. In this aspect, textiles are very different from waste streams such as paper and glass, where recycling unfortunately by far out-weighs re-use. Concerning the basis for EU intervention we agree; we especially agree to that a response at EU level will be needed regarding textile waste collection, sorting and recycling. B. What does the initiative aim to achieve and how? These are our comments to the eight paragraphs: 1. Boosting the competitiveness, sustainability and resilience of the EU textile sector sound good, but sustainability must come first, as priority number one, and it should be the global textile sector that should be addressed, not only the one inside the EU. Our world today is so interlinked that we – humanity - do not stand a chance unless we act on the global needs. 2. Good to make optimal use of the recovery plan. Instead of “new business models” please go for “sustainable business models” as in paragraph six. Re-use, repair, renting and sharing are as old as humanity and very effective ways of addressing the current situation. The fact that they have been somewhat outside mainstream for a few decades doesn’t mean they are new. 3. Very good with targets to significantly step up re-use and recycling efforts. This is a must. We would like to add that this should be done at all levels (at European, national and local levels) and appropriate monitoring will be needed. We welcome targets for green public procurement. In addition, we suggest setting targets for durability and repairability of new clothes, ban incineration of unsold goods and enforce use of all new items. 4. Good to improve textile waste collection and recycling in the Member States. However, the intention alone is not enough, it needs concrete action such as: - Minimizing VAT on second-hand goods and services - Secure appropriate funding for collection and sorting, for instance for the treatment of the clothes that cannot be re-used - Promote codes of conduct for collection, sorting and sale of used textiles - Support communication to citizens about re-use, repair and recycling - Support dialogue and collaboration across the sector 5. Good to improve design for sustainability, an important approach would be to set targets for durability and repairability, see above. 6. Very good with supporting sustainable lifestyle etc and sustainable business models. 7. Make sure that extended producer responsibility schemes support the top of the waste hierarchy (re-use above recycling) 8. Very good with improving traceability and transparency across the sector. C. Better regulation Concerning the consultation of citizens and stakeholders we welcome the description of stakeholders to be included (also collectors, sorters, recyclers, consumers, consumer associations and civil society are mentioned here), we welcome the described consultation activities and look forward to contributing. Concerning the evidence base and data collection we wish to draw your attention to our market survey on second-hand clothes. Find an article about it on the European Circular Economy Stakeholder Platform (https://circulareconomy.europa.eu/platform/en/news-and-events/all-news/market-survey-second-hand-clothes) and visit our blog www.secondhandcounts.wordpress.com. About HUMANA Kleidersammlung GmbH We collect, sort and sell used clothes. We are an SME in Germany with more than 30 years of experience, more than 100 employees and a large network within the global second-hand sector. As a social business we use our profit entirely on environment and development cooperation.
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