Blind Spots in Circular Economy Data Infrastructure for Sustainable Textile Management: End-of-Life Textile Products in Trade Statistics

Sustainable textile management and circular supply chains depend on shared product classifications that make used products visible. This paper investigates whether the Harmonized System (HS), which underpins trade statistics and the EU textile extended producer responsibility (EPR) scope, can distinguish used textile products from new ones. All 152 headings of HS Section XI, along with five associated headings, are graded on a four-level end-of-life resolution scale based on the HS legal notes. Coverage is measured with 450,872 UN Comtrade records for 2013–2023, using a validated procedure for missing and misreported weights, and Eurostat data for the EU market. Carpets, other made-up articles, and technical textile articles have no used or waste code, so their used forms are declared as new goods. They accounted for 26.5% of finished textile exports in 2023 (bootstrap 95% interval 22.7–35.3%; 20.3–39.7% under alternative boundary definitions) and 29% of the EU market by mass (13% by value), and they lie outside the EU textile EPR scope. These shares locate a classification gap rather than measure unrecorded waste. Removing records without usable weights converts a 37% increase under the recovery headings into a 6% decline. The gap limits the monitoring of reuse, recycling, and used-textile exports, the coverage of EPR financing, and the tracking of Sustainable Development Goal 12. Combined Nomenclature subdivisions, digital product passport data, and transparent treatment of incomplete records could close it and support resource-efficient, accountable textile value chains.