Last July, Textile Exchange released the new version of the “Reclaimed Material Declaration Form” (RMDF), which is the declaration template to be used by the “reclaimer” – the first organization in the supply chain of recycled material products that is required to be certified. Typically, this entity recovers waste and certain by-products in order to convert them into a secondary raw material eligible for GRS/RCS certification and, in the near future, for “MMS – recycled & MMCF materials” certification.

This important revision of the RMDF aims to improve transparency regarding the origin and type of recovered materials and, through a process of standardizing and classifying data, to make the traceability of such materials along the recycling chain more reliable and efficient.

Let’s look at the main updates:

1. Key management aspects

• The RMDF must be prepared by the reclaimer for each supplier and for every calendar month during which recovered material is received.
• The RMDF must also be submitted to the Certification Body (CB) within 31 days after the end of the calendar month in which the recovered material was received.

2. Classification of the recovered material supplier. The supplier must be classified according to the following categories, which are in turn linked to the type of material:

• Brand/Retailer: This implicitly refers to (i) “defective finished products,” as well as (ii) “unsold finished products,” and (iii) “customer-returned products” that are not resellable. This is a particularly relevant area addressed by EU Regulation 2024/1781 (Ecodesign), which introduces a ban on the destruction of unsold textile products. A draft delegated regulation is currently under discussion, which outlines the exceptions or derogations under which the destruction of unsold products may be allowed. These would generally fall under the category of “post-consumer waste”.
• Manufacturing Industry: This category also warrants further consideration, especially in relation to waste management legislation and the Ecodesign Regulation. While a full analysis isn’t possible here, it’s important to note that a manufacturing operator without the appropriate authorization for the collection, transport, and storage of waste is not permitted to manage “waste.” They may only handle “by-products” – that is, production scraps which, according to the waste prevention principle, are not considered waste. This has clear implications for the use of the term “recycled.
• Collectors and/or Concentrators:. In my view, this category requires further clarification, as it operationally overlaps with another category – “Municipal/industrial/commercial/nonprofit collection,” which includes public and private entities and nonprofits. These organizations typically operate under specific licenses allowing them to collect and store waste, which may be either pre-consumer (e.g., spinning or weaving waste collected from industry players) or post-consumer. From this, one could infer that “Collectors and/or Concentrators” are private entities lacking a license to handle waste, and therefore only authorized to manage “by-products.” If this interpretation is correct, then it would not be appropriate to list “Waste collection network” (PR0052) as a source, since it pertains to authorized organizations.