Brussels, 29 July 2026
Comments on Notification 2026/0220/RO – Draft Emergency Government Ordinance on the Introduction of Used, Repaired or Reconditioned Products into Romania
The Bureau of International Recycling (BIR) is the world’s largest recycling federation, representing over 30,000 companies across 73 countries, through 36 national associations and over 1,100 direct corporate members. BIR's mission is to promote materials recycling, free and fair trade of recyclables, the environmentally sound management of resources, and the use of recycled materials worldwide.
BIR wishes to express serious concerns regarding the Draft Emergency Ordinance on the introduction of used, repaired or reconditioned products into Romania.
BIR fully supports efforts to prevent illegal shipments of waste disguised as reusable products, as well as measures aimed at protecting consumers, public health and the environment. However, we believe that several provisions of the Draft Ordinance risk creating unnecessary obstacles to the legitimate trade of second-hand products and may undermine the objectives of the European circular economy.
Second-hand textiles move through a globally integrated value chain in which different countries and regions perform distinct, complementary functions, from collection to sorting and grading, and resale. These flows are highly interdependent, and restricting any single link in this chain does not eliminate the material, but instead diverts it towards less efficient outcomes, including disposal.
1. Mandatory cleaning, disinfection, pest control, washing and ironing according to ISO 3175-1:2017
The Draft Ordinance requires second-hand textile products to undergo cleaning, disinfection, pest control, washing and ironing prior to being placed on the Romanian market.
BIR considers this requirement disproportionate and inconsistent with the principles underpinning EU legislation on waste prevention and reuse. The Waste Framework Directive recognises preparation for reuse as a key waste-prevention activity and identifies checking, cleaning and repair operations as operations to be undertaken only where necessary to enable products to be reused safely. The Directive does not establish mandatory compliance with a single cleaning standard for all used textiles, irrespective of their condition or intended market.
Imposing blanket treatment requirements on all second-hand textiles would create significant additional costs for operators, with no evidence that these costs are matched by a corresponding benefit to public health. It would also increase water consumption, energy use and greenhouse gas emissions associated with reuse activities, thereby reducing the environmental advantages that textile reuse is intended to deliver.
BIR therefore urges Romania to adopt a risk-based approach whereby cleaning, disinfection or other treatments are required only where justified by the condition of the products or specific health considerations, in line with EU legislation.
2. Automatic classification as hazardous products due to administrative deficiencies
Under the Draft Ordinance, shipments with incomplete documentation or labelling deficiencies may be classified as dangerous products. BIR does not consider that gaps in documentation or labelling are, on their own, sufficient grounds to classify a product as hazardous. Such an approach conflates administrative infringements with genuine product safety concerns, creating substantial legal uncertainty for operators engaged in legitimate trade.
The proposed mechanism risks discouraging reuse activities and could result in reusable products being unnecessarily diverted from reuse pathways into waste management streams, contrary to the waste hierarchy established under EU legislation.
BIR therefore recommends that documentation and labelling deficiencies be addressed through proportionate corrective measures rather than the automatic classification of products as hazardous.
3. Mandatory registration of transactions 24 hours prior to entry into Romania
The requirement to register transactions through the SIATD ROSH platform at least 24 hours prior to the introduction of products into Romania raises significant concerns regarding its operational efficiency and its impact on trade in second-hand goods.
The second-hand textile sector operates through complex and dynamic supply chains that require timely logistical planning. Additional pre-notification requirements may create delays, increase administrative costs and reduce competitiveness without demonstrable benefit.
Any traceability system should be proportionate, practicable for economic operators, and targeted at identified risks. BIR urges the Romanian authorities to engage with industry stakeholders to develop practical solutions that facilitate compliance while avoiding unnecessary burdens.
Conclusion
BIR supports Romania's objective of preventing illegal waste imports and ensuring consumer safety. However, the Draft Ordinance as currently formulated introduces measures that risk creating unjustified barriers to the movement of reusable products, imposing disproportionate compliance costs, and undermining established circular economy practices.
BIR also notes that unilateral national measures of this kind, introduced outside a coordinated EU or international framework, risk setting a precedent that could be replicated by other jurisdictions. A fragmented regulatory landscape wouldincrease compliance costs across the sector, disrupt established and efficient trade flows, and ultimatelywork against, rather than support, the shared goal of a well-functioning circular economy for textiles.
We respectfully urge the Romanian authorities to reconsider these provisions and to work with stakeholders to develop a more proportionate and risk-based framework that effectively targets illegal waste shipments while safeguarding legitimate reuse and recycling activities.
