First define what your business can actually sell

Start the specification with your own sales market. Only then compare it with the material offered by suppliers.

A sorting facility selling many categories into different markets may accept a different lot structure from a wholesaler supplying only shops looking for a specific quality level. This is not a reason to reject unsorted material automatically. It is a reason to check whether the company has customers and operational capacity for the full expected structure of the material.

Buyer requirements sheet

Separate a contractual requirement, a historical result and an indicative description of the material. A statement that “previous shipments contained a lot of winter clothing” is not a commitment that a specified share of winter clothing will be present in your container.

For unsorted material, demanding exact, guaranteed shares of every category may not reflect how the material is actually prepared. In that situation, negotiate primarily around the source, collection period, extent of prior selection, exclusions and access to inspection.

If your business needs a predictable category structure, ask in parallel for an offer for pre-selected material. Compare the price difference with the cost of labour, residual material and tied-up stock — not with the price of unsorted material alone.

Where to find suppliers and how to establish their actual role

Build the candidate list through several channels: industry directories, trade fair contacts, importer recommendations, direct searches for collection operations and sorting facilities, and contacts with logistics operators. Treat B2B platforms as a way to find contacts, not as completed due diligence.

One specific starting point is the Public Directory of SMART — the Secondary Materials and Recycled Textiles Association. The directory helps identify companies active in secondary textiles, but it does not replace checks on the specific seller and lot. ^[1]

A company label does not define responsibility

Ask for five parties or functions to be identified: the seller under the contract, the invoice issuer, the holder or party controlling the material, the party responsible for preparation and loading, and the party responsible for handling claims.

These do not always have to be the same companies. The relationships between them must, however, be clear and documented. If an intermediary presents the offer but is not responsible for the sale, assess the scope of its service separately from the credibility of the actual exporter.

Supplier verification before the first deposit

The purpose of qualification is not to collect as many files as possible. It is to establish whether an existing entity, represented by the right person, can fulfil the specific order.

Identity and authority

Obtain the full legal name, registration or business number, address, details of the contracting party and the payment beneficiary. Check that this information is consistent with an independent register and the commercial documentation.

In Canada, the Corporations Canada database covers federal corporations, but not every business incorporated under provincial or territorial law. No result in this database does not prove that a company does not exist; the relevant register should then be checked. ^[2]

Finding the company alone does not confirm the authority of the person signing the order. Where necessary, ask for a document demonstrating authority to represent the company or a power of attorney.

Facilities and access to the material

Ask for the storage location, a description of how the material is sourced and prepared, and an opportunity to see the warehouse. During a live video call, ask the supplier to move to a specified part of the facility and show current bales, markings and the weighing process.

A promotional video may show a genuine facility, but it does not by itself establish whether the offered lot is currently there or who has the right to dispose of it. For greater financial exposure, consider an independent inspection.

Export history and references

Ask for anonymised documents from previous shipments: invoices, packing lists and transport documents. Check that dates, parties and transaction descriptions are consistent.

Verify a reference through contact details found independently. Ask about weight conformity, completeness of documents, timeliness and how problems were handled. Confirmation that “the container arrived” alone does not establish the quality of the business relationship.

Documents from a previous shipment are not evidence of the quality of the next lot.

Sample and traceability

Assess any sample together with information about where it came from, who selected it and whether it can be linked to the order. A set of attractive pieces selected for presentation cannot be used to estimate the outcome of the entire unsorted lot.

If the material will only be assembled after the order is placed, agree the preparation process, when the lot will be separated, how it will be marked and at what stage inspection will take place. Do not replace these arrangements with photographs of unrelated stock.

Warning signs that should stop the transaction

Confirm any change of bank account through a channel that was verified earlier, not through a phone number first supplied in the message announcing the change. The FBI recommends this type of independent verification as protection against fraud involving compromised or impersonated business correspondence. ^[3]

RFQ: an enquiry that can produce comparable responses

Send every candidate the same request for quotation — RFQ. Ask suppliers to identify deviations from the specification rather than simply confirming that “we can supply”.

Do not compare kilograms without defining them. A price based on weight that includes packaging is not directly comparable with a price based on the net weight of the clothing. Likewise, the weight of the entire loaded container is not the chargeable weight of the material.

The common comparison point should be the goods received at the buyer’s warehouse, before sorting. Record unconfirmed charges as “data unavailable”, not as zero.

Negotiation: every agreement must be verifiable and enforceable in the transaction

In the first transaction, the buyer should negotiate primarily to reduce uncertainty about the material and how the order will be fulfilled.

A sensible sequence for the discussions is:

1. Description of the goods.
2. Access to the lot.
3. Weight.
4. Documents.
5. Responsibility.
6. Payment.
7. Claims.
8. Final price.

What to put in the purchase order

The following guidance shows which conditions are worth agreeing when purchasing used clothing. It is not a ready-made legal opinion. The parties’ details, the goods’ parameters and the transaction terms should be defined in the purchase order or contract.

Subject of the order

Define precisely which lot of clothing the order covers. Refer to an annex containing the goods specification, state its number and date, and describe the agreed method of preparing the lot for shipment.

If the clothing’s origin, collection method or collection period matters, specify those elements as well. The seller should not replace the agreed goods with clothing from other sources without the buyer’s prior consent.

If the lot is prepared only after the deposit is paid, agree the preparation deadline, the identification method and the possibility of inspecting the goods before shipment.

Weight and price

Clearly state the price, currency and settlement unit, for example a price per kilogram or pound.

Also define the weight used for final settlement—for example, the net weight of the clothing or the gross weight including packaging. State how the goods will be weighed, which document will confirm the weight and how differences between declared and actual weight will be settled.

Goods inspection and subsequent payments

If payment is divided into stages, define precisely when the next payment becomes due and which documents or information the seller must provide beforehand.

Agree the criteria used to assess whether the prepared lot complies with the order. They may cover the type of clothing, preparation method, origin, condition, packaging and agreed weight.

A right to inspect the goods is not enough. Agree in advance what happens if material non-conformities are found. Options may include a new inspection after correction, an appropriate adjustment of the transaction terms, price renegotiation or termination of the order under previously agreed rules.

It is especially important to define how the deposit or other amounts paid before inspection will be settled if the prepared lot does not meet the agreed conditions.

Claims

The parties agree the deadlines for reporting non-conformities visible on receipt and those discovered during sorting, the evidence required, the seller’s response time and the available methods for settling an accepted claim.

Do not insert an arbitrary number of days. The deadline should reflect the actual time needed to unload and inspect the lot, taking into account the governing law and any separate time limits for transport claims.

Define what the supplier is responsible for

“Good quality”, “premium original” and “high yield” are not substitutes for a measurable description. If the sales outcome depends on your customers and your sorting method, do not automatically treat it as a parameter guaranteed by the exporter.

Incoterms define selected obligations, costs and the transfer of risk, but they do not replace agreements on payment, quality, transfer of title or dispute resolution. These matters must be addressed separately. ^[6]

Payment: compare the mechanism, not just the deposit percentage

There is no single deposit percentage that makes a first transaction safe. Assess the amount exposed to loss, the quality of the evidence available before payment and the realistic ability to pursue a claim.

Documentary mechanisms reduce selected risks, not every risk associated with the purchase. Their structure and costs should be agreed with the bank or operator before the contract is signed. ^[4]

Define the event that triggers payment

A clause saying “balance after shipment” leaves too much room for interpretation. Specify the trigger: an accepted inspection report, weighing document, loading and sealing, a specified transport document or a complete set of compliant documents.

Also agree who verifies the documents and what happens if there is a discrepancy. Do not assume that receiving a PDF file is equivalent to confirmation by the carrier.

Transport documents and control over cargo release

A sea waybill is a non-negotiable document and, as a rule, does not require presentation or surrender of an original for release of the goods. The cargo is released to the consignee named in the document in accordance with the carrier’s identification and release procedure. With a bill of lading, its type and the agreed cargo-release method matter, including any release without paper originals. The effectiveness of documentary control should therefore be agreed with the bank and carrier. ^[5]

A transport document does not replace a quality report.

Before making a transfer, compare the beneficiary with the contract and invoice. Payment to a factor or another company requires a documented explanation. For new or changed bank accounts, consider requiring approval by a second person.

CN 6309, customs duty and CETA: three separate questions

Classification depends on the actual goods

CN heading 6309 covers worn clothing and certain other worn articles. Under Note 3 to Chapter 63, the goods must simultaneously show appreciable wear and be presented in bulk, in bales, sacks or similar packings. The scope of the heading is defined; it does not automatically cover every item found in a collection. ^[10]

Give the customs agent a description of the contents, the share of other articles, information about new items, the degree of wear and any material intended for recycling. Do not automatically copy a code from an exporter’s previous invoice.

A 5.3% rate does not automatically mean the same duty at every clearance

The 2026 CN tariff shows a conventional customs rate of 5.3% for code 6309 00 00. This is a tariff rate, not a guarantee that exactly that duty will apply to a particular consignment. ^[10]

Before placing the order, check the correct CN code, country of origin, availability of customs preferences and required documents in the current tariff system. The clearance date also matters because rates and conditions can change. The import-cost calculation should show not only the rate used but also where it comes from and the basis on which it was applied.

Shipment from Canada is not enough for CETA

For HS 63.09, the CETA protocol specifies a change from another tariff heading. At the same time, simple sorting, classifying and packaging are insufficient operations. Preferential origin therefore cannot be inferred solely from the place of collection, storage or shipment. ^[11]

The prescribed proof is an exporter’s origin declaration compliant with CETA, not just any certificate of origin. ^[12] If the Canadian exporter has been assigned a Business Number, it should be entered in the relevant field of the declaration; a situation in which no number has been assigned is separate. ^[11]

Ask the exporter for the basis of qualification and the documents that would support the declaration during verification. Provide them to the customs agent before basing the calculation on preferential treatment.

Product or waste: determine the status before loading

Price, an invoice and the existence of a buyer are not enough to demonstrate that the material is a product.

The Polish Waste Act links waste status to discarding a substance or object, an intention to discard it or an obligation to do so. It also distinguishes the re-use of products that are not waste from preparation for re-use of items that have previously become waste. ^[17]

What information to collect

Present the history of the material to an adviser or the competent authority: how it was collected, its status with the previous holder, any inspection and selection already carried out, its physical condition and its intended use.

Evidence must relate to the actual lot, not merely to a “second-hand clothing” description on the invoice. In particular, establish whether the material has been assessed as suitable for re-use and on what basis.

The commercial term “unsorted” may mean that the material has not been divided into sales categories. It should not, however, be used as a substitute for an assessment of its legal status.

If the material has waste status, establish the correct waste code, shipment procedure, whether import is permitted and whether the recipient has the required authorisations. Reducing the price or planning to sort the material only after arrival is not sufficient.

Regulatory changes and the purchase decision

Directive 2025/1892 introduces further measures relating to textiles. Its transposition deadline is 17 June 2027. That date alone does not determine whether a particular national measure may have taken effect earlier. Nor should it be treated as suspending existing waste rules. ^[18]

Most provisions of Regulation 2024/1157 on shipments of waste have applied since 21 May 2026. The appropriate procedure depends, among other things, on the type of waste, the purpose of the shipment and the route; the “green list” does not automatically cover every lot of textiles. ^[19]

For the Article 18 procedure, GIOŚ announced that paper documentation would be accepted in Poland until 31 December 2026, using the new Annex VII and the appropriate contract. This is a position on application of the rules, not a general postponement of the Regulation. It does not remove electronic obligations in notification procedures or the need to check the rules in other countries along the route. ^[20]

SENT and VAT: account for the actual transaction flow

SENT does not depend on the product name alone

From 20 June 2026, the threshold for goods under CN 6309 00 00 is more than 31.5 kg gross weight per consignment. The regulation provides exclusions, however, so the code and weight alone do not complete the analysis. ^[15]

PUESC distinguishes, among others, the following cases:

The obligations of each party depend on how the specific delivery is organised and whether a statutory exclusion applies. ^[16]

AEO status must be assessed for the specific entity and type of carriage. The fact that a forwarder or carrier has AEO status does not automatically exempt the importer from its own obligations. ^[15]

Before transport begins, clearly determine who checks whether a declaration is required, who prepares it, who provides the reference number and who is responsible for later updates and confirmation of receipt.

Distinguish the entity that formally bears the obligation from a company or person that merely performs technical steps on its behalf. The carrier should separately confirm which transport-monitoring duties apply directly to it.

VAT: separate economic cost from funding

The standard VAT rate in Poland is 23%.

The VAT base on import is not limited to the invoice value of the clothing. It may also include the customs value, customs duties and specified additional costs that have not already been included. This covers, among other things, transport and other costs to the first place of destination and, in some cases, to a further known destination in the EU. ^[14]

The calculation should therefore show two elements separately: the transaction’s actual economic cost and the amount of cash required to complete it.

VAT that the taxpayer may later deduct does not have to be a permanent purchase cost, but it can increase the financing requirement at the time of import. Its treatment should therefore reflect the importer’s actual VAT-accounting rules.

Pre-shipment inspection and lot assessment

Before shipment

Collect the lot identifier, bale list, weighing and packaging documentation, and an inspection record. Document the condition of the inside of the container, the loading process, the container number and the seal number.

For material prepared to order, define the point from which the lot is segregated and cannot be replaced without agreement.

How to agree the sample

The following approach is a proposal for organising the inspection, not a universal statistical standard.

1. First define the lot being tested. A sample from a different period or source should not be presented as a sample of the material being ordered.

2. Then agree how the bales will be selected. The buyer or an independent inspector should have a say in selecting bales from the entire available set. If the lot includes different sources or periods, reflect that heterogeneity in the plan.

3. Define the scope of the content examination. Assess the material in the agreed bales using the same categories and weighing methods. Do not restrict the inspection to a few easily accessible items from the top.

4. Separate sampling from targeted inspection. A bale opened because of visible moisture provides information about a suspect unit. Do not combine its result without explanation with a sample intended to assess the entire lot.

Receipt at the warehouse

Before mixing the material with older stock, inspect the container and seal, count the units, carry out the agreed weighing and record the condition of the packaging and contents. Mark damp, dirty or damaged lots and separate them where appropriate.

A notification to the seller, carrier or insurer should match the type of problem and the applicable procedure.

Assessment after sorting

Base the decision to repeat the order on the result for the entire lot or on a clearly described sales stage that is still open. A few valuable items do not replace the container-level balance.

Logistics from trade terms to container return

Choose terms that match the point where the goods are handed over

For containers, the ICC identifies FCA as an appropriate starting point. FOB relates to delivery on board the vessel and does not always correspond to the earlier handover of a container to the carrier at the terminal. ^[6]

Under CIP, the seller pays carriage to the agreed place, but risk transfers earlier, when the goods are handed to the carrier. Under CIF, risk transfers on board the vessel. The default level of insurance under CIP is broader than under CIF, but neither abbreviation should be treated as a guarantee that every type of loss is covered. ^[7]

Ask for the policy terms concerning used material, moisture, mould, packaging, the deductible and the claims procedure.

Assign every activity to a specific company

The execution sheet should cover material preparation, container positioning, loading, VGM, transport to the terminal, export clearance, freight, insurance, port charges, import clearance, SENT, any inspections, final haulage, unloading and return of the empty container.

For each item, record the service provider, payer, document confirming completion, and the cost or method used to determine it. “The freight forwarder handles it” does not explain what has been ordered and paid for.

The schedule must separate preparation from transport

Plan the sequence as follows:

1. Lot readiness.
2. Inspection.
3. Transport booking.
4. Loading.
5. Terminal cut-off times for the container and documents.
6. Sea voyage and any transhipment.
7. Cargo availability after arrival.
8. Customs clearance.
9. SENT.
10. Final haulage.
11. Unloading.
12. Container return.

Total cost: a purchased kilogram is not a sold kilogram

First calculate the cost to receive the goods at the warehouse

Include the goods, any preparation and packing not already included, initial transport, freight and surcharges, insurance, customs duties, terminal handling, documents, customs agency services, inspection, any controls, final haulage, unloading and container return. Add delay costs and non-deductible taxes in line with the chosen scenario.

Count each item only once. A cost already included in a CIP or DAP price should not appear again as a separate expense.

Cost per delivered kilogram = cost of receiving the lot at the warehouse ÷ actual net weight of material received.

Then calculate the cost of the full cycle

Assessing the profitability of the trial purchase also requires sorting, repacking, further storage, financing, sales and handling of residues. Allocate financing costs to a defined period so that they are not counted twice in delivery and subsequent sales costs.

Sensitivity example

Assumptions: 10 500 kg net and 84 000 zł cost delivered to the warehouse before sorting. The input cost is 8.00 zł/kg.

If the share falls from 75% to 60%, the unit cost calculated in this way rises by 25%, despite no change in the purchase price or transport cost.

This is not a margin calculation. It does not yet include sorting, different prices for individual categories, possible revenue from other fractions, management of residual material or the time required to sell the goods. Weight classified for sale does not mean weight already sold.

For a repeat-order decision, prepare both the sales result and an inventory statement. Do not replace realised revenue with the expected value of all items still in the warehouse.

How to compare offers before the final negotiation

First check whether the offers cover comparable material, weight and delivery point. Only then compare the amounts.

Example of two offers

These are hypothetical educational figures. They assume the same net weight of 10,500 kg and a comparable scope of goods.

Offer B has a higher material price, but in this example it costs 3 150 zł less once both offers are brought to the same comparison point.

This does not automatically mean that B should be selected. Separately verify the evidence concerning the material, inspection, payment, responsibility and claims.

GO/NO-GO checklist before paying the deposit

Documents that will only be created during loading do not have to exist before the deposit is paid. There must, however, be an agreed route for obtaining them and a clear answer as to what happens if the conditions are not met.

GO does not mean there is no risk. It means that the buyer knows the material uncertainties, has a way to control them and consciously accepts the financial exposure.

A second order should follow from data on the entire lot, labour, sales and stock turnover — not merely from a good first presentation of the material.