Where the rules are clear, we follow them. Where they're moving, we say so.
This page sets out the regulatory context we trade in, the positions we take, and what we report. Where a rule is under review we mark it and describe the current position as we understand it. We don't pretend a debate is settled.
The 80/20 arrangement for freezone sorters.
Sorting units in Pakistan's Export Processing Zones import used clothing without paying duty at entry, on the basis that the graded output is re-exported. The arrangement commonly referred to as "80/20" allows a unit to sell a limited share of its output, described as up to 20%, into the domestic tariff area, with duties and taxes paid on that portion, while the balance is exported.
The arrangement has been the subject of representations from domestic importers, who argue that leakage from the zones undercuts duty-paying sorters, and from EPZ units, who argue the domestic share is commercially necessary. Changes to the policy have been proposed and discussed. We have not assumed an outcome. Until the current position is confirmed in writing, this section describes the context only.
Our position does not depend on how that debate resolves:
- Every EPZ buyer's route is declared on its KYB file and on each trade record.
- We do not facilitate, and will not knowingly supply, diversion of bonded goods into the domestic market outside whatever share is permitted at the time.
- EPZ buyers show their re-export record and zone returns as part of verification (check B5).
- When the rule changes, our standard changes with it, and we notify every EPZ buyer in writing.
Domestic buyers pay what the tariff says, on what the container holds.
We don't act as importer or clearing agent. We make sure the documents we're responsible for give customs an accurate picture.
- Classification
- Used clothing and worn textiles under PCT heading 6309
- Valuation
- Declared values in line with the customs valuation ruling for used clothing in force at the time
- Invoice accuracy
- Commercial invoices state the real grade, weight and price agreed. We do not issue or accept second invoices.
- Importer status
- Domestic buyers must be active on the FBR Active Taxpayer List and registered on Pakistan Single Window (checks B1, B2).
- Evidence
- Sample goods declarations showing duty paid on previous used-clothing imports are held on file (check B5).
For charities: a report you can put in front of trustees.
Charities are increasingly asked where donated textiles end up. Our end-destination report answers that per container, in plain terms, and says honestly what is measured and what is reported.
- Container
- Number, seal, loading date, net weight, origin yard
- Buyer
- Named sort floor (with the buyer's consent) and its KYB reference
- Route
- EPZ re-export or domestic duty-paid, with arrival and clearance dates
- Sort outcome
- Share by broad stream: domestic reuse, re-export for reuse, recycling, residual waste
- Re-export markets
- Destination countries for re-exported grades, as reported by the buyer
- Verification
- Whether the figures were spot-checked by a visit that quarter
What the report is, and isn't
Sort-outcome shares are reported by the buyer from their grading records and verified by sample on site visits . They are not independently audited weights, and we don't present them as such.
We don't publish carbon or "tonnes saved" figures. When we have a methodology that will stand up to scrutiny, we'll publish it with the numbers.
The baseline a sort floor must meet to buy through Ragtrail.
Sorting is manual, dusty, and often hot work. These are the minimum conditions we check on every buyer site visit. They are a floor, not a certification.
Wages
At least the applicable provincial minimum wage, paid on time, with records
Age
No workers below the legal minimum working age. No one under 18 on balers, presses or night shifts.
Fire safety
Extinguishers serviced and accessible, exits unobstructed, no smoking on the floor. Textile fires spread fast.
Dust & heat
Ventilation on sort lines, masks and gloves provided, drinking water and rest breaks in hot months.
Machinery
Guarding on balers and presses. Only trained operators.
Terms & voice
Written terms of employment, and a way to raise a grievance that doesn't go through the supervisor concerned.
When a site falls short
- A written remediation plan with dates, agreed at the visit
- A follow-up visit to confirm it's done
- Allocation paused if the plan is refused or missed, not quietly continued
What we don't claim
We are not a social-audit body and these visits are not audits. If a supplier needs a formal social audit of a buyer, we will arrange access for an auditor of their choosing.
Next step
Questions about a position on this page? Ask us directly.
We would rather answer a hard compliance question before a contract than after one.