Why leather should be excluded from the scope of the Proposal for a Regulation on Deforestation-Free Products
COTANCE is a non-profit organization representing the leather-producing industry at European and international level. COTANCE represents the employers in the EU Social Sectoral Dialogue and develops active coordination policies in the areas of environmental performance, social accountability, corporate social responsibility, R&D+I, as well as education & training and image & communication. COTANCE is a member of the International Council of Tanners (ICT) and participates in the Global Leather Cooperation Committee (GLCC).
COTANCE deplores that all the efforts deployed by governments and international organisations to curb deforestation and forest degradation have not been able to halt or reduce the incalculable damage that they cause to the planet. For this reason, COTANCE strongly supports the EU efforts to tackle activities associated with deforestation and forest degradation.
However, the proposal for a Regulation on Deforestation-Free Products errs in the inclusion of leather into its scope: While the proposed EU rules on meat and meat products can be effective in curbing deforestation and forest degradation, COTANCE contends that it is incorrect, damaging and unnecessary to additionally target animals’ by-products, which have a negligible value relative to meat and therefore cannot be considered as drivers of deforestation.
The inclusion of leather in the scope of the Regulation would disproportionally impact an EU industry composed of small & medium sized companies, which has no direct impact on deforestation, severely jeopardising the competitiveness of EU companies and undermining the objectives of the EU Strategy for Sustainable and Circular Textiles. The inclusion of leather could be putting at risk some 30.000 direct jobs in tanning and about 300.000 in downstream sectors in the EU.
In light of the above, COTANCE calls on the Members of the European Parliament to exclude hides, skins and leather from the proposal for a Regulation on deforestation-free products.
COTANCE remains firmly committed to uphold the highest environmental standards and actively uses all its communication channels with its suppliers in the meat industry to promote ethical requirements in the leather value chain. COTANCE is constantly working on implementing traceability along the supply chain and contributes to the development of tools (1, 2, 3, 4) aimed at avoiding reputational risks related to cruelty to animals or the sourcing of hides and skins from animals raised in deforested areas.
In this paper, COTANCE voices its concerns as regards the inclusion of hides, skins and leather in Annex I to the abovementioned proposal, namely:
The inclusion of leather is not justified, as leather is not a driver of deforestation:
- It has been shown that the demand for hides for leather does not directly affect cattle production and only has a neglectable influence on the number of animals reared and slaughtered. Therefore, it cannot be considered per se a driver of deforestation. In fact, the value of the hides corresponds to 0.8% of the animal’s value.
- Leather is not comparable with the other commodities in the scope of the proposal. Unlike meat for cattle or chocolate for cacao, leather is not the “raison d’être” of cattle; it is the result of the transformation of a by-product from meat and dairy production.
- The only reason why leather has been added to the scope of the proposal is due to the misconception that animals’ hides or skins (by-products) have the same detrimental environmental impact as meat (product). However, it is worth noting that cattle is raised for milk and meat for human consumption, whereas hides and skins are residues.
As it stands, the proposal will lead to a non-level playing field for EU producers of leather and leather articles:
- European leather value chain operators will face increased competition from third countries businesses that are not bound by the Regulation. The due diligence requirements contained in the proposal will lead to an uneven level playing field vis-à-vis non-EU manufacturers of leather articles (e.g., footwear, bags, belts or wallets), as these are not in scope of the proposal. This will increase the relocation of leather and leather articles manufacturing away from Europe, with the consequent loss of jobs, skills and wealth creation.
- The proposed rules will further penalise European tanners in the sourcing of raw materials. European tanners already suffer an unfair comparative price advantage in comparison with non-EU operators, as over 60% of global availability of hides are already subject to export restrictions or export taxes.
- EU tanners are mainly small and medium enterprises. We, therefore, expect that the proposed due diligence requirements for the EU leather value chain will pose a significant bureaucratic and economic burden on these companies, while not bringing any added value to the fight against deforestation.
The current proposal disregards the objectives of the EU Strategy for Sustainable and Circular Textiles:
- Leather is unmistakably a circular material, essential for the transition to a sustainable fashion value chain: Tanneries transform a residue produced by the meat sector into a highly value-added fashion material required by the world’s most demanding brands. As leather is characterized by its longevity, leather products often have several lifecycles, passing from hand to hand, from generation to generation, minimising the environmental impact of their production and contributing to tackling fast fashion. Moreover, leather products can be recovered, reused or repurposed and biodegrade at the end of their lifecycle.
- As a by-product, leather’s origin is very different from all other fashion materials. Unlike leather, textile raw materials, such as cotton, wool and silk (natural) or polyester (synthetic), are produced on demand and are not by-products from other production systems. This is also the case for plastic materials, which are a frequent alternative to leather. The latter cannot be regarded as a sustainable solution due to their pollution and waste generation potential.
- The EU Strategy for Sustainable and Circular Textiles introduced the Textiles Ecosystem Transition Pathway, which is intended to support the recovery and long-term sustainability of, among others, the leather sector. As discussed, the inclusion of leather in the EU deforestation regulation creates an uneven level playing field for operators in the sector’s trade. Posing such a burden on the EU leather value chain will only hinder the strategic objectives of the European Commission for the Textiles Ecosystem.
July 2022