Fight against Deforestation
Although “leather” material originates in slaughterhouses, where raw hides – waste from the meat industry – are recovered by the operators of our supply chain, the principle of the supply chain can be traced back, in the evaluation of specific sustainability aspects, also to the upstream part of the meat supply chain, i.e., to the animal’s breeding.
In this regard, it is obviously ESSENTIAL to consider that the nature of leather as a by-product creates a strong, and in many ways, unbridgeable distance between the operators of the actual leather supply chain and the farms, given that thein this phase, the leather per se does not exist as a good. And this prevents any specific or general requests from the tanneries from reaching the farms and concretely stimulating changes in the related production practices and processes.
Despite this undeniable characteristic of our supply chain, the relationship that exists between the raw hides and the life of the original animal leads the tanning sector to take an interest in any disputes regarding certain farming practices in terms of sustainability. The inclusion of cattle farming among the presumed causes of deforestation and land conversion falls within this context and pushes the leather supply chain to also consider this aspect in its sustainability parameters.
Aware of these critical issues in the fully transparent management of supply chains upstream of the tannery, especially in some areas of the globe particularly at risk of deforestation, for over 15 years UNIC has supported the tanning industry and the entire supply chain in its projects and actions to eliminate possible links to agricultural holdings created or developed through illegal deforestation practices (particularly in South America).
Part of these traceability objectives was pursued through collaboration with the non-governmental organisations NWF (National Wildlife Federation) and WWF (World Wildlife Fund), which led to the DCF (Deforestation and Conversion Free) Leather Project in 2019. The Project aims to track farms through a mapping system to confirm that they are not located in areas of South America affected by illegal deforestation.
Furthermore, in collaboration with CICB, the Brazilian tanners’ association, UNIC has encouraged dialogue and partnership between ICEC and the National Wildlife Federation. This has made it possible to develop a complete evaluation system to be applied to raw hides coming from the Amazon (Brazil and Paraguay) to be integrated with ICEC TS 410 and ICEC TS412 certifications: these are issued at the same time as the entire supply chain’s adoption of public procurement policies based on the Deforestation and Conversion Free DCFL criteria.
The New Legislation against Deforestation – The EU Anti-deforestation Regulation no. 1115/2023 (EUDR)
The European Union has based its political action on environmental, economic and social sustainability since 2019. To this end, the European Green Deal was adopted, in the wake of which the EU biodiversity strategy for 2030, the EU forestry strategy and the farm-to-fork strategy were subsequently outlined, culminating in Anti-Deforestation Regulation no. 1115/2023 (EUDR). This last measure aims on the one hand to create an incentive for companies operating in the common market to avoid sources and suppliers at high risk of deforestation, forest degradation and illegality, and on the other commits the European Commission to collaborate with countries assessed as having high risk so that, through targeted investments and policies, they can improve their risk profile in the future.
The regulation imposes stringent obligations on European operators who market and place the products affected by the standard on the EU market for the first time, including bovine leather (ex CH 4101, 4104, 4107), requiring operators to verify, through ‘due diligence,’ that the aforementioned goods come from areas in which no phenomena of deforestation, forest degradation or illegality have occurred after 31 December 2020. To fulfil these obligations, operators must obtain the geolocation data of all the plots in which the raw materials and products involved have been produced: if the due diligence has a positive result, operators enter the geolocation data into an IT system created and managed by the EU Commission (still in the testing phase) and, upon completion, present the relevant declaration certifying the success of the analysis conducted. If the due diligence instead has a negative result, the operator will have to refrain from marketing the affected products.
In practice, the EUDR requirements will require tanneries to know, with a previously unthinkable granularity, the geolocation data of all the establishments in which the cattle was kept, including when it was alive (farm(s), slaughterhouse, other establishments that have treated/marketed the cattle hides upstream of the tannery, any tanneries).
All this without considering the fact that bovine leather was included in the list of products affected by the Regulation without any impact assessment analysis (to evaluate all the possible consequences) by the Commission, and unfairly, because bovine leather is a an Animal By-Product (EU Reg. 1069/2009), i.e., waste from the food industry that tanneries recover (thus avoiding its disposal as waste). Given their minimal value compared to the animal, the raw hides are therefore not a driver, nor a cause of cattle breeding, and cannot even be considered a driver of any deforestation caused by cattle breeding. Thus the reasoning behind its inclusion in the EUDR Regulation is missing.
While for leathers produced in EU territories, the animal tracking already present for health and food safety (meat) purposes could support activities aimed at complying with the EUDR, in almost all non-EU areas from which the bovine raw hides imported into the EU come from, to date (June 2024), the creation and implementation of the traceability required to comply with the EUDR requirements is substantially impossible, both due to the typical characteristics of the meat supply chain in those areas, and for reasons related to confidentiality of the tracking data, and in general, the minimum value of raw hides at the slaughterhouse (never forget that it is a simple waste product that is recovered, an aspect of circularity which is the basis of the material’s sustainability).
Therefore, the strong risk is that the EUDR will transform, at best (EU), into a useless increase in traceability costs, and at worst (extra-EU), into a useless total block on leather imports in Europe.
Similar regulations are also currently under discussion in the United Kingdom and the USA, but the approach in these cases appears more substantial and pragmatic, and takes greater account of the concrete purposes and feasibility of the requirements.
As the inclusion of bovine leather in the scope of the EUDR regulation took place without the EU Commission carrying out an impact assessment on the consequences these provisions would have for European companies (the only case among the products included in the regulation), the Scuola Superiore Sant’Anna of the University of Pisa conducted a cross-sectoral study on the potential repercussions of this inclusion for the leather sector.
The study, entitled ‘Socio-economic and Environmental Analysis of the Effects of Regulation 2023/1115/EU on the European Leather Sector’, which is intended to become a crucial resource in the future revision of the European Deforestation Regulation (EUDR), is available below: