LCA e PEF

LCA Life Cycle Assessment

For a comprehensive evaluation of the environmental impacts associated with product creation, the international scientific community has developed the Life Cycle Assessment (LCA) methodology. LCA studies the environmental aspects and potential impacts throughout a product’s entire life cycle—from raw material acquisition to production, use, and disposal (ISO 14040, 2006).

Since LCA calculations must, by definition, be implemented on all processes that contribute to the creation of the product, one of the most important factors on which an agreement must be reached at an international level is the definition of what are known as ’System Boundaries,’ which define the process that must be considered as the initial phase of the product itself (the cradle) and the one that determines its end (the grave). The tanning process includes various chemical and mechanical processes which have the aim of transforming organic matter that can rot (raw hides) into products with high added value, strategic for sectors such as footwear, fashion, furniture and transport.

Defining system boundaries is crucial for accurate LCA assessments. One of the most debated aspects within the tanning sector is whether to include or exclude upstream processes such as agriculture and animal breeding, which can account for up to 80% of the carbon footprint and 99% of the water footprint in leather production.

A key consideration in LCA calculations is the classification of raw hides: are they waste from the meat industry, or are they co-products/by-products? If classified as waste, the environmental impact would be fully attributed to the primary product (meat), excluding agriculture and livestock from leather LCA studies.

International regulations primarily recognize raw hides as by-products of the food industry. European legislation, such as Regulation 1069/2009 and Regulation 142/2011 on animal by-products, supports this classification. From this perspective, it becomes essential to further analyze the nature of the different processes that led to the generation of the by-product. In particular, the scientific literature on LCA, available at an international level, addresses the case of co-products (by-products) of renewable origin, defining it as a highly complex technical problem which, however, is easily understandable by answering two questions:

Are raw hides by-products of renewable origin?

and

Does leather replace, at least partially, other materials?

To answer the first question, a generic co-production process must first be analysed. In every process that generates one or more co-products (by-products), there is in fact a product defined as determining. The determining product is the one which precisely determines the production volume of the process itself. If it were not for the production of that product, the process would not start. There can be only one determining product at a specific time. In the specific case of the tanning supply chain, over 99% of the raw material used (raw hides) has bovine, sheep and goat origin, the availability of which is linked to the consumption of meat and, consequently, to the dynamics of animal slaughter. It can therefore be stated that the determining product is not the leather, but the meat.

Given the definition of renewable resource as ’a natural resource with the ability to reproduce through biological or natural processes and reproduced with the passage of time,’ it can be stated that raw hides are almost entirely by-products of renewable origin.

Regarding the second question, given the composition of the materials made using finished leather, it is easy to state that the leather itself provides the main alternative to other materials (mostly synthetic) in the creation of objects (footwear, leather goods, clothing, car interiors, upholstery).

In conclusion, if raw hides originate from animals raised for meat, dairy, or wool production, the system boundary should be set at the slaughterhouse—where initial preservation processes (e.g., cooling, salting) prepare hides for tanning. This implies that the environmental impacts of agriculture and livestock should be assigned only to primary products, not leather.

However, some major international LCA projects, such as those related to Product Environmental Footprint (PEF), Environmental Product Declarations (EPD), and ISO standards, have not fully adopted this approach. Despite raw hides being classified as by-products, these studies allocate a portion of livestock-related environmental impacts to leather due to its economic value.

Product Environmental Footprint (PEF)

In 2013, the European tanning industry, including Italy, participated in the pilot phase of the European Commission’s Single Market for Green Products initiative. This initiative aimed to develop a unified methodology for assessing the environmental impact of products sold within the EU—the Product Environmental Footprint (PEF). Each sector was tasked with establishing specific assessment rules, known as Product Environmental Footprint Category Rules (PEFCR).

The PEF is a company (self) diagnosis tool, which provides a criterion for identifying the environmental impacts of processes and products, with the general objective of reducing them, considering the activities of the supply chain (origin of raw materials, production, use and final waste management).

The methodology evaluates 16 environmental impact categories using the most reliable calculation methods, and allows companies to delve deeper into the origin of environmental impacts and plan possible improvement actions. However, these actions can only concern the phases over which the tannery has or can have direct control and not the impacts deriving from agriculture and livestock farming.

The evaluation of the PEF requires, as mentioned previously, an analysis of the entire product chain for which, in addition to the processes over which the tannery has or can have direct control, all the upstream phases must be considered, starting from animal husbandry. A portion of their impact must therefore be allocated to the various resulting products, following pre-established rules based on different criteria.

For the reasons described above (by-product of animal origin and impossibility of influencing the upstream phases, agriculture and breeding), in the context of the discussion on the boundaries of the PEF, the tanning sector has instead supported ’zero allocation’ for raw hides.

However, the European Commission has established that all products with an economic value cannot be treated as waste, thus definitively rejecting the ’zero allocation’ proposal and forcing the sector to bear a portion of the environmental impact of the phases upstream which, although negligible in terms of percentage (on the total impact of animal breeding), appears to have an enormous weight for some categories of environmental impact.

The accuracy of PEF calculations heavily depends on the availability of primary data or the quality of commercial environmental databases. In the absence of precise upstream data (e.g., on livestock farming and feed production), default values from databases introduce significant approximations, often leading to exaggerated and unrealistic environmental impacts.

In 2023, UNIC continued participating in the PEF initiative by joining its review project. However, due to the European Commission’s reluctance to reassess allocation rules with updated data and the continued reliance on unreliable default values, UNIC made the difficult decision in 2024 to withdraw from the project. At present, UNIC no longer supports the PEF initiative, as it does not accurately reflect the environmental impact of leather production.

UNIC is currently working on other alternative schemes capable of analysing and reflecting the life cycle of our product in a more faithful and objective manner, always based on the collaboration of all the subjects involved in the value chain, through the sharing of data, with important mutual benefits in terms of reliability, reproducibility, and comparability of results.