COTANCE contribution to the Public Consultations initiative: EU rules to minimise deforestation & forest degradation – amendment of Annex I to the Deforestation Regulation
12 May, 2025
Brussels
Feedback reference - F3550979
The Confederation of National Associations of Tanners and Dressers of the European Community (COTANCE) represents the European tanning sector (+/- 1500 tanneries and 30,000 workers). It gathers 10 national member organizations (DK, FR, DE, HU, IT, NL, PT, ES, SE, UK) accounting for some 90% of Europe's leather production. With 25% of the sector's worldwide turnover, it is an important player in the leather market. COTANCE contends that leather is not a driver of deforestation! We request that hides, skins and leather of cattle (ex 4101, ex 4104, ex 4107) be excluded from Annex 1 of the European Union's Regulation 2023/1115 on deforestation-free supply chains (EUDR) for the following facts:
- Lack of impact assessment: The inception impact assessment of EUDR only covered beef but did not cover leather. It said that leather should be specifically assessed at a later stage, which has not happened yet (SWD(2021) 326 final, p.33 footnote 99). The inclusion of hides, skins and leather in the scope is arbitrary, as it did not follow the EU better regulation principles.
- Academic intelligence: Studies conducted by researchers of the Montana State University (2021) clearly establish that the demand of leather has no influence on the supply of cattle hides and those of the SantAnna School of the University of Pisa (2024) have proven that there is no causal link to be found between leather and deforestation in the scientific literature (annex).
- EU tanning SMEs are unable to drive traceability of hides & skins worldwide: Nobody rears cattle for their hides/skins. As a by-product, cattle hides represent only a marginal fraction of the animal's value (1-2%). Yet, with dairy not in the EUDR scope and the EU hardly importing any beef due to the CAP, the EUDR expects that traceability of extra-EU cattle worldwide is put in place by EUs tannery SMEs.
- EU Tanners have no leverage to bring extra-EU suppliers of cattle hides, skins and leather to implement cattle traceability: The EU imports 40% of all its needs in tannery raw materials from over 100 countries. These EU family businesses have no leverage whatsoever on their bigger counterparts in the supply chain and are not in a position to influence the implementation of a traceability system for cattle in foreign countries. The Jeff Bezos Foundation estimated full cattle traceability in Brazil to cost some 5-6 USD per animal. When the price of a skin (5-6 USD) equals the costs of fulfilling the traceability requirements, assuming that SMEs will be able to push large companies for the implementation of traceability systems for hides and skins is not realistic.
- The fact that no downstream leather products fall under the EUDR scope is a death sentence for EU leather businesses: Cattle is an EUDR commodity with an incomplete set
of derived products: No dairy products, gelatin or collagen, pet food or any other derived products than meat and leather. Downstream leather products have not been put under the scope of the EUDR (shoes, garments, gloves, leather goods, furniture or car interiors), while downstream products of other supply chains are in the scope. Extra-EU imports of leather products and all other cattle derived products do not have to comply with EUDR requirements.
This will push production, SMEs and workers in the EU out of business while this sacrifice will have no effect on curbing deforestation. Implementation of the EUDR in its current form will lead to the closure of companies and job losses both in the EU leather sector and in third countries where the leather industry is a source of jobs and wealth. In conclusion, COTANCE claims that keeping hides, skins and leather in EUDR Annex 1 is nonsensical, won't contribute to curb deforestation and will have a devastating impact on the EU tanning industry. Consequently, we request that cattle hides, skins and leather be withdrawn from Annex 1.
Feedback can be found: HERE