Mike Redwood


International Leather Maker

If you are not aware of the European Union’s (EU) new laws on deforestation-free products, often referred to as EUDR, then you are remarkably out of touch. Worse, it may mean you have not bothered to join your national leather trade association, which will have been working hard on the subject and will have produced lots of guidance about the challenges it creates for anyone selling cattle hides, crust or finished leather in Europe. If I have understood it correctly, finished products made from the leather are currently not included in the EUDR legislation.

The EU is dedicated to fighting for the environment, be it climate change or dangerous chemicals. This is admirable but it does seem far too prone to make errors in the science. In this instance, it has doubled the error of bad science about leather by not listening and being thoughtless about the nations to which the rules apply – a big mistake when geopolitics is reshaping the world and the EU wants to keep its friends.

Does the EU want all agriculture run by giant business?

While environmental bodies have been supportive, these new rules have upset governments with good programmes and where more cooperation is required, rather than a legal imposition that feels like a deliberate trade barrier. Throughout the world, there is an outcry at the damage that will be done to small farmers by imposing such a demanding and inequitable system.

The legal structure and the technical mapping, geolocation, risk assessments and due diligence statements required mean large organisations with extensive resources will win. Does the EU want all agriculture run by giant business? Is it disinterested in the subsistence farmer, the pastoralists and rangeland regions with all their environmental significance?

The law in question is Regulation (EU) 2023/1115 of the European Parliament and of the Council of May 31, 2023, on deforestation-free products (EUDR). It lays out detailed requirements for anyone trying to sell seven commodities into Europe.

Beef, cocoa, coffee, palm oil, soy, wood and natural rubber are the commodities involved and, if you read down, you see derived products from these include leather, furniture and chocolate. In Annex 1, we have the cattle details with hides, part-processed hides and leather all covered with leather “being of cattle, further prepared after tanning or crusting, including parchment-dressed leather, without hair-on, whether or not split”.

Non-compliance bans importing those products into the EU. For companies of 250 employees or more, the rules start from the end of this year and, for smaller ones down to a turnover of €2 million, from six months later. Already, palm oil and some timber products are being redirected away from the EU to countries without such restrictions. There are loud cries from small Ethiopian coffee growers and Asian rubber producers in Thailand, Malaysia and Cambodia to the Brazilian government, which feels disrespected. We must expect big areas of world trade to be reshaped – bad news overall for the EU and for EU tanners for whom compliance, where it is possible, will add to the price of their leather compared to the rest of the world – with limited evidence of global environmental benefit.

Even the EU itself has issues and 20 countries in the EU have followed the lead of Austria and asked for a postponement and partial rethink. They are worried about matters such as their own use of soya, loss of access to cocoa and worries about the difficulties the small coffee suppliers they rely on will have with compliance. It has been agreed to defer categorising supplier countries by their risk status but there is currently no indication of further concessions.

The wrong way to do it

Given that, in 2018, the Leather Product Environmental Footprint Category Rules (Leather PEFCR) were officially approved by the EU Environmental Footprint Steering Committee based on leather being a non-determining by-product (i.e. hides have no influence on whether cattle are kept for beef), it seems curious that another arm of the EU adds leather back in.

It is a tougher situation, too, to the extent that tanners are dependent on the farmer and meatpacker supplying honest information about where the animals have lived. Many beef cattle are moved to richer grasslands or feedlots for the last few months before slaughter, so this is not always straightforward. An initiative involving the Leather Working Group, World Worldlife Fund and Textile Exchange has been working on this project for some years and deserves support, rather than being usurped by this legislation.

COTANCE has been making it clear for some time that, since no beef cattle are slaughtered for their hide or skin (cattle extend to buffalo etc. in this definition), hides and leather should not be part of this. It is just bad science. “If leather is not a driver of cattle slaughter, it cannot be considered a driver of deforestation.”

UNIC, the Italian tanners’ association, spoke for all of us in saying they support the basic aims but hate the detail:  “The current wording of EUDR requires that operators selling bovine hides in the EU must verify that they come from non-deforested areas”. How? Through “the application of traceability tools that, to date, are totally inadequate, if not unavailable, and unsuitable to meet unnecessarily strict and stringent requirements”.

Regardless, tanners should all be finding the best ways to map the sources of raw materials and to be transparent about them. The EUDR is merely the wrong way to do it.


Follow Dr Mike Redwood on Twitter: @michaelredwood

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