Environment

COTANCE Position Statement
COTANCE Council meeting – Paris, 13 June 2008

The representatives of the Tanning industry of Italy (UNIC), Spain (CEC-FECUR), Germany (VDL), France (FFTM), Sweden (SG), United Kingdom (UK Leather Federation), Netherlands (FNL), Switzerland (VSG), Belgium (UNITAN), Portugal (APIC), Greece (HTA), Bulgaria (BULFFHI), meeting in Paris for the COTANCE Mid-Year Council, reviewed the sector’s preparedness with regard to REACH and expressed their satisfaction with the initiatives launched by a core group of members having developed practical tools for a smooth transition to the new supply conditions of chemicals for Europe’s leather industry.

UNIC (Italy) has produced an interactive computer programme facilitating the sector’s companies to dressing their inventories of substances and generating automatically required ratios and data as well as the relevant correspondence for REACH communications up and down the supply chain.

VDL (Germany) has developed the concept and structure of the use and exposure scenarios that the sector requires for assessing within REACH the safe use of chemical substances in tanning processes and the exposure scenarios during the life-cycle of the substances used. A number of exposure scenarios for certain sub-sectors have already been dressed.

FFTM (France) has created a databank of chemical substances potentially used in tanning processes where to find relevant substance information for REACH evaluation and reporting needs for securing the continued intended use in tanneries of those sector specific substances. The databank is hosted at CTC (the sector’s Lyon based technology center).

CEC-FECUR (Spain) has taken responsibilities in the sector’s standardization activities for chemical test methods within CEN TC 289 Leather.

European tanners using these tools are equipped to face the forthcoming REACH downstream user challenges. Their customers in the footwear, clothing, leathergoods, upholstery or car industries can rest assured of quality leather supplies by responsible companies meeting REACH Standards.

The COTANCE Council expressed, however, concerns over the loopholes in the REACH legislation with regard to the import into Europe of leather articles containing substances whose use has been banned. Randomly collected leather articles tested in Europe’s leather technology centers reveal an increase in frequency of imported products failing to meet legal restrictions for azo-dyes, PCP, formaldehyde or CrVI. Europe’s Tanners consider that customs controls at the border and market surveillance by public authorities are today completely inadequate for securing European consumers safe imported leather articles. These shortcomings in Europe’s legislation risk nullifying the expected benefits of REACH in terms of consumer safety and spread suspicion among consumers over the product leather as such, harming thus also those operators fully complying with REACH.

In this context, COTANCE recognises the value of the initiative launched by ACTE (see note hereunder) and expresses its readiness to cooperate in initiatives that promote best practice not only by industry but also by public authorities.

COTANCE has, furthermore, decided to coordinate an initiative aiming at assessing the extent of the national consumer markets of leather articles at risk to evidence non-compliance with European standards. It invites all members to participate developing representative test screenings, and collecting and reporting evidence on test results in order to dress a European picture of the phenomenon and requesting appropriate action by public authorities in defence of the image of leather.

Note : ACTE represents the European territories with a strong presence of industries from the Textile, Clothing or Leather sectors, also known as fashion sectors. ACTE is the Association of European Textile Communities, (ACTE President is Mr Teo Romero). ACTE has been constituted in 1991 in Guimarães (Portugal) and covers today over 70 members from 6 EU Member States plus Croatia.

Under the LIFE Programme, AIICA has developed a leaflet and a DVD on an alternative to NPE's sheepskin degreasing. For further information, please visit AIICA's web site under "projects - Eco-degreasing". 

Rapex, safety alerts for non-food products

The EU Commission has just published a summary of the "safety alerts" Member States of the EU are obliged to send it about dangerous non-food products, under the Community early warning system Rapex. This summary will be published every week on the Commission's Internet site which will also carry quarterly statistics on Rapex notifications.
It is worth noting that Rapex was shored up by the new directive on general product safety (directive 2001/95/EC modifying directive 92/5/EC), which entered into force last January. Safety alerts for foodstuffs and animal feed are carried out via another early warning system.
In a press release, David Byrne, Commission of health and Consumer Protection, said:"one of the most important objectives of consumer protection policy is to protect consumers of all ages against shoddy, unsafe products. Providing information to the public about product hazards is essential to achieve this objective."

Environmental Communication from UNIC

In December 2003, in the framework of the Italian Presidency of the European Union, Milan hosted the 9th Conference of the Parties on Climate Changes, the most important international summit on environment after the one in Johannesburg in Autumn 2002. The conference was organised by the UN and the Italian Ministry of Environment.

On December 12th, 2003, closing date of the summit, the Italian government presented the environmental policies of the Italian tanning sector as an international example of excellence in environmental management. Contents of the first Environmental Report of the Italian tanning industry and results of efforts and investments of the past years were presented, together with possible future objectives.

The event represented a part of wider strategies of environmental communication, which aim at the valorisation of the ethic and environmental content of leather correctly produced and at the comparison with international competitors.

ETAD Information note related to Azo-dyes: 

In 2002 COTANCE reached an agreement with ETAD (Ecological and Toxicological Association of Dyes and Organic Pigments Manufacturers) on an information note regading azo-dyes and cooperation regarding the compliance with the proposed 19th Amendment to Directive 76/769, which restricted the use of certain azo dyes, restrictions that apply to textile and leather articles.

ETAD and COTANCE signed an Information Note and the two Appendixes that are annexed to it: one containing a diagram with a decision tree regarding with the “Review by the dye manufacturer of product range” and the other a “Model declaration of compliance with the restriction of certain azo colorants under the 19th Amendment to Directive 76/769/EEC”. Through this document, they promote best practice and recommend a number of measures to minimise the harmful effects of false positives. These measures are the result of certain inefficiencies of the current analytical method, which for instance doesn’t differentiate between a restricted 4AAB (4-aminoazobenzene) dye and an unrestricted dye.

As a result of this cooperative effort throughout the leather value chain, we pursue to inform dye suppliers, manufacturers, customers and retailers of finished leather articles and regulatory control authorities of this situation, so that tested articles are not concluded to be non-compliant.

For further information on this note: http://www.etad.com/news.html

IPPC

- COTANCE Document on BAT’s economic viability and their effect on competitiveness for SME’s - the Leather sector 
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- Document on IPPC for tanneries: download here .
- Report on the final draft dated March 2001 at the 9th IEF meeting, by Ineke Jansen, European Commission: download here .

COTANCE signs UNEP's declaration on cleaner production

On 29 April 2002, in Prague, Mr Gonzalez-Quijano, Secretary General of COTANCE, signed the International Declaration on Cleaner Production on behalf of his association.

The International Declaration on Cleaner Production is a commitment to the goal of sustainable development by the bodies who are signatories to it. It was formulated by the United Nations Environment Programme (UNEP) in order to eliminate pollution before it is created, rather than clean up the damage caused. 

Following a Council decision taken in 2000, COTANCE had decided to become a signatory to the UNEP declaration. In signing up, the European Tanning Industry makes public its commitment to favour pollution prevention and cleaner production. Indeed this is already a reality in most of the European Tanneries and should therefore be communicated to the general public by all available means, first by signing the UNEP declaration and then, by further implementing and widely disseminating its principles (see also article on COTANCE report on sustainability).

COTANCE submits a report on Sustainability to UNEP 

The COTANCE report for the World Summit on Sustainable Development (Johannesburg) is an unprecedented achievement of the leather industry. Europe's tanners participate in the reporting exercise of UNEP with regard to the three pillars of sustainability. This is a contribution to the global leather industry because it sets a benchmark against which to measure achievements in terms of sustainability and a yardstick in the quest for sustainability of the tanning industry

You may download the COTANCE report directly on UNEP's web site.