COTANCE welcomes the opportunity to contribute to the European Commission’s Call for Evidence on the forthcoming Biotech Act II and strongly supports the objective of strengthening Europe’s bioeconomy and industrial biotechnology capacity.
At the same time, we underline that the European leather sector is an established, biobased value chain with multiple industrial biotechnology integration points and should be appropriately reflected in relevant policy considerations.
Leather as an established bio-based and circular material
Leather is inherently bio-based, as it is derived from animal hides and skins – natural, renewable raw materials that are unavoidable by-products of the meat and dairy sectors. If not valorised, these materials would require disposal and generate significant environmental burdens. Furthermore, no animal is slaughtered for its hide or skin, as these are by-products of the meat and dairy value chains.
The tanning industry transforms this residual biomass into a durable, high-value material (leather) used across multiple value chains. In doing so, it directly contributes to core bioeconomy objectives:
• resource efficiency, by utilising biomass that would otherwise be wasted;
• waste prevention, by avoiding landfill and associated emissions;
• value creation, by converting low-value residues into long-lasting products.
Globally, 8 million tons of hides and skins are recovered annually by the leather industry. Without this upcycling activity, this biomass would become waste, contributing significantly to greenhouse gas emissions. Leather also demonstrates key circularity characteristics:
• long service life, often spanning generations;
• repairability, supported by established repair ecosystems;
• biodegradability under appropriate conditions at end-of-life.
These properties make leather a benchmark material for circularity within the European bioeconomy.
Policy recommendation: The Biotech Act II should ensure that industrial biotechnology and biomanufacturing policy measures recognise and support applications that enhance the resource efficiency and circularity of established bio-based value chains through biotechnological processes, including the valorisation of animal-derived residual biomass.
Addressing the omission of leather in EU bioeconomy policy
Despite these characteristics, leather has not been explicitly recognised in previous EU Bioeconomy Strategies. COTANCE regrets that this omission persists and considers that the Biotech Act II provides a timely opportunity to correct this.
Supporting leather as a bio-based, circular material would enable the tanning sector to fully contribute to the EU’s objectives on sustainability, resilience, and strategic autonomy. Failure to do so risks overlooking one of Europe’s most established examples of industrial bioeconomy in practice.
Policy recommendation: The Biotech Act II should ensure that industrial biotechnology measures, including R&D support, scale-up funding, and market deployment instruments, explicitly include applications involving the biotechnological processing of animal-derived residual biomass, including leather, within established value chains.
Technology neutrality and avoiding unintended market distortions
COTANCE stresses that the outlook on Bioeconomy, and therefore the Biotech Act II must remain firmly technology-neutral.
Public funding, regulatory incentives, and market-shaping measures should not favour only specific materials or some emerging technologies at the expense of existing biobased value chains. In particular, there is a growing risk that policy frameworks may implicitly even prioritise newly developed alternatives, including even fossil-based materials, without adequately accounting for the environmental performance of established materials.
A level playing field requires:
• equal treatment of all materials based on robust scientific assessment;
• avoidance of restrictive support schemes targeting specific technologies;
• recognition of by-product-based materials as resource-efficient solutions.
Policy recommendation: The Biotech Act II should explicitly ensure technology neutrality across all measures, including funding, regulatory frameworks and market incentives, and avoid provisions that directly or indirectly privilege specific materials or production pathways over others without a comprehensive, life-cycle-based justification.
The Biotech Act II should include a biogenic carbon quantity assessment before favoring certain materials and processes. Such assessment could be based on the existing CEN standard (CEN/TS 16640) differentiating materials’ carbon (14C) content between biogenic and fossil carbon. This would ensure that the Biotech Act II favours materials that are truly bio-genic, avoiding false claims as per Green Claims Directive (2023/0085 (COD)).
Biotechnological innovation within the leather value chain
The leather sector is not only a user of biomass but also an active platform for biotechnology applications. Significant opportunities exist for integrating industrial biotechnology into leather value chains, including:
• valorisation of fleshings and trimmings into collagen, gelatine, peptides, and other bio-based intermediates;
• conversion of tanning by-products and waste streams into bio-based chemicals, fertilisers, or energy carriers;
• development of bio-based processing agents, including enzymes and alternative crosslinking systems;
• biotechnological treatment of effluents to improve environmental performance.
These pathways demonstrate that the leather sector can act as a biorefinery-type ecosystem, where multiple outputs are derived from a single biomass input, maximising resource efficiency. Supporting such innovations would align fully with the objectives of the Biotech Act II and deliver tangible environmental and economic benefits within existing industrial structures.
Policy recommendation: The Biotech Act II should explicitly support the integration existing bio-based value chains, including the leather sector, into industrial biotechnology, through targeted research and innovation funding, pilot and scale-up support, and measures facilitating the development of biorefinery-type approaches for the valorisation of residual biomass and industrial side streams.
Full life-cycle assessment as the basis for policy decisions
COTANCE strongly supports the development of harmonised sustainability assessment frameworks. However, these must be firmly grounded in full life-cycle assessment (LCA) methodologies.
Partial or simplified metrics risk systematically disadvantaging durable, long-life materials such as leather, while favouring short-lived alternatives with higher replacement rates and cumulative environmental impacts.
Recent experience with the Product Environmental Footprint Category Rules (PEFCR) for Apparel and Footwear illustrates this risk. Current durability assumptions – such as a default service life of 100 uses – fail to reflect the actual lifespan of leather products, thereby penalising long-lasting natural materials while favouring fast fashion alternatives. This highlights the need for more accurate, material-sensitive methodologies.
Key elements should include:
• product longevity and durability;
• reparability and reuse;
• end-of-life biodegradability;
• correct allocation of environmental burdens for by-products.
In particular, the treatment of by-products such as hides and skins in LCA methodologies should reflect their nature as residual outputs of other value chains. Allocation approaches should be designed to incentivise their efficient valorisation and support circular use of biomass. Appropriate allocation rules are essential to promote the efficient use of residual biomass.
Policy recommendation: The Biotech Act II should ensure that sustainability assessment frameworks and related policy measures are based on comprehensive, harmonised LCA methodologies, including accurate durability assumptions and appropriate allocation rules for by-products, and avoid the use of simplified metrics or default values that risk distorting comparisons between materials.
Market uptake and fair competition between materials
Measures to stimulate demand for bio-based products – including public procurement, labelling, and standards – must be based on performance criteria rather than material origin or perceived innovation.
Durable materials that extend product lifetimes and reduce replacement rates provide significant environmental advantages that must be fully reflected in policy frameworks.
At the same time, misleading claims or terminology that blur the distinction between genuine bio-based materials and synthetic or partially bio-based alternatives risk distorting consumer perception and undermining trust.
Policy recommendation: The Biotech Act II should ensure that market uptake measures, including public procurement criteria and labelling frameworks, are based on objective performance indicators such as durability and life-cycle impacts, and support the development of clear, science-based definitions and rules to prevent misleading environmental claims and ensure fair competition between materials.
______________________________________________________
COTANCE supports the ambition of the Biotech Act II to strengthen Europe’s leadership in biotechnology and bioeconomy. By building on Europe’s existing strengths – including established value chains such as leather – the Biotech Act II can deliver a truly competitive, sustainable, and resilient European bioeconomy.