Joint COTANCE-ETUF:TCL Position Statement
Introduction
The Social Partners of the European Leather Industry, in their Social Sectoral Dialogue Committee meeting held on 24 September 2010 in Brussels adopted the following contribution to the European Commission Consultation regarding the Raw Materials Initiative.
COTANCE and ETUF:TCL reaffirm their commitment to the principles of sustainable development, notably to the sustainable production and use of raw materials.
The three pillars of sustainability, economic, social and environmental, need to be fully taken into account.
Europe’s leather industry’s Social Partners fully respect the right of all nations to develop creating wealth and employment for their people. Industry can be an important lever for growth and jobs in many countries. The leather industry in Europe, however, wants to see the development of the industry follow sustainability principles.
•Policy Area: Defining critical Raw Materials
Criticality of a raw material at EU level as defined depends on variables (most of the other raw materials) that are not defined. Rapid identification of a supply shortage in a given raw material requires a more practical methodology. In the leather sector the supply of raw materials becomes critical when their prices hike abnormally.
Recommendations referring to the situation regarding raw materials in the leather sector are missing and would be highly opportune.
Raw material markets would merit to be analysed notably with regards to anticompetitive behaviours such as cartels.
•Policy Area: Trade
The 3 axes of the trade raw materials strategy reflect adequately the importance of trade but would need to be strengthened. Their implementation should be empowered with a clear definition and graduation of “all available instruments”
Priority should be given by DG Trade to cases of infringements of bilateral trade agreements (Morocco in the area of hides and skins and wet-blue).
SMEs, notably in the leather sector, are not specifically supported in their foreign investment strategies for securing raw materials. A sector approach would need to be developed in order to cover all industries in need from mining to wood including hides, skins and wet-blue.
•Policy Area: Development
International scrutiny over raw material production and trade in the various sectors including hides & skins would be the most powerful instrument for transparency.
The setting up of a multilateral competition authority with autonomous powers within the African Union and other agreements would be an ambitious and useful objective.
Ores, wood and other raw materials, such as hides and skins, could eventually be addressed if demanded by the respective industry.
•Policy Area: Regulatory framework
The implementation of regulatory options in the EU export rules regarding certain raw materials such as export restrictions in the area of bovine skins ought to be seriously considered by Member States and EU authorities.
Rules on management of animal by-products (hides and skins) should address the opportunity to set up conditions for recipient countries of a hygiene rules equivalent to EU standards.
Actions regarding the improvement of the quality of domestic raw materials (hides & skins) would be beneficial for enhancing domestic resource efficiency in the leather sector in the EU.
•Policy Area: Skills, R&D and Innovation
Better cooperation between companies, universities and public authorities in order to promote skills in the hides and skins sector could be fostered by specific programs targeting animal welfare, traceability and more efficient preservation techniques.
The highest positive impact on the security of supply of hides & skins could be achieved through an R&D action targeting the elimination of salt as a preservation agent in the EU.
Project partners at EU level would need to involve the Meat industry as well as all links in the leather value chain.
•Policy Area: Resource efficiency & Recycling
Leather can’t be recycled, but it can be recovered and valorised in other products or ultimately in energy generation. Research could target the identification of new applications for the raw materials in outworn leather articles.
Trade in used shoes has been identified as a major threat to the development of an indigenous footwear industry in developing countries.