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Substances in Articles

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.