Confédération des Associations Nationales de Tanneurs et Mégissiers de la Communauté Européenne
COTANCE
COTANCE, Confederation of National Association of Tanners and Dressers of the European Community, is the representative body of the European Leather Industry.
ID: 077706416598-79
Lobbying Activity
Meeting with Esteban González Pons (Member of the European Parliament)
12 Nov 2025 · The Regulation on Deforestation-free Products
Response to Circular Economy Act
5 Nov 2025
Please, find the feedback of COTANCE attached.
Read full responseMeeting with Valentina Schaumburger (Cabinet of Executive Vice-President Stéphane Séjourné)
24 Jun 2025 · Introduction of the leather sector
Meeting with Aurel Ciobanu-Dordea (Director Environment)
12 Jun 2025 · Environmental footprint allocation at slaughterhouse level
Response to Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation)
12 May 2025
The Confederation of National Associations of Tanners and Dressers of the European Community (COTANCE) represents the European tanning sector (+/- 1500 tanneries and 30,000 workers). It gathers 10 national member organizations (DK, FR, DE, HU, IT, NL, PT, ES, SE, UK) accounting for some 90% of Europes leather production. With 25% of the sectors worldwide turnover, it is an important player in the leather market. COTANCE contends that leather is not a driver of deforestation! We request that hides, skins and leather of cattle (ex 4101, ex 4104, ex 4107) be excluded from Annex 1 of the European Unions Regulation 2023/1115 on deforestation-free supply chains (EUDR) for the following facts: -Lack of impact assessment: The inception impact assessment of EUDR only covered beef but did not cover leather. It said that leather should be specifically assessed at a later stage, which has not happened yet (SWD(2021) 326 final, p.33 footnote 99). The inclusion of hides, skins and leather in the scope is arbitrary, as it did not follow the EU better regulation principles. -Academic intelligence: Studies conducted by researchers of the Montana State University (2021) clearly establish that the demand of leather has no influence on the supply of cattle hides (https://tinyurl.com/4pvxfm6x) and those of the SantAnna School of the University of Pisa (2024) have proven that there is no causal link to be found between leather and deforestation in the scientific literature (annex). -EU tanning SMEs are unable to drive traceability of hides & skins worldwide: Nobody rears cattle for their hides/skins. As a by-product, cattle hides represent only a marginal fraction of the animals value (1-2%). Yet, with dairy not in the EUDR scope and the EU hardly importing any beef due to the CAP, the EUDR expects that traceability of extra-EU cattle worldwide is put in place by EUs tannery SMEs. -EU Tanners have no leverage to bring extra-EU suppliers of cattle hides, skins and leather to implement cattle traceability: The EU imports 40% of all its needs in tannery raw materials from over 100 countries. These EU family businesses have no leverage whatsoever on their bigger counterparts in the supply chain and are not in a position to influence them implementing of a traceability system for cattle in foreign countries. The Jeff Bezos Foundation estimated full cattle traceability in Brazil to cost some 5-6 USD per animal. When the price of a skin (5-6 USD) equals the costs of fulfilling the traceability requirements, assuming that SMEs will be able to push large companies for the implementation of traceability systems for hides and skins is not realistic. -The fact that no downstream leather products fall under the EUDR scope is a death sentence for EU leather businesses: Cattle is an EUDR commodity with an incomplete set of derived products: No dairy products, gelatin or collagen, pet food or any other derived products than meat and leather. Downstream leather products have not been put under the scope of the EUDR (shoes, garments, gloves, leather goods, furniture or car interiors), while downstream products of other supply chains are in the scope. Extra-EU imports of leather products and all other cattle derived products do not have to comply with EUDR requirements. This will push production, SMEs and workers in the EU out of business while this sacrifice will have no effect on curbing deforestation. Implementation of the EUDR in its current form will lead to the closure of companies and job losses both in the EU leather sector and in third countries where the leather industry is a source of jobs and wealth. In conclusion, COTANCE claims that keeping hides, skins and leather in EUDR Annex 1 is nonsensical, wont contribute to curb deforestation and will have a devastating impact on the EU tanning industry. Consequently, we request that cattle hides, skins and leather be withdrawn from Annex 1.
Read full responseMeeting with Aurel Ciobanu-Dordea (Director Environment)
8 May 2025 · Exchange of views on circularity in the leather industry
Meeting with Alisa Tiganj (Cabinet of Commissioner Christophe Hansen) and European farmers and
30 Apr 2025 · • ELV five recommendations for the Vision for the Future of EU Agriculture and for the mandate • Presentation of ELV (European Livestock Voice) • Exchange of views: Vision for the future of Livestock • EU Trade policy review: State of play
Response to Single Market Strategy 2025
31 Jan 2025
COTANCE, representing the European Tanning and Leather industry, welcomes the European Commission's initiative to modernize the Single Market strategy. The European leather sector faces significant challenges due to barriers within the EU Single Market that stem from - lack of harmonisation of national leather authenticity and labelling rules existing in at least 6 EU member States; - lack of sound cut off rules for simplifying allocation rules in the EU Environmental Footprint initiative - an impact below 3.5% should qualify for a 100-0 cut-off; - lack of enforcement of EU Reach legislation at the EU borders; - lack of consultation of stakeholders and specific consideration in sector relevant impact assessments (Taxonomy, Deforestation); but also increasingly complex and fragmented regulatory requirements. These issues place a disproportionate administrative burden on tanning SMEs, which often lack the resources to navigate this complexity, resulting in a catastrophic loss of competitiveness. Critical information about the scope of legislation in the Textile ecosystem Strategy is often unclear or not easily accessible, leading to confusion and missed opportunities. Moreover, fragmented benchmarks, inconsistent certifications, exacerbate the situation. These challenges create significant obstacles for SMEs, which lack the economies of scale to absorb such inefficiencies. The costs of a fragmented internal market are immense, as highlighted in the Draghi and Letta reports. These analyses underscore how regulatory divergence and administrative inefficiencies lead to higher compliance costs, reduced productivity, and lost opportunities for businesses to scale up. For the highly globalised and trade intensive tanning and leather industry, such fragmentation significantly impedes the ability to get necessary raw materials supplies, leverage economies of scale, and innovate. The name of "Textile ecosystem" is misleading and does not allow to understand businesses and public authorities what sectors it comprises, penalising leather and leather products missing opportunities. This leads to SMEs are disproportionately affected, as they often lack the resources to adapt to complex and inconsistent regulatory landscapes. A fully integrated single market would unlock potential for growth, enabling businesses to compete more effectively and contribute to Europes economic and social priorities, including sustainability. The administrative and regulatory burdens caused by market fragmentation critically undermine the global competitiveness of EU tanning and leather companies. Operating in a highly globalized and trade-intensive sector, these businesses already face intense competition from low-cost producers outside the EU. Inconsistent rules and costly compliance measures (EUDR) further increase production costs and erode profit margins, making it harder for EU companies to compete internationally. This is particularly detrimental as tanning and leather companies in other regions often operate under less stringent regulations, allowing them to offer lower-priced products in the EU and abroad. Without decisive action to reduce barriers and harmonize regulations, European tanning and leather companies risk losing market share both within the EU and globally, stalling innovation and growth. The administrative burdens imposed by fragmented regulations (CSRD, CSDDD), inconsistent enforcement, and divergent national policies (LCA) severely impact SMEs and leather companies operating within the EU Single Market. Addressing these barriers requires harmonized frameworks, streamlined compliance processes, and robust enforcement of Single Market principles. Reducing these burdens would enable SMEs to focus on growth, innovation, and sustainability, fostering a stronger, more integrated European tanning and leather industry.
Read full responseResponse to Joint European degree
31 Jan 2024
On behalf of the TCLF Skills Alliance, COTANCE is pleased to respond to this Call for Evidence and provide our joint statement on the Joint European Degree Initiative package in the attached document.
Read full responseResponse to Revision of EU rules on textile labelling
28 Sept 2023
COTANCE is pleased to respond to this call for evidence and provide its contribution to the review of the Textile Labelling Regulation in the attached document.
Read full responseResponse to Review of the de minimis aid Regulation
25 Jul 2022
COTANCE représente l'industrie du cuir à l'échelon européen. Ce secteur est constitué d'environ 1600 entreprises employant directement 33.000 travailleurs (1.783 / 34.500 en 2012). Avec une dimension moyenne de 21 emplois par entreprise, il s'agit d'un secteur composé en grande partie par de PME et TPE. La transformation en cuir de la peau animale, résidu de la production de viande, génère en Europe un chiffre d'affaires annuel de quelque 7.380.000 EUR, ce qui rend ce secteur du recyclage, l'un des plus prospères de l'économie circulaire.
Ce secteur est toutefois exposé à une rude concurrence extra-communautaire par des entreprises qui jouissent d'un soutien public important par le biais de restrictions à l'exportation de matières premières (ce qui équivaut à une subvention sur le prix des peaux dans le marché ouvert) et de soutiens financiers divers. Aussi, la pandémie du Covid-19 a eu un impact fort négatif sur le secteur des tanneries-mégisseries européennes qui ont perdu quelque 30% de leur chiffre en moyenne.
COTANCE se réjouit d'apporter sa contribution dans le cadre de l'appel à contributions lancé par la Commission européenne en ce qui concerne la révision des règles sur les aides de minimis qui expirent le 31 décembre 2023. Le règlement de minimis régit les aides d’État de faible montant qui sont de ce fait exemptées de contrôle car elles sont considérées comme n’ayant aucun impact sur la concurrence et le commerce dans le marché intérieur de l’Union européenne; les États membres de l’Union Européenne n’ont donc pas besoin de les notifier à la Commission européenne.
COTANCE estime que le plafond de 200 000 € devrait être porté à 500 000 € car il ne correspond plus à la réalité économique.
Ce montant de 200.000 € n’a plus évolué en 15 ans, sauf situations exceptionnelles, lesquelles se sont multipliées. Ainsi pour les années 2009, 2010, 2011, 2020, 2021 et 2022 - pas moins de 6 années et plus du tiers de la période concernée – le plafond de minimis a été remonté à 500 000 €, voire 800 000 € in fine par l’Encadrement temporaire du 19 mars 2020), sans engendrer de distorsions de concurrence majeures.
Il convient d’ailleurs de relever que c’est ce plafond de 500 000 € qui a été retenu par la Commission lors de l’élaboration d’un règlement de minimis applicable aux entreprises en charge d’activités de service d’intérêt économique général (Cf. règlement n° 360/2012 du 25 avril 2012) et pour lesquelles la Commission a considéré que le seuil de 500 000 € n’était pas de nature à affecter la concurrence.
En conclusion, ce plafond de 500 000 € devrait devenir la règle de droit commun applicable à toutes les entreprises ou, à tout le moins, être appliqué dans un premier temps aux PME.
Read full responseResponse to Sustainable Products Initiative
18 Jun 2022
COTANCE, the representative body of the European Leather-Making Industry, welcomes this opportunity to give its feedback to the Commission Ecodesign proposal.
Leather is the material that results from the recycling of hides & skins which arise as a residue (ABP) during slaughter of animals for human consumption. It is a perfect example of the circular economy. This industrial symbiosis avoids the accumulation of Cat 3 ABP Risk Material in the environment, the release of CO2 through putrefaction and the resulting leather reduces the need for fuel-based synthetic materials with their adverse environmental consequences. Leather production is a recycling operation; it is scientifically proven that demand for leather does not drive livestock production or slaughter, which is substantially driven by the demand for meat. The circular nature of leather needs to be acknowledged appropriately in the "recycled content" criteria (100%) of the Ecodesign rules..
Leather has its own Product Environmental Footprint Category Rules (PEFCR) which are currently being revised in the context of the Commission's EF Transition Phase. Leather is also treated as a separate product group in the EU Taxonomy rules. Leather is part, both of the Agri-Food and the Textiles ecosystems in the context of the EU industrial policy. The former addresses the availability and quality of the domestic raw material resources in the EU, the latter focuses on the optimisation of the generation of wealth and jobs with sustainable leather. European Leather is mostly made out of cattle hides and calf, sheep, goat or rabbit skins. To a minor extent (less than 1% of production), European tanners also tan the hides or skins resulting from hunting or, in the case of certain exotic skins, from breeding. Leather & leather products deserve to be treated separately under Ecodesign criteria and not be mixed up with Textliles simply because they are considered to be a part of the Textile Ecosystem. The differences between Textiles and Leather from an environmental point of view are also evidenced in the existence of separate IED BREF documents.
Only Leather is Leather! It is as important to keep the Leather product group separate from Textiles as it is to keep it separate from fakes or imitations that are made of other materials than leather. Ecodesign product groups ought to be homogeneous in terms of the nature of the material for avoiding unwarranted comparisons and possible penalising competitive situations or blunt discriminations.
Leather is a durable material. Under normal conditions of use products made with leather can last a lifetime, or more. It is important that the durability of leather and leather products is appropriately rewarded in the Ecodesign criteria. Their longer duration of service - which determines the product's environmental footprint - needs to be acknowledged appropriately.
Leather is reusable and repairable and safely reintegrates nature at the end of life. The example of a leather soled footwear best explains both, the biodegradation of the material at the end of the duration of service (holed soles), and the repairability of the good thanks to the use of leather (leather shoe components are stitched together and can be repaired or replaced when damaged).
The origin of leather is important. The place where the animals have been bred, the hides and skins were harvested and where the leather has been tanned are essential elements that determine the characteristics (technically and emotionally) of the material and the product made with it. Traceability requirements for leather need to be practical, applicable by SMEs, enforceable by authorities and backed by legislation that ensures the mandatory transmission of all the origin information through the supply chain. As to their disclosure to the public, risk criteria should determine when such information should be disclosed to consumers and competitors.
Read full responseResponse to Carbon Removal Certification
16 Feb 2022
Every year, on a global level, tanneries recover and valorise some 8 million tons of raw hides and skins from the food sector. Without the leather industry and its upcycling activity, this residual material would simply become waste. In the EU, there are still about 1.600 tanneries recycling the hides and skins generated for the production of meat for human consumption. This is a recycling process of materials classed as Animal By-Products (ABPs) in EU Reg 1069/2009, although their nature would rather qualify as "waste" according to the Commission Communication on Waste & By-Products. Contrary to a general modern belief, tanneries don't drive livestock production or slaughter as the value of the hide or skin is below 1% of the value of the animal. Leather production cleans up the act of the meat industry and provides an additional service to society by producing a durable material that is used in a wide variety of consumer products. Europe champions in the production of high quality leather under the most stringent environmental conditions and in sound social accountability.
If disposed of in landfills or incinerated as waste, hides & skins would release around 5 million tons of greenhouse gases.
That corresponds to the annual emissions of 1,087,400 average cars according to the US EPA emissions equivalencies calculator. According to the International Council of Tanners (ICT), about 40% of bovine hides are still thrown away worldwide. There is thus still a big potential to increase the avoidance of GHG through leather production.
The recovery and recycling of hides & skins by the leather industry reduces greenhouse gas emissions while creating a valuable and versatile product.
It is of utmost importance that the positive effect of leather in terms of durable strorage of CO2 is acknowledged by our authorities and consumers and that a robust methodology is developed for determining the concrete amounts stored in this bio-material. Furthermore, it is essential that the use of products that stock CO2 durably is given appropriate incentives. Finally, a robust methodology needs to be developed and adopted by our authorities to set default values for the longevity of products and materials storing CO2.
Read full responseMeeting with Frans Timmermans (Executive Vice-President) and European farmers and
31 May 2021 · Exchange on Farm to Fork Strategy with European Livestock Voice
Response to Environmental claims based on environmental footprint methods
31 Aug 2020
COTANCE represents the leather industry in Europe. European tanners supply leather to the most demanding value customers in the luxury, fashion, automotive and home decoration sectors. Leather products play an essential role in consumers’ every-day lives.
The European Tanning Industry is composed of nearly 1,600 companies and 33,000 workers and 7.4 billion Euro turnover, albeit there has been a gradual concentration over the last decade. The sector has traditionally been composed of family-owned small and medium enterprises but also includes large, listed multinational companies. The average size of a European tannery is currently 21 employees; in 2000, it was 24 employees. Today, the tanning industry in Europe represents a strategic segment of the manufacturing sector, thanks to the combination of tradition and continuous innovation. These characteristics have led the European tanning sector to become a global leader in terms of both value and of quality. The EU share of global turnover is the largest, at 30%, before China, Brazil, India and the other producers.
European tanners process all the main species (bovine - over 80% of production -, ovine and caprine) and supply for all the end uses for leather. The main market destination of leather has traditionally been the footwear sector. It is still the largest destination, accounting for 38% of European production. However, in recent years use in other products has increased, such as leather goods (22%) and car interiors (13%).
COTANCE welcomes the initiative of the European Commission to regulate the area of environmental claims and the opportunity to engage on the legislative proposal on substantiating green claims. It supports the objective to move towards a more harmonised approach for providing consumers with relevant, reliable and comparable environmental information, increasing simplification and reducing administrative burdens, especially for SMEs.
COTANCE would like to contribute the attached considerations to the inception impact assessment.
Read full responseResponse to Intellectual Property Action Plan
12 Jul 2020
COTANCE, the representative body of Europe's leather industry, integral part of the so-called "Textiles ecosystem" on which the EU is to roll out a strategy for preparing it for a circular and digital future, estimates that misdescriptions of products and piracy or theft of its collective trade mark, the "leather mark" (stylist symbol representing the hide of an animal) cost the sector up to 20% of its turnover, some 1.6 billion Euro annually.
The leather mark is a collective trade mark registered by the association of the Italian tanning industry (UNIC-Concerie Italiane) covering a number of important markets in the EU and other global markets, and it is also a Registration mark registered by the LeatherUK, the British leather trade association for its domestic market. Theoretically, these intellectual property rights should have given to their SME holders a protection similar to the one experienced by the famous "Woolmark" held by Australian hands. Unfortunately, this is not the case! EU IP rules do not offer the same attention to collective trade marks as they do to corporate trade marks. In certain EU Member States, association leaders have even been discouraged to further a collective trade mark protection where the name or the symbol to be filed is been considered to be an ordinary or common name. Leather is a common name, indeed, but this common name is associated to a number of conditions; its animal origin, its processing trough tanning, its intact internal fibrous structure, etc... and the sector's associations are the bodies holders of the duty to care for the proper use of the term and the symbol representing it.
Geographical Indications for non-agricultural products is also orphan of attention and care by EU authorities. The Roadmap refers to them timidly indicating that the Commission considers their feasibility. Leather, which is an industrial product issued from an agricultural origin, can not take advantage of the agricultural GI, and risks to be excluded also from due consideration in the current timid initiatives. Leather is an industry that has deep regional and local roots in a number of EU Member States (in Italy, in the Veneto region places such as Arzignano, in Tuscany, Santa Croce, San Miniato, Fucecchio, in Campania the cluster of Solofra; in Spain in Catalogne, the clusters of Vic or Igualada, in Valencia, the area of Canals; In France the region of Occitanie and the area Millau or Graulhet; in Portugal the cluster of Alcanena; etc...) These are places will a long tradition and specificities that would deserve to be protected and promoted.
For all these reasons it is key that the EU reinforces its IP arsenal and offers the appropriate support and assistance, in particular for those IPs like Collective Trade Marks and Geographical Indications that can boost the competitiveness of Europe's SME's.
Read full response