Confédération Européenne de l’Industrie de la Chaussure
CEC
To contribute to the growth and competitiveness of the footwear industry through different activities: A) Lobbying Maintain dialogue with EU institutions with a view to ensuring that the interest of EU footwear industry is taken into account at the appropriate level in the different EU policies and legislation. B) Information and promotion of EU joint initiatives to prepare companies for green and digital transition between associations, trade unions, technology and education centers. Coordinate Members’ activities in relation to the EU where appropriate. C) Research and Innovation Promote research on relevant topics such as technical, safety, social, and circularity aspects, digitalisation, new business models, etc. Identify EU funding opportunities. D) Strengh private-public collaboration accross the EU in the different policies. E) Increase international collaboration with worldwide footwear associations to promote free trade and a level playing field.
ID: 13497369622-37
Lobbying Activity
Response to Circular Economy Act
6 Nov 2025
Supporting Sustainable Materials, Repairability and Reconditioning The CEC believes that the CEA should adopt a broad approach that promotes not only secondary raw materials but also circular, sustainable and durable materials such as leather. Leather is inherently circular, produced from raw hides and skins that are by-products of the food industry. By transforming waste into a long-lasting material, leather contributes to resource efficiency and waste reduction. To achieve the CEAs objectives, legislation should encourage a move away from fast-fashion models. Instead, it should promote durable, repairable and reconditionable goods designed for long lifespans. Leather footwear represents a model of circularity: robust, repairable and durable, it outperforms synthetic or plastic-based alternatives both environmentally and functionally. The CEC welcomes the promotion of repairability and notes that many footwear producers already offer repair services to extend product life. The CEA should recognise and build upon these efforts, facilitating repair networks and access to repair information. However, the CEC opposes the reuse of worn footwear, except when new or fully reconditioned. Shoes adapt to the shape of their owners feet and cannot be completely sanitised; reusing them can lead to hygienic risks and musculoskeletal issues. Regulating the Specifics of Footwear Footwear should not be regulated as textiles. Footwear production involves more complex designs, multi-material components and assembly processes that differ from those of garments. Measures on repairability, recyclability and durability must therefore reflect these technical differences. The CEC also cautions against mandatory recycled-content quotas. Current technologies do not always allow safe or practical use of recycled materials in footwear, and enforced quotas could compromise product safety, quality and performance. The footwear industry continues to research and invest in sustainable manufacturing, including material efficiency and recycling projects. However, consumer demand for sustainable footwear remains limited. The CEA can help bridge this gap by incentivising green purchasing, supporting public procurement of durable products, and promoting consumer awareness of sustainability benefits. Harmonisation, Digitalisation and a Level Playing Field The CEC calls for harmonised implementation of the CEA across all EU Member States to avoid administrative fragmentation. Diverging national rules risk increasing compliance burdens, especially for SMEs operating across borders. A consistent EU framework will ensure regulatory clarity and foster innovation and competitiveness. The EC should establish a single EU-wide digital portal for reporting obligations related to the CEA and other instruments such as Extended Producer Responsibility (EPR) schemes. Such a platform would streamline compliance, reduce duplication and enhance transparency for authorities and businesses alike, and key in industries long supply chains such as footwear. Finally, the CEC emphasises the importance of ensuring a level playing field between EU and non-EU producers. Imported products must meet the same environmental and circularity standards as those produced within the Union, and market surveillance and customs controls should be reinforced. The proposed digital tool could help monitor compliance and guarantee fair competition in the internal market. TO CONCLUDE: The CEC fully supports the Circular Economy Act objectives and shares the ambition to create a more sustainable, resource-efficient EU economy. Success will depend on a pragmatic and sector-specific approach that recognises the unique characteristics of products such as footwear. By acknowledging leathers inherent circularity, supporting repair and reconditioning, and ensuring harmonised, digital and fair regulation, the CEA can help EU footwear sector lead the transition toward a truly circular and sustainable future.
Read full responseMeeting with Aurel Ciobanu-Dordea (Director Environment)
12 May 2025 · Exchange of views on EPR fees and product durability
Response to Single Market Strategy 2025
31 Jan 2025
The CEC, the European Footwear Confederation, represents the interests of the European footwear industry and supports the competitiveness and sustainable growth of footwear companies. In the context of the green and digital transitions, it is essential to re-enforce the Single Markets rules, and ensure a level playing field, allowing businesses and SMEs to grow. Following feedback from our members, key areas of intervention necessary to guarantee a well-functioning Single Market and the opportunity for European businesses to flourish are: Effective Market Surveillance and Customs Controls: Trade statistics show that around 80% of footwear products circulating in the single market originate from outside Europe. These goods do not often comply with European legislation requirements, safety, social and environmental standards, and the controls of customs and market surveillance authorities are insufficient and inadequate. Without proper surveillance, the market is being flooded with cheap shoes that are unsafe to European consumers. There is an urgent need to further invest in strengthening such controls . Legal social and environmental requirements on products are increasing at exorbitant levels while controls remain insignificant. Moreover, online sales remain an easy channel for the introduction of unsafe products in our Single Market. Low quality and the use of certain chemicals in shoes represent a high risk of contamination for consumer health. There is also the challenge of the waste generated in pre and post consumption, that should be differentiated from the waste originated by shoes conforming with the EU standards when it comes to recycling if the use of such materials is to be considered for manufacturing new products. Another challenge is the unknown origin of goods that is generally associated with a reduction in budget revenues from taxes due. Issues arising from unknown origin of goods were highlighted in a recent intervention by Polish national authorities against an illegal transfer of PLN 7 billion from Wólka Kosowska near Warsaw to Asian countries. The numerous problems related to third country imports underlines the need to reinforce surveillance action and prevention measures. Furthermore, despite Member States remaining responsible for their market surveillance policy, the EU should play a coordination role to strengthen its efficient function Facilitating Access to Capital for Business Development: Companies operating in short supply chains should be incentivised by e.g. having access to preferential loan interest and tax rates. This would promote positive outcomes such as increasing the prevalence of local production, reducing carbon footprints, and improving employment structures. Increasing the Use of Public Procurement to support European industry This, particularly in the footwear sector, can serve as a strong stimulus for the development of specialized companies, which can, in turn, drive the growth of other companies in the sector having a trailblazing effect. Internationalization: The procedures related to this type of support need to be simplified and the administrative burden reduced. Furthermore, in the era of reducing consumption and waste for fighting climate change, European high-quality products should be helped to reach all possible markets. There should be more ssistance programmes for industry organisations in the areas of brand promotion and financing participation in international trade fairs. EU branding: In this regard, European products would benefit significantly from an awareness campaign to increase demand for products Made in Europe produced with sustainable and durable materials such as leather. Energy Transition: Increasing access to affordable energy sourced from domestic sources should be seen as a priority. This applies to individual enterprises, economic clusters, industrial parks, etc.
Read full responseResponse to Waste Framework review to reduce waste and the environmental impact of waste management
22 Nov 2023
The European Footwear Confederation (CEC) welcomes the proposal on the revision of the Directive 2008/98/EC on waste (also know as Waste Framework Directive - WFD) tackling i.a. textiles and textiles waste and thanks the European Commission for the opportunity to provide feedback. As an actor engages in contributing to the targets of the EU Green Deal and the Circular Economy Action Plan, the CEC supports the establishment of separate collection and management systems for textiles and textile waste as well as Extended Producer Responsibility (EPR) schemes; in particular, we value the EC attempt to adopt a feasible proposal, attentive to the need of the smaller players and the state of play of our industry. Nevertheless, in the enclosed contribution we would like to highlight some elements of the proposal needing further discussions, and propose some alternatives.
Read full responseResponse to Environmental claims based on environmental footprint methods
21 Jul 2023
The European Footwear Confederation (CEC) welcomes the adoption of the proposal for an EU Directive on Substantiating Green Claims and the consequent implementation of a science-based approach, which represents a step forward towards harmonisation in the EU single market while allowing certain flexibility to economic operators. Please find enclosed our comments to the proposal.
Read full responseResponse to Ecodesign for Sustainable Products - Product priorities
12 May 2023
The textiles ecosystem is one of the 14 priority industrial ecosystems launched on the New Industrial Strategy for Europe in March 2020 and aggregates the textile, clothing, leather and footwear sectors (TCLF). Against the opportunity to addressed certain common issues, the establishment of the textiles ecosystem opened the door to confusion and misinterpretation of the specific sectors covered by this term and to the tendency to look for one-fits-all solutions. In the case of footwear, the product is often excluded or assimilated to textile and apparel, and consequently subject to the exclusion or inclusion in the scope of several initiatives, without a proper assessment. In line with the legislative trends, the study of the EC Joint Research Centre (JRC) considers textiles and footwear as a unique product group within the product priorities to be tackled by the Ecodesign for Sustainable Products Regulation (ESPR). In principle, the EU footwear industry welcomes the efforts of the European Union to reach the sustainability goals set in the EU Green Deal and looks forward to contributing to the green transition. However, the current state of play shows that, from a circularity point of view, footwear cannot be treated as textile and clothing, and it is not feasible to prioritise it in the ESPR Working Plan. Despites belonging to the wider fashion industry, footwear remains a product with specific features and needs that cannot be neglected by policymakers. Footwear needs more time and research to address its circularity, including the ecodesign, waste management, and recyclability. It would therefore be very risky to start a pilot exercise such as the regulation of a product ecodesign with footwear, because the resulting legislation could be not enforceable in the current state of play. Against this background, the European Footwear Confederation (CEC) thanks the EC for the opportunity to provide feedback and contribute to the public consultation on the new product priorities for the upcoming ESPR and wishes to highlight through this document the criticalities of the current approach towards the footwear industry and, consequently, to advance alternative proposals: 1. Textiles and footwear cannot be considered as a unique product group under the ESPR 2. The footwear industry needs further time and support to comply with ecodesign requirements 3. Only a complementary approach towards horizontal requirements will avoid trade-offs 4. Tackling smaller product categories is necessary for an enforceable ESPR (Please see attachment)
Read full responseResponse to Sustainable Products Initiative
22 Jun 2022
The European Footwear Confederation (CEC) welcomes the main concepts of the EC proposal for a review of Eco-design Directive and their integration in the EU Strategy for Sustainable Textiles. We recognise the capacity of the proposal to ensure a sustainable future for our industry, a priority for our members, by establishing requirements and criteria for a greener production, limiting the proliferation of alleged green labels and schemes (art. 26.4b) in order to avoid greenwashing and prohibiting the destruction and disposal of unsold consumers products (art. 20). We particularly welcome the objective to create a level playing field for our companies vis-à-vis third-country actors, which often place products with different standards and certificates, and which safety is often put in question. An effective market surveillance and customs will remain essential and a priority. players will not be able to place products manufactured following different safety standards and tests.
The CEC welcomes as well the introduction of the Digital Product Passport (arts 8-13): an increasing number of EU consumer are more conscious of the environmental challenges and opt for a greener lifestyle, basing their purchase decisions on sustainability information. A DPP with information on the environmental footprint of a product, its composition but also its origin, will enable consumers to buy more sustainably and support national and EU economies, while reducing the carbon footprint with their choices. The DPP would certainly allow the industry to improve transparency and product traceability, as well as fighting against counterfeited products. However, sufficient adaptation period should be provided to SMEs, and the general provisions on the support of SMEs included in art. 19 should be accompanied by well-defined actions at EU and local level allowing a proportionate effort for SMEs in the enforcement of the Regulation.
Ecodesign will play a key role for the future of the footwear sector, albeit the concrete risk that the current diversity of designs and models, so much appreciated by worldwide consumers thanks to the assembly of multiple components and materials, will suffer from simplification by producing more uniform models and reducing their number. Furthermore, it is of utmost importance to exclude footwear from the first wave of products under the 2022 Ecodesign Regulation proposal due to the complexity of the product and manufacturing process. For the same reason, the “ecosystem approach” (i.e. equating textiles to footwear) shall be avoided: in addition to the already mentioned complexity of the product, the duration of life of a shoe and its materials is much longer that the one of textile or a clothing product. It is important that the durability of footwear, even more of leather footwear, is appropriately rewarded in the Ecodesign criteria. Their longer duration of service - which determines the product's environmental footprint - needs to be acknowledged appropriately.
Finally, any approach to ecodesign in footwear should also consider:
• The comfort of the footwear, prior to the stage of use;
• The possibility of repairing and extending the useful life of footwear;
• The recyclability potential depending on the composition/mixture of materials;
• The possibility of having traceability of materials, to unify and have accessibility to databases of environmental impacts of materials and components used in footwear.
Concluding, the CEC urges the EC to take into account the specificities of footwear and the capability of SMEs before taking any decision related to ecodesign affecting the footwear sector, and to define, when necessary, smaller but achievable goals in order to make the green transition inclusive and effective.
Read full responseMeeting with Nicolas Schmit (Commissioner) and
16 Mar 2021 · Pact for Skills roundtable with the textile, clothing, leather and footwear sectors.
Meeting with Thierry Breton (Commissioner) and
16 Mar 2021 · Skills roundtable on textile