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International Fur Trade Federation

IFF

In 1949, members of the fur trade formed the International Fur Federation (IFTF), which brings together natinal associations from all parts of the world.

Lobbying Activity

Response to Measures to reduce microplastic pollution

16 Jan 2024

The International Fur Federation (IFF) would like to express its support of the Commission's initiatives to address microplastics pollution at the European level. Due to the transboundary nature of the problem, it is crucial to have a coordinated European approach to enforce consistent and harmonised legislations across Member States. This unified effort will not only help protect ecosystems and safeguard public health but will also position the EU as a global leader in the fight against microplastics pollution.
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Meeting with Anna-Michelle Asimakopoulou (Member of the European Parliament)

28 Nov 2023 · Green Claims Directive

Response to Revision of EU rules on textile labelling

29 Sept 2023

The International Fur Federation welcomes the objectives of the Textile Labelling Regulation revision, which aims to harmonise labelling rules for textile products and related products. We hope that this will enhance regulatory clarity and consistency. Additionally, we expect it to improve consumers' access to relevant information and care instructions. As an organization representing the fur industry, we endorse the inclusion of fur products within the Regulation's scope, as we believe it aligns with these objectives. Furthermore, we agree with the proposed focus on clothes/apparel, clothing accessories and household/interior products. However, we believe that the revised legislation should address specific aspects to ensure fairness, practicality, and scientific accuracy. In the attached position paper, IFF outlines its perspectives on key issues within the proposed revision.
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Response to Sustainable Products Initiative

22 Jun 2022

IFF supports the regulation objective of improving the sustainability of products and wishes to bring the Commission’s attention on a number of elements in the draft that IFF believes require further consideration and refinement. Article 2. The proposal defines product groups through the lens of purpose, functional properties, and consumer perception of goods. However, sufficient granularity in the definition of product groups is needed to avoid that products with an only apparent same function – e.g. raincoat v a fur coat both have an outerwear function but are meant for different purposes – are subject to same ecodesign requirements when the very nature of the product function call for separate considerations. Moreover, products with a relatively similar functionality may rely on very different production processes and materials, possibly resulting in incompatible ways of quantifying and comparing their performances with regard to the different ecodesign requirements. For instance, you can repair fur products in ways that are not feasible for textile products, but at the same time you cannot recycle fur down to a fibre level as in the case of textiles. Therefore, product groups should also be defined taking into consideration the nature of the materials and production processes involved, and in this context, it would be more sensible to develop dedicated ecodesign requirements meant to incentivise producers to improve environmentally critical aspects of their respective production processes rather than driving production and consumption towards one product or the other. Article 7. The use of environmental footprint as an ecodesign requirement has to be carefully thought of. On the one hand, the Commission shall ensure that the environmental footprint of products is defined and calculated according to one single agreed methodology across different pieces of legislation. On the other hand, the current PEFCRs work is still ongoing and delayed until 2024 and we do not know whether this tool will eventually bring along the promised benefits. Currently, this work includes a number of controversial aspects which are still under discussion e.g., about when products are comparable. Secondly, the mix of emotional and physical durability of fur makes fur products particularly long-lasting and easy and highly likely to repair and reuse, if used properly and under reasonably foreseeable conditions by the end user. These characteristics should be proportionally rewarded through the ecodesign requirements. In fact, the fur business model is already reliant on high actual and perceived value, and accessible repair and remodelling services to prolong the service life of products, and ecodesign requirements should incentivise this business model and not negatively affect its profitability. Chapter III. Clarifications are needed about the ownership and handling of data/information that will be included in the DPP of a product. The proposal should at least clarify that ownership and responsibility for data accuracy will be clearly assigned in the delegated acts, to avoid that manufacturers are held accountable for data that may change in lifecycle phases beyond their reach or responsibility. Moreover, the roles, mechanisms, and costs for the verification of authenticity of data in DPP also requires further clarification. Article 15. The concept of mimicking label should be clearly defined in the proposal to avoid legal uncertainties as for the use of other already existing labels covering overlapping sustainability aspects as the ecodesign requirements. Chapter 7. In article 21, there is a risk of proliferation of technical documentation to prove the conformity of products, with consequent high costs for testing and certification. The European Commission should aim to reduce this burden especially for SMEs and to provide them with sufficient financial and technical support for the implementation of ecodesign requirements and the DPP.
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Response to Sustainable corporate governance

23 May 2022

The International Fur Federation welcomes the proposal for a directive on Corporate Sustainability Due Diligence with a view to establishing a transparent, reliable, and fair business environment for all value chain actors. Coherence and legal certainty Concerning the application of the directive, Article 2 includes a number of sectors falling under its scope. However, a more precise definition of these affected sectors is necessary. NACE codes – also used in Annex 11 to ‘SWD(2022) 42 final’ to identify high-impact sectors – could be a useful instrument in this sense. Clarity must also be provided with regard to a number of concepts mentioned in the draft proposal, such as “Business relationship” and “established business relationship”, “direct” and “indirect” relationships, “severe impacts”, “suitable industry initiatives.” The proposal should make clear reference to existing international guidelines that have been progressively taken up by EU companies, in particular the UN Guiding Principles on Business and Human Rights, the OECD Due Diligence Guidance for Responsible Supply Chains in the Garment and Footwear Sector, the OECD FAO Guidance for Responsible Agricultural Supply Chains. Trickle-down effect on SMEs Although virtually no European fur company falls under the scope of the directive, indirect effects are expected to impact companies – especially SMEs – along the entire value chain. Article 5(b) states that a company’s code of conduct shall be followed by the company’s employees and subsidiaries. However, article 7(b) extends this obligation to the company’s suppliers and customers (“business partner with whom it has a direct business relationship”) through “contractual assurances”. The same article also envisages contractual cascading. This will likely cause a dangerous trickle-down effect for SMEs which: o Could be required by large customers or even forced by market conditions (perceived obligation due to perceived loss of competitiveness) to sign-up to codes of conduct they had no role in shaping and may find difficult or onerous to fulfil. o Suffer from limited leverage over larger suppliers and be incapable of fulfilling any sort of contractual cascading. This approach could shift most of the burden on suppliers. Therefore, the position of SMEs should be better protected, especially in view of the risk of terminating business relationships for reasons beyond their control. Article 7(2)(d) goes in this direction, but it seems insufficient. A potential solution could be to introduce the concept of “circle of influence” that SMEs can reasonably be expected to have an impact on in the value chain. This concept would on the one hand go beyond a conservative “tier-1 suppliers” approach that would limit the impact of the directive; and on the other, provide sufficient safeguards limiting larger companies’ freedom to shift the burden on SMEs. Article 6 includes the principle of a risk-based approach to due diligence. This approach should be strengthened e.g., by clearly spelling out “business partners” among the stakeholders a company has to consult in the process of identifying actual and potential impacts. Smart mix of measures IFF welcomes the cross-sectoral approach of the proposal and the possibility for the European Commission to develop sectoral guidelines to support companies in fulfilling their obligations (art. 13). The European Commission shall ensure that the business landscape is fairly represented in this process, including companies of all sizes, representing different parts of the value chain, and presenting different due diligence risks. Timeframe The co-legislators should consider a longer time window between entry into force and implementation, especially in light of the difficult economic conditions of the fashion & clothing industry as a result of the SARS-CoV-2 pandemic and the current geopolitical situation in Ukraine, both of which heavily impact several European sectors, including fur.
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Response to Animal welfare labelling for food

6 Aug 2021

The International Fur Federation welcomes the opportunity to contribute to this Inception Impact Assessment. Detailed comments are avaialble in the attached document.
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Response to EU strategy for sustainable textiles

2 Feb 2021

The International Fur Federation (IFF) welcomes this roadmap and shares the European Commission’s objective of building more resilient and sustainable European textile and clothing supply chains. Detailed comments on the roadmap can be found in the attached document. IFF represents 56 members are located in over 40 countries around the world, representing trade or farming associations in their country.
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