Chairman Column
You are aware that the European Deforestation regulation will come into affect from 30th December 2026. Under EUDR, cattle hides/ leathers under HSN 4101, 4104 and 4107 have been included.
Accordingly, Indian suppliers may be required to provide geo location of plots where cattle was born, reared, slaughtered etc.,
Leather supply chain in India involves many stakeholders namely small farmers/slaughter houses/ butchers, merchants, tanneries, producers etc., Also, in India we do not have commercial farms where cattle are bred/reared. Further, in India cattle rearing is domesticated and is done throughout the country, and not in forest land. In India, the cattle are slaughtered for meat and leather is a by-product of meat industry. Such leathers are derived from domesticated animals and village small farmers and not from forest land. Hence, it would not be possible for the leather exporters in India to comply to para 1(d) of Article 9 of EUDR pertaining to geo location (extract given below).
(d) the geolocation of all plots of land where the relevant commodities that the relevant product contains, or has been made using, were produced, as well as the date or time range of production; where a relevant product contains or has been made with relevant commodities produced on different plots of land, the geolocation of all different plots of land shall be included; any deforestation or forest degradation on the given plots of land shall automatically disqualify all relevant commodities and relevant products from those plots of land from being placed or made available on the market or exported; for relevant products that contain or have been made using cattle, and for such relevant products that have been fed with relevant products, the geo-location shall refer to all the establishments where the cattle were kept; for all other relevant products of Annex I, the geo-location shall refer to the plots of land;
Hence, we have taken-up the request with the Government of India that the proposed EU deforestation regulation should be dropped for leathers under HSN 4101, 4104 and 4107 for India, considering that such leathers are not derived from deforestation and that India is also placed under “Low Risk” category. We hope that the European Union will consider this request.
With kind regards,
Ramesh Juneja
Chairman
COUNCIL FOR LEATHER EXPORTS