Chairman Column
You are aware that the European Union had earlier issued a Regulation (2013/115) of May 31, 2023 on Deforestation and Forest Degradation free supply chain. Among other products, this regulation covers cattle hides (HSN 4101), semi-finished leathers (HSN 4104) and cattle finished leathers (HSN 4107). As per this regulation, Relevant Commodities and relevant products shall not be placed or made available on the market or exported, unless all the following conditions are fulfilled
- They are de-forestation free
- They have been produced in accordance with relevant legislation of the country of production and
- They are covered by a due diligence statement.
As per latest communication received from Indian Embassy in Brussels, the EU Parliament has proposed one year postponement of the regulations i.e. till 30th December 2026 for large operators and traders and till 30th June 2027 for micro and small enterprises.
Though India is a placed under “Low Risk” category under above regulation, Article 9 of the Regulation prescribes the stipulations for operator i.e. any natural or legal person who in the course of a commercial activity, places relevant products on the EU market or exports them.
As 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 be difficult for the leather exporters in India to comply to para 1(d) of Article 9 of EUDR pertaining to geo location.
(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 geolocation shall refer to all the establishments where the cattle were kept; for all other relevant products of Annex I, the geolocation shall refer to the plots of land;
Considering the above, we had taken-up the request with the Embassy that EU Commission may consider exempting leathers under HSN 4101, 4104 and 4107 from complying with Article 9 of EUDR, which includes providing geo location data etc., since all cattle in India are domesticated and not reared in forest land.
We are awaiting further updates on our request and will keep posted you in due course.
With best wishes
Rajendra Kumar Jalan
Chairman
COUNCIL FOR LEATHER EXPORTS