Scope analysis for the revision process of the Ecolabel for “Footwear” Joint Research Centre (JRC) IPTS - Institute for Prospective Technological Studies Seville - Spain http://ipts.jrc.ec.europa.eu/ http://www.jrc.ec.europa.eu/

According to the current EU Ecolabel for Footwear (Decision 2009/563/EC), the product group ‘Footwear’ shall comprise all articles of clothing designed to protect or cover the foot, with a fixed outer sole which comes into contact with the ground. Footwear shall not contain any electric or electronic components. Criteria applies for components weighting more that 3% separately for upper and sole part of footwear. The general objective of the revision is to check the possibility to extent footwear product group to other leather products and update the existing criteria according to the actual Legislation and state-of-the-art of targeted industry

37 products (online catalogue) According to the current EU Ecolabel for Footwear (Decision 2009/563/EC), the product group ‘Footwear’ shall comprise all articles of clothing designed to protect or cover the foot, with a fixed outer sole which comes into contact with the ground. Footwear shall not contain any electric or electronic components. Criteria applies for components weighting more that 3% separately for upper and sole part of footwear. The general objective of the revision is to check the possibility to extent footwear product group to other leather products and update the existing criteria according to the actual Legislation and state-of-the-art of targeted industry Currently footwear is not amongst the most successful Ecolabels: 9 licenses 37 products (online catalogue)

SCOPE ANALYSIS: Key aspects considered European and international standards European and non-European Ecolabels and standards Preliminary market analysis Available LCA studies on footwear, leather, and leather products Technical Analysis – feedback from experts 5.1. Diversity of leather 6. Technical Analysis of the scope extension 6.1. Function of the final product 6.2. Materials composition 6.3. Material and processing 7. Company visit The scoping document provided to the CBs constitute the background information for the revision of the EU Ecolabel for Footwear in terms of the scope definition and its possible extension to other leather products. Hence, one of the particular objectives was to determine the product group covered by the EU Ecolabel for Footwear and Leather products. Based on this definition, the EU Ecolabel criteria shall be reviewed so that they can apply to all products within analysed category, addressing the most important environmental impacts from the Life Cycle Assessment perspective. The technical scoping document document first analysis identified relevant sources of information, and then develops the main arguments to support the revised scope proposal. Finally, it presents conclusions and preliminary recommendations. Thus the following key aspects were taken into consideration 1. European and international standards European and non-European Ecolabels and standards Preliminary market analysis Available LCA studies on footwear, leather, and leather products Technical Analysis – feedback from experts Diversity of leather Technical Analysis of the scope extension . Function of the final product Materiasl composition Material and processing

Ad. 1. European and international standards Main international standards relevant to the footwear and leather sectors: CEN – European Committee for Standardization: ISO – International Organization for Standardization IULTCS - International Union of Leather Technologists and Chemists Societies Diverse technical requirements related to footwear and leather product. No standards/testing requirements for a range of leather products Read the slide

Ad. 2. European and non-European Ecolabels and standards The following table introduces the main European and non-European Ecolabels schemes and standards that address both footwear and/or leather containing product group(s). The labels shown have been selected due to their market penetration, their recognition on the market and because they are usually used as benchmarks during the EU Ecolabel criteria development process. By analyzing the way in which the scope is defined, it is possible to evaluate the feasibility of recommending the scope that covers all or by contrary determined leather products. As example, following the Nordic Swan specification, leather is included in the common group of textile, skins and leathe. Blue Angel covers leather material by the product group of Footwear and upholstery leather. Japanese Eco Mark makes a clear division between Footwear and Leather clothes, gloves, and belts. The main conclusion are: When considering product group of footwear, (Eco Mark and Blue Angel) the scope is close to the current EU Ecolabel for footwear, and is based on the final function of the product “to cover the foot”. Other Ecolabels, such as Distintiu de garantia de qualitat ambiental, apply the criteria that cover 'all products made of leather'. Here, the set of criteria only apply to leather itself, and not to other materials or the final product. Ehen defining scope as made of leather, but excluding footwear (Eco Mark, Nordic Swan, Environmental Choice), the schemes also define a minimum quantity of leather that should be present in the end product. Note: For the Nordic Swan, footwear was excluded, as being addressed by the EU Ecolabel criteria for footwear.

Ad. 3. Preliminary market analysis World leather use by end products1 Leather use-million square feet Footwear 11,925 (52%) Furniture 3,210 (14%) Auto 2,340 (10.2%) Garments 2,290 (10%) Gloves 1,010 (4.4%) Other leather products 2,155 (9.4%) Total 22,930 (100%) The table shows that footwear is the major leather-made end product, sharing as much as 52% of global production. It is important to emphasize that footwear is considered as specific and separate product group, classified as a unique product category. 1 International Council of Tanners estimates 2007

Ad. 3. Preliminary market analysis Estimated % division of the European leather market production value2,3 The official EU production statistics (Prodcom, Comext) does not consider precise leather market segmentation. The aggregation of leather with other materials within specific product groups limits the reliability of possible estimation that is why it is quite complicated to screen the market and specify the scope of possible interest. The only data that are clearly analysed considers footwear with leather uppers, that constitute 72% of European footwear production 2. EUROSTAT: 3. CBI Market Information Database (2010) Market Intelligence Reports, www.cbi.eu

Ad. 3. Preliminary market analysis Italian production by sector of intended use % incidence4 Italy is the main leather and leather goods manufacturer in Europe, according to the UNIC Report (published the European Leather Industry Association), the Italian leather sector segmentation shows footwear as the main product, followed by furniture, leather goods, and clothing 4. Unione Nazionale Industria Conciaria (2009) Environmental Report

Ad. 3. Preliminary market analysis: Conclusions Material use in “leather products” manufacturers: Synthetic material (plastic, nylon, PVC, PP etc) textiles paperboard metal combinations The leather branch make an additional use of a variety of materials such as synthetic material (plastic, nylon, vulcanised fibre, PVC, PP, etc.), textiles, paperboard or a combination of all (with leather). Leather is not the major constituent of the final product. Thus, there is a potential risk that if the wide range of articles apparently relevant to leather were covered by the scope, it would then include products that do not predominantly contain leather (or that only contain a minor quantity of it).

Ad. 3. Preliminary market analysis: Conclusions Product group Product Leather fraction Belts 70% Small leather goods Wallets, key pouches, toilet bags etc 30% Handbags 25% Business cases Brief cases, computer cases etc 20% Suitcases 4% Travel bags Back backs etc. 2% Other bags Shopping bags, sport bags etc na

Ad. 3. Preliminary market analysis: Conclusions Large variety of different products Reduced leather share (are these leather products?) Reduced market share Preliminary assessment: Potential environmental saving is limited

4. Available LCA studies on footwear, leather, and leather products LCA quick screening: Leather processing is environmental hot spot Consequently criteria for this stage are adequate Option 1: Cradle to gate Technical/environmental analysis for 1 m2 of leather (only B2B approach) Option 2: Product oriented One pair of shoes, one belt, one pair of gloves The goal of the Ecolabels is to help consumers to choose the most environmentally friendly goods available on the market. When consumers look for a product, they actually seek for the specific function to fulfil (i.e. to eat, to dress). As with the LCA study, the EU Ecolabel should define a product category based on a common final utility. The ISO 14040:2006 and ISO 14044:2006 standard clearly state that environmental comparisons between systems shall be made on the basis of the same function(s), quantified by the same functional unit(s). In addition, the EU Ecolabel Regulation mentions that the criteria “should be market oriented and limited to the most significant environmental impacts of products from the life cycle perspective From the criteria setting perspective, the scope extension would require more than one functional unit.

5. Technical Analysis – feedback from experts Scope extension to all leather product Leather experts Tanneries Testing laboratories Technology Centre Leather Association Manufacturers No / Yes/No Scope extension to proximate products : e.g. belt & handbags Possible Yes Yes but focus on Leather/No 13 stakeholders inquired that represent the leather and footwear sector (technical centres, tannery, manufacturers). According to the preliminary consultation with several stakeholders directly involved in the leather goods production or testing In general, stakeholders do not consider it obvious to extend the scope to other leather product. Exception could be made for very proximate articles such as i.e. belts or handbags.

Ad. 3. Preliminary market analysis: Conclusions Industry pointed out an additional issue: Product life cycles are getting shorter (less than 6 months). An Ecolabel for individual products (= 1 pair of shoes) is not reasonable. How can that be addressed?

SHALL WE EXTEND THE SCOPE? Scope Analysis SHALL WE EXTEND THE SCOPE?

Conclusions and recommendations on the scope The principal recommendation on the scope extension is to maintain it as currently defined: “The product group ‘footwear’ shall comprise all articles of clothing designed to protect or cover the foot (…)” As alternative and by the way of similarities the closest products could be considered: “The product group ‘footwear and leather products’ shall comprise all articles of clothing or accessory Either designed to protect or cover the foot, Or made of leather and designed as decorative or functional accessory, such as belts, bags, gloves, and other articles normally carried in the pocket …” The proposed scope extension contains products of different characteristics, compositions and functions which makes the determination of base case average products for conducting the LCA very complicated. Additionally, the proposed scope extension of the EU Ecolabel revision of footwear is practically so wide that is more appropriate to refer to it as a parallel revision of footwear and development of a new product group that covers "leather based products". The principal recommendation on the scope extension is to maintain it as currently defined: However, and considering all the above mentioned arguments, if the first option (to maintain the current scope and definition covering footwear product group) is considered to be too narrow, by the way of similarities the closest products could be considered. By way of similarities only goods related to apparel might to be kept under the scope definition, as a consumer will never compare footwear to upholstery for car seats and furniture. Leather garments should also remain out of the scope, because they are addressed in the EU Ecolabel for Textiles. Thus the second proposal is: The product group ‘footwear and leather products’ shall comprise all articles of clothing or accessory Either designed to protect or cover the foot, Or made of leather and designed as decorative or functional accessory, such as belts, bags, gloves, and other articles normally carried in the pocket …” Because leather has been chosen as a common characteristic and the basis for extending the scope, it is necessary that leather is the main material used for the products covered by the set of criteria of the EU Ecolabel for footwear and leather products. Therefore the inclusion in the scope of bags and other small leather goods (except belts) is not rightly recommendable as leather is not the major material used in these products. One could imagine including only these products that contain a minimum amount of leather referring to them as "leather goods", the consumer, however, may not focus on the materials used when comparing different items. The exact cut-off limit should be discussed with the EU Ecolabel Board and involved stakeholders.

Questions to CB: GENERAL: How do the current criteria work? Problems with assessment and verification? SCOPE: Should the scope remain as it is? If expanded, what should be included (e.g. belts, gloves, bags)? MATERIALS: 3% material cut off OK? Does criterion on material origin make sense? Derogation for recycled material? ENERGY: What was the result of the energy reporting criterion? Any data? Can we set limits now?

Thank you for your attention

Website: http://susproc.jrc.ec.europa.eu/footwear