Exported from the old PCR Forum - May 13 2005 16:10 -
Dear Sirs, please find enclosed comments and observation made on the document PCR Leather dp 05 04 05 pubblished on the site for open consultation.
We do represent UNIC, the Italian tanners association. All the observation have been made taking into consideration one main principle: the EPD for finished leather shall be developed as an useful tool for the promotion and development of the environmental excellence of tanneries on the market.
In order to reach this goal, it is our duty, as industrial association, to guarantee that every instrument and tool developed for the purpose is actually tailored for the needs of tanneries and can be easily applied on a product as particular as leather is.
It has to be pointed out that the discussion and work on the realisation of a type II Environmental declaration for leather has started more than two years ago at a national level, co-ordinated by UNIC. In this respect, it has to be stressed one more time the relative importance of Italy in the international market scenario, representing 66% of the European turnover, 20% of world total output and 25% of world total export.
Our organisation is acknowledged that one more project for the definition of product specific requirements has been carried out at a national level in Italy and is ready to be sent.
Moreover, activities carried out at international level (CEN, ISO) by the competent working groups should be taken more in to consideration as propedeutic to the realisation of the proposed PCR, that in any case deals with general matters and therefore has to be subordinated to technical and sectoral specific norms.
It would be very important to discuss in details with the organisations and persons that have prepared the current version of the PCR and amend it.
Being the text of the PCR the current version PCR Leather dp 05 04 05, our organization cannot accept it.
/ Federico Brugnoli