PRODUCT GROUP: UN CPC 2912 FINISHED BOVINE LEATHER



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2011:13 VERSION 2.0 VALID UNTIL: 2019-06-11

TABLE OF CONTENTS 1 General information...4 2 Definition of the product group...5 2.1 Specification of manufacturing company...6 2.2 Specification of the product...6 3 Declared unit...7 4 Content declaration...7 5 Units and quantities...7 6 General system boundaries...8 6.1 Upstream processes... 10 6.2 Core processes... 10 6.3 Downstream processes... 10 7 Upstream Module... 10 7.1 System boundaries... 10 7.2 Data quality rules... 11 7.3 Other calculation rules... 12 7.4 Cut-off rules... 13 8 Core Module... 13 8.1 System boundaries... 13 8.2 Allocation rules... 15 8.3 Data quality rules... 16 9 Downstream Module... 17 9.1 Transport to an average customer... 17 9.2 End-of-life of packaging... 17 10 Environmental performance-related information... 17 10.1 Use of resources... 18 10.2 Potential environmental impacts... 18 10.3 Waste production... 19 10.4 Other environmental indicators... 19 10.5 Additional environmental information... 19 11 Content of the EPD... 20 11.1 Programme-related information... 20 11.2 11.3 Product-related information... 20 Content declaration... 21 11.4 Environmental performance-related information... 21 11.5 11.6 Additional environmental information... 21 Mandatory statements... 21 11.7 Differences versus previous versions of the EPD... 22 11.8 References... 22 12 Validity of the EPD... 22 13 Changes in this PCR document... 22 PAGE 2/24

GENERAL INTRODUCTION TO PRODUCT CATEGORY RULES IN THE INTERNATIONAL EPD SYSTEM This is a Product Category Rules (PCR) document developed in the framework of the International EPD System, operating in accordance with ISO 14025:2006 and the following international standards: ISO 9001, Quality management systems ISO 14001, Environmental management systems ISO 14040, LCA - Principles and procedures ISO 14044, LCA - Requirements and guidelines The International EPD System is a system of voluntary environmental declarations applicable to any type of goods and services. The rules and requirements of the system are defined in the General Programme Instructions, available at the website: www.environdec.com. A PCR is defined in ISO 14025 as a set of specific rules, requirements and guidelines for developing Type III environmental declarations for one or more product categories. This PCR document specifies the rules for the underlying life cycle assessment (LCA) and sets minimum requirements on EPDs for a specific product group that are more detailed than the standards and the General Programme Instructions. In the case of building products, the International EPD System also allows the use of EN 15804 (Sustainability of construction works - Environmental product declarations - Core rules for the product category of construction products) and ISO 21930 (Environmental declaration of building products) as underlying standards, if relevant. The compliance with these standards shall be defined in each PCR. The principle programme elements in International EPD System are presented below. More information is available in the General Programme Instructions and on the website: PURPOSE Complying with principles set in ISO 14025 on modularity and comparability Simplifying work to develop Product Category Rules (PCR) Secure international participation in PCR work Facilitating identification and collection of LCAbased information Broaden market applications of EPDs Expand possibilities for organisations to issue EPDs in a cost-effective way ELEMENT IDENTIFICATION AND PRINCIPAL APPROACH 1. "Book-keeping LCA approach" (attributional LCA) 2. A Polluter-Pays (PP), allocation method 3. PCR Module Initiative (PMI) in order to structure PCR in modules according to international classification 4. PCR Moderator for leadership and support of the PCR work 5. Pre-certification of EPDs 5. Online PCR Forum for open and transparent stakeholder consultation 6. Selective data quality approach for specific and generic data 8. Introducing Sector EPDs 9. Introducing "Single-issue EPDs" 10. Introducing "EPD process certification" Alignment of Product Category Rules (PCR) across intermediate and final products in the supply chain and of PCRs developed in the framework of other ISO 14025 compliant programmes is strongly encouraged. In order to have a - unique identification of each product group, the United Nation Statistics Division - Classification Registry CPC codes (http://unstats.un.org) are used in the International EPD System. All PCR documents have a maximum period of validity after which the document shall be revisited. PAGE 3/24

1 GENERAL INFORMATION Name: Programme operator: Finished bovine leather The International EPD System, www.environdec.com. E-mail: info@environdec.com Publication date: 2015-06-11 (Version 2.0) Version 1.0 was published 2011-09-28 Registration no: 2011:13 This PCR was prepared by: Appointed PCR moderator: Aequilibria www.aequilibria.com Daniele Pernigotti, Aequilibria, dpernigotti@aequilibira.com Open consultation period: 2014-11-01until 2015-02-25 (Version 2.0) 2011-05-30 until 2011-06-30 (Version 1.0) Contributors during open consultation (only list with their approval) Review panel for this PCR: The PCR is valid within the following geographical region: Carlo Brondi and Federico Fragassi of CNR-ITIA The Technical Committee of the International EPD System. Full list of TC members available on www.environdec.com/tc This PCR can be used on a global level. Valid until: 2019-06-11 More information on this PCR s website: http://environdec.com/en/pcr/detail/pcr2011-13 This document provides Product Category Rules (PCR) for the assessment of the environmental performance of Finished bovine leather, within the UN CPC product class 2912 Other leather, of bovine or equine animals, without hair on and the declaration of this performance by an EPD. More information about the product group is available in Section 2. This PCR excludes the UN CPC product class 2911 Chamois leather, patent leather and patent laminated leather; metalized leather. This PCR complies with the General Programme Instruction of the International EPD System, version 2.01 dated 2013-09-18. It is based on the requirements and guidelines given in PCR Basic Module, CPC Division 29: Leather and leather products; footwear, version 2.0, dated 2013-10-24. For the preparation of this PCR the following documents have been considered: PCR UN CPC 2111 AND 2113 MEAT OF MAMMALS, 2012:11, VERSION 2.0 PAGE 4/24

PCR UN CPC 022 RAW MILK, 2013:16, VERSION 1.01 PCR UN CPC 2912, 2011:13, VERSION 1.0 ISO/TS 14067; First edition 2013-05-15; Greenhouse gases - Carbon footprint of products - Requirements and guidelines for quantification and communication; Gruppo Dani Spa, 2012. EPD Environmental Product Declaration - Leather for clothing, upholstery, footwear, leather goods, accessories and interior design. THE INTERNATIONAL EPD SYSTEM Conceria Montebello S.p.A., 2012. EPD Dichiarazione Ambientale di Prodotto - Pelli per abbigliamento, arredamento, calzatura, pelletteria, accessori ed interior design. THE INTERNATIONAL EPD SYSTEM Pelletier, N., Pirog, R., & Rasmussen, R. (2010). Comparative life cycle environmental impacts of three beef production strategies in the Upper Midwestern United States. Agricultural Systems, 103(6), 380 389. doi:10.1016/j.agsy.2010.03.009 European Commission Joint Research Centre Institute for Environment and Sustainability, 2015. JRC Technical Report- Default Approaches for Cross-Cutting Issues for the Cattle Related Product Environmental Footprint Pilots; Final draft version. This PCR document is publically available on www.environdec.com. The PCR document is a living document. If relevant changes in the LCA methodology or in the technology for the product category occur, the document will be revised and any changes will be published on the website. Any comments to this PCR document may be given on the PCR Forum on www.environdec.com or directly to the PCR moderator during the period of validity. The PCR Moderator should initiate a revision process before the validity time expires to give due time for announcing and collecting comments. EPDs shall be based on the latest version of the PCR, and refer to the version number and date of the PCR used. The production of new PCR versions does not affect the certification period of EPDs that are already published. 2 DEFINITION OF THE PRODUCT GROUP The product group under study in this PCR document is Finished bovine leather, which is part of the product group Tanned or dressed leather; composition leather and of the product class Other leather, of bovine or equine animals, furless. This PCR is applicable for finished bovine leather which is produced from rawhides coming from both adult bovines and calves. This is defined in the UN CPC classification as class 2912: Division: 29 - Leather and leather products; footwear - Group: 291 - Tanned or dressed leather; composition leather Class: 2912 - Other leather, of bovine or equine animals, furless More information about the product group and the United Nation Statistics Division - Classification Registry CPC codes can be found at http://unstats.un.org/unsd/cr/registry/regcs.asp?cl=25&lg=1&co=2912. This PCR excludes the following related UN CPC classes: Class 2911 -- Chamois leather, patent leather and patent laminated leather; metalized leather"; Class 2913 - Other leather, furless (including sheep, lamb, goat or kid skin leather); composition leather with a basis of leather or leather fibre. The product group and UN CPC code shall be specified in the EPD. The type of product under study in this PCR is Finished bovine leather", intended as a finished product of the tanning sector and ready to become an input as a semi finished product for further transformation in various manufacturing sectors. PAGE 5/24

The leather can be used as a semi finished product for different kinds of goods such as furniture, clothing, automotive, footwear etc. Since the application of Finished bovine leather in final consumer products varies substantially, no specific function has been defined for the product. This PCR can be used for all kinds of finished bovine leather types from a single manufacturing facility in any one of the following ways: A) For an EPD of a single product (i.e. finished bovine leather constituting a specific article); B) For an EPD of a family of similar and homogeneous products that are part of the same production category (automotive, footwear, etc.). In this case the LCA study shall be based on the average finished bovine leather production for family (e.g. all types of finished bovine leather for the footwear manufacturing sector produced by the tannery in one year); C) For an EPD of the average production of all kinds of finished bovine leather types produced in a tannery in a defined time period. In that case it shall be clearly stated in the EPD that the result does not refer to a specific category of finished leather but to the average production of the tannery. In the LCA study underlying the EPD shall be specified which of the three above approaches is used. This PCR is compatible with different tanning methodologies such as wet blue, wet white, vegetable tanning, etc. In the LCA study underlying the EPD shall be specified which tanning method is used for the finished bovine leather analysed, and the finished bovine leather shall be treated in homogeneous groups, depending on the tanning methodology applied. In the following chapters, for editorial simplification, the tanned hide is called tanned wet blue. Though in the case of the LCA study it is applied to leather tanned with other methodologies such as wet white or vegetable tanning, the descriptor shall be changed accordingly (for example in the process flow diagram). 2.1 SPECIFICATION OF MANUFACTURING COMPANY Mandatory information: Manufacturing company Manufacturing site and country Issuer and contact information Voluntary information: ISO 14001 and/or EMAS certificate at the manufacturing site Specification of the process phases carried out in the production site Potential use destination of the products (e.g. clothing) Environmental policy Manufacturers logotype 2.2 SPECIFICATION OF THE PRODUCT The trade name (if relevant) of the product shall be declared. Relevant Type I and Type II environmental labels awarded to the product may be stated. Any claims made about the product must be verifiable. In case the EPD is done for the average leather production of the tannery (case C, see clause 2), inside the different finished bovine leather categories changes in product quality (as thickness, colour, suppleness, stretch.) are possible as a function of specific customer requirements. A single EPD is allowed if these changes do not cause differences of more than 10% from the normalized impacts of the referenced average product. Analysis with respect to this threshold shall be reported in the LCA study. PAGE 6/24

3 DECLARED UNIT The declared unit is the production of 1 m 2 Finished bovine leather, measured according to ISO 11646. As reference flow one kg of finished leather equates to one m 2 of finished leather. The declared unit shall be stated in the EPD. The environmental impact shall be given per declared unit. 4 CONTENT DECLARATION The finished bovine leather shall comply with the relevant national legislation regarding the content of chemicals in the finished leather of the markets where it is distributed. For the European Union, the relevant legislation is Regulation EC 1907/2006 (REACH). The declaration of material content of the product shall include all substances contained in the product that are listed in the Candidate List of Substances of Very High Concern (SVHC) for authorisation when their content exceeds the limits for registration with the European Chemicals Agency 1. Furthermore the declaration of material content shall comprise, as a minimum, the content of Hexavalent chrome, Formaldehyde, Pentachlorophenol and Azocolorants in ppm in the finished bovine leather. 5 UNITS AND QUANTITIES The International System of Units (SI units) shall be used. Reasonable multiples may be adopted for a better understanding. The units to be used for power and energy are: kw (MW) for power kwh (MWh) for energy A maximum of three significant digits shall be used when reporting LCA results. The thousands separator and decimal mark in the EPD shall follow one of the following styles: SI style (French version): 1 234,56 SI style (English version): 1 234.56 In case of any potential confusion, the EPD shall state what symbols are used for thousand separator and decimal mark. As conversion factors, e.g. for heat gas from m 3 to MJ or for diesel from l to kg, those stated in the national NIR shall be used for the relevant production year or in officially recognised national standards. If there are more specific conversion factors available, they can be used, but this has to be justified in the LCA study. 1 http://echa.europa.eu/chem_data/authorisation_process/candidate_list_table_en.asp PAGE 7/24

6 GENERAL SYSTEM BOUNDARIES The International EPD System has adopted an LCA calculations procedure which is divided into three different life cycle stages, see Figure 1: Upstream processes (from cradle-to-gate); Core processes (from gate-to-gate) Downstream processes (from gate-to-consumer gate) In the EPD, the environmental performance associated with each of the three life cycle stages above shall be reported separately. In the EPD it is possible to report separately impacts, distinguishing the impacts of the tanning processes from those due to the agriculture and cattle raising phase. PAGE 8/24

Figure 1. System diagram illustrating the main processes and the division into Upstream, Core and Downstream processes. PAGE 9/24

6.1 UPSTREAM PROCESSES The upstream processes include: Feed cultivation Feed products preparation Animal breeding (including enteric fermentation) Energy consumption for cattle raising Manure management Slaughterhouse The manufacturing of primary and secondary packaging used for finished leather transportation Chemical and auxiliary materials production used for leather preparation 6.2 CORE PROCESSES The core processes include: External transportation to the core processes Preparation of finished bovine leather, including fresh water consumption, wastewater treatment, heating and emissions to air Maintenance activities more frequent than once every three years Waste treatment of waste generated during manufacturing; Impacts due to the electricity production according to the proper energy mix hypotheses (see Section 7.4) 6.3 DOWNSTREAM PROCESSES The downstream processes include: Transportation from manufacturer to an average customer End-of-life processes of packaging waste by the customer The finished bovine leather is a semi-product. Its system boundaries are limited to the customer gate, as there are numerous ways and markets of use of the product, so no reliable scenario of use and end-of-waste can be performed. 7 UPSTREAM MODULE 7.1 SYSTEM BOUNDARIES The processes listed in Section 6.1 shall be included in the upstream module. Processes not listed may also be included. Production of all raw materials shall be included, if not otherwise excluded by the cut-off rules. For agriculture and cattle raising it is particularly important to consider emissions of CH 4 and N 2O. The rawhide is a by-product of the slaughtering stage and not a waste of it. Therefore rawhide takes part in the environmental burdens related to slaughtering and cattle raising activities, according to the allocation rules of clause 7.3. PAGE 10/24

7.2 DATA QUALITY RULES As a general rule, specific data shall always be used if available. For the upstream module, selected generic data and other generic data may under certain criteria -- also be used if specific data are not available. 7.2.1 RULES FOR USING GENERIC DATA The book-keeping (attributional) LCA approach in the International EPD System forms the basic prerequisites for selecting generic data. For allowing the use of selected generic data selected prescribed characteristics for precision, completeness and representativeness must be fulfilled and demonstrated, including but not limited to: Representativeness of the geographical area for industrial processes should adhere to Data deriving from areas with the same legislative framework and the same energetic mix, Representativeness of the geographical area for agriculture should adhere to Data deriving from areas with the same production conditions and the same yield levels. Technological equivalence adheres to Data deriving from the same chemical and physical processes or at least the same technology coverage (nature of the technology mix, e.g. weighted average of the actual process mix, best available technology or worst operating unit), Boundaries towards nature adhere to Data shall report all the quantitative information (resources, solid, liquid, gaseous emissions; etc.) necessary for the EPD, and Boundaries towards technical systems adhere to The boundaries of the considered life cycle stage shall be equivalent. Data calculated with system expansion should not be used, but if no other data are available, any negative flows should be changed to zero. As in PCR MEAT OF MAMMALS 2012:11 VERSION 2.0, animals that yield rawhide shall be divided in two categories: Mammal: non-reproducing mammal destined to meat production (e.g. calf in cow meat farming); Reproductive mammal: mammal of female gender that has reproduced and that at end of career (when no longer destined to reproduction and/or milk production) is destined to meat production (e.g. Reproductive cow in cow meat farming). As selected generic data for animal production processes the use of Agrifootprint database is recommended, using data of Beef cattle for Mammals (non-reproducing mammals destined to meat production) and data of Dairy cows for Reproductive mammals (mammals of female gender that have reproduced and that at end of career are destined to meat production). If specific data, selected generic data - or other data that meet the requirements of the International EPD System as necessary input data - are not available, other generic data may be used and documented. The environmental impacts associated to other generic data must not exceed 10% of the overall environmental impact from the product system. Rawhides may come from different bovine types with differentiated agriculture and cattle raising practices as well as differentiated slaughtering processes on a global level. Rawhide lots are normally delivered to the tannery as a rawhide mix. Furthermore rawhide batches may be provided to the tannery without previous tracking or with limited tracking. The limited tracking can include information on bovine geographic provenience and/or on rawhide transport, but the rawhide's origin remains fundamentally unknown up to the tannery gate. For this reason this PCR advises LCA practitioners to pay particular attention to the data quality of the upstream phase, as this life cycle phase has a very significant contribution to the environmental impact of leather. To improve the data quality of the LCA study it is important to check if there are available updated data regarding cattle raising related to the different geographical contexts. This may include knowledge about bovine provenience, animal transportation to the slaughterhouse and rawhide transport to the tannery. Every choice regarding the modelling of the provenience and the transport of the animals and the rawhides has to be justified. Regarding the cattle's raising process, the use of Agrifootprint data is recommended, unless there are more specific data available on geographic scale. PAGE 11/24

Considering that the Agrifootprint database is based on European data, it is preferable that for cattle raising in different geographic regions more representative data of the specific geographic context be used. For example, if this PCR is used as a CFP-PCR, for extra-european and extensive raising practices the use of the study of Pelletier et al. (2010) is suggested. 7.2.2 DATA QUALITY DECLARATION The EPD may include an indicator suitable to demonstrate the relevance of specific, selected generic and other generic data. 7.3 OTHER CALCULATION RULES PCR MEAT OF MAMMALS 2012:11 VERSION 2.0 should be used as a reference for all the methodological issues related to animal breeding. PCR MEAT OF MAMMALS 2012:11 VERSION 2.0 shall be used as a reference for allocation rules in the slaughtering process of the upstream module. In particular, the following general rules of PCR MEAT OF MAMMALS apply also in this PCR: Meat chain by-products may vary in relation to the type of mammal considered; and may come in the form of food products or miscellaneous goods; In all cases, impact allocation for all by-products shall be done considering an estimate of the economic value of the various products. The value employed for the allocation of these impacts shall be calculated in relation to the average economic value over the last 3 years, with annual verification of updates. These values shall be published within a specific section of the environmental declaration, along with a description of sources and main hypotheses. The percentages of the economic allocation of slaughtering products and by-products shall therefore be calculated individually in every LCA study, but the process of data collection shall follow the rules described above and shall be documented. For consistency the economical allocation shall be used even at the farm stage (e.g. for milk and calves produced at the dairy farm where the reproductive mammals are raised). Further guidelines for allocation are provided by the updated documents of PEFCR Pilot Cow Model Working Group (CMWG). Though an economic allocation is performed for the output products of the slaughtering process, the mass of the rawhides of each of the animal categories used by the tannery (non-reproducing mammals and reproducing mammals) from slaughterhouses over the last three years must also be collected and documented. These data shall be used to calculate a weighted average mass of the representative rawhide from the slaughterhouse. A weight reduction for the salting and trimming of the rawhide from the slaughterhouse shall be applied as following: The weight X of the rawhide from the slaughterhouse necessary for obtaining Y kg of rawhide ready for soaking/liming is: Y = X * ((a*(1-b))+(c*(1-d))) Y: weight of the representative rawhide ready for soaking/liming X: weight of the representative rawhide from the slaughterhouse a: percentage of salted rawhides used in the tannery b: percentage of weight reduction of salted rawhides between slaughtering and soaking/liming (fixed at 15% for all categories) 2 2 Data origin: Tanneries involved in the PCR elaboration; these variations shall be used as fixed specific data for all categories of raw hides. PAGE 12/24

c: percentage of fresh rawhides used in the tannery d: percentage of weight reduction of fresh rawhides between slaughtering and soaking/liming (fixed at 3% for all categories) 7.4 CUT-OFF RULES Life Cycle Inventory data shall be included according to the following cut-off criteria: All chemical products shall be included in the inventory, if the total weight of the product (as commercial presentation) is 1% respect to the mass of all chemical product inputs. The concept of "all chemical product inputs" has to be deflected depending on whether the EPD is made for a single product, for a family of similar products or for the average leather production (see clause 2). In the case of a single product (A) and a family of similar products (B) the mass of all chemical products has to be intended as the total amount of chemical products used to produce the specific category of products which are the subject of the study at the time of reference. In case the EPD is made for the average leather production (C) the mass of all chemical product inputs refers to the sum of all chemical products used in the tannery at the time of reference. In order to guarantee a conservative approach, all chemical products excluded from the previous cut-off rules shall be considered by aggregating the masses consumed of their commercial presentations. For every manufacturing phase the products excluded shall be aggregated and shall be considered as the most consumed product in that phase. In terms of data quality the following criteria shall be applied: Specific data quality: the specific chemical compound is present in the used databases or available in additional LCA studies; Selected generic data quality: the exact formulation of the chemical compound is not present in the database, however a very similar formulation or the precursors of a common industrial process for the production of the chemical substance are present in the database. In this scenario the substance has to be represented by the similar formulation or by its precursors, which shall be used with a ratio commensurate with their molar weight contribution in the common industrial production process of the compound. Generic data quality: the exact formulation of the chemical compound is not present in the database, however an alternative compound can be identified in the database. In this case the following conditions should apply: a) The chemical compound should be based on the same reactive group (e.g. OH, -CHO, -NH2 etc.); b) The alternative chemical compound should have a similar molecular weight (e.g. substitution of formaldehyde with polyaldehyde); and c) The selected compound should be in the same physical state as the original compound in normal conditions (i.e. gas, liquid, solid). When more alternative compounds are available, a conservative choice regarding the environmental impact should be adopted. All other choices shall be justified and these data shall be considered as generic data quality. 8 CORE MODULE 8.1 SYSTEM BOUNDARIES 8.1.1 TECHNICAL SYSTEM The processes listed in Section 6.2 for the production of the final product shall be included. All tanning processes have to be included in the study. Manufacturing processes not listed may also be included. However, the production of the raw materials used for production of all product parts shall be included according to the cut-off rules at Section 8.2. PAGE 13/24

Preservation/storage of rawhides Production of wet blue (from rawhide to wet blue) Production of crust (from wet blue to crust) Production of finished leather (from crust to finished) Soaking/dehairing/liming Fleshing/pelt splitting and trimming Deliming/bating/pickling/tanning Shammying Soaking Wet blue splitting and shaving Neutralization/retanning/dyeing/fatliquoring Drying Spraying/coating Finishing/embossing/ironing/milling/buffing/measuring Figure 2. Indicative manufacturing processes to include in the Core Module Manufacturing processes which are not used can be excluded but their exclusion must be stated. Manufacturing processes can be aggregated for the impact assessment but this must be stated. Manufacturing processes covered by third parties and inputs and outputs of semi-finished leather (e.g. tanned Wet Blue) shall be considered and stated in the LCA study. The waste produced in the manufacturing processes shall be declared as kg of waste and kg of hazardous waste. Energy and electricity used at the manufacturing site, the emissions to air and the amount of waste generated is included. When electricity is used at the manufacturing plant and there are not primary LCA data available, country appropriated data shall be considered as specific data. The waste production impact is charged to the tannery. When a wastewater treatment plant is present outside the system boundaries of the production site, the associated emission reductions shall be included in the LCA study, taking into consideration the amount and the quality of the effluent. The technical system shall not include: Manufacturing of production equipment, buildings and other capital goods. Business travel of personnel. Travel to and from work by personnel. Research and development activities. For additional information about system boundaries concerning waste, etc., see the General Programme Instructions. 8.1.2 BOUNDARIES IN TIME The life cycle inventory (LCI) data shall be representative of the time period for which the EPD is valid (maximum three years). 8.1.3 BOUNDARIES TOWARDS NATURE Boundaries to nature are defined as flows of material and energy resources from nature into the system. Emissions to air, water and soil cross the system boundary when they are emitted from or leaving the product system. PAGE 14/24

8.1.4 BOUNDARIES TOWARDS GEOGRAPHY The data for the core module shall be representative for the actual production processes and representative of the site/region where the respective process is taking place. 8.1.5 BOUNDARIES TOWARDS OTHER TECHNICAL SYSTEMS If there is an inflow of recycled material to the production system in the production/manufacturing phase, the recycling process and the transportation from the recycling process to where the material is used shall be included. If there is an outflow of material to recycling, the transportation of the material to the recycling process shall be included. The material going to recycling is then an outflow from the production system (see General Programme Instructions). By-products of the tanning processes (e.g. fleshings, hair, etc.) shall be treated as a waste that goes to recycling, and therefore only the transport from the tannery to the place of recycling is considered. 8.2 ALLOCATION RULES Allocation rules must be defined for individual products when the manufacturing processes result in many different kinds of products and where there is only aggregate information available about the total level of emissions. Collection of product-specific information under such circumstances is to prefer to avoid allocation. The method of avoiding allocation by expanding the system boundaries is not applicable within the framework of the International EPD System due to the rationale of the book-keeping LCA approach (attributional LCA) used and the concept of modularity. If allocation cannot be avoided by dividing the unit process into two or more sub-processes and collecting the environmental data related to these sub-processes, the priorities suggested by the ISO 14040 shall be considered in the procedure definition. In practice the inputs and outputs of the system should be partitioned between its different products or functions in a way that reflects the underlying physical relationships between them; i.e. they should reflect the way in which the inputs and outputs are changed by quantitative changes in the products or functions delivered by the system. Where physical relationship alone cannot be established or used as the basis for allocation (or they are too time consuming), the inputs should be allocated between the products and functions in a way that reflects other relationships between them. For example, input and output data might be allocated between by-products in proportion to the economic value of the products. If the economic allocation has been used, a specific sensitivity analysis shall be provided to the verifier, and the monitoring of the relationship between results and current economic value shall be documented and updated. The process of slaughtering shall be treated by economic allocation (value) following the specification of Section 7.3. Surface area is used to allocate splitting activities, so the environmental impact - up to the splitting process - is equally allocated between split hide (50%) and grain leather (50%). Splitting in the beam house and splitting WB shall be evaluated separately. All calculations related to the reference flows in the core module shall be referred to the hide mass per declared unit. During these phases there is a weight variation due to the loss of material or variation in the water content. These variations shall be considered in the allocation of inflows and outflows of the specific manufacturing phases. The weight variations that have to be applied are specified in figure 3. Y is the weight of the representative rawhide ready for soaking/liming of the tannery, calculated as specified at chapter 7.3. PAGE 15/24

Manufacturing process Rawhide ready for soaking/liming Weight variation average hide Pelt (limed and dehaired hide) Y +12% Grain split ready for tanning Y - 50% Shammied, tanned and shaved grain ready for dyeing Crust (dyed and dried) Finished leather Y Y-75% Y-86% Y-86% Figure 3. Weight variations during the manufacturing processes 3 Where the LCA and EPD is done for a single article or for a family of similar articles (see clause 2, category A and B), which are made of the same rawhide type (e.g. all bull hides of a certain thickness range), it is possible to introduce specific weight variation factors. In the LCA study report these specific weight variation factors shall be justified. One kg of finished leather equates to one m 2 of finished leather. 8.3 DATA QUALITY RULES Specific data (also referred to as primary data) shall be used for the Core Module, except for the chemical and auxiliary materials for which generic data can be used. Specific data are gathered from the actual manufacturing plant(s) where specific processes are carried out and data from other parts of the life cycle traced to the specific product system under study, e.g. materials or electricity provided from a contracted supplier being able to provide data for the actual delivered services, transportation taking place based on the actual fuel consumption and related emissions, etc. For the electricity used in the process, there are two alternatives: the company buys the energy from the national or regional grid or from a specific supplier. In the first case the national/regional electricity mix shall be adopted. In the second case a specific energy mix should be used if available. Electricity production impacts should be accounted for in this priority: Renewable Energy Certificates (RECs) or Guarantee of Origin from electricity supplier Electricity supplier s residual energy mix National mix/electricity mix on the actual market (preferably residual mix, otherwise national mix The electricity mix used shall be documented. If no specific information is available for rawhide transport from slaughtering to tanneries as a cumulative generic process should be modelled as follows: the mix of transport means used shall reflect the geographical context and shall be justified. If the location of the slaughterhouse is not known, the distance between the capitals of the exporting countries and the tannery should be adopted as a reference for transport calculation; weighting values should be based on the average import ratio of the tannery for the specific country. In case the export country is generic (i.e. continent) a reference city should be chosen and justified. 3 Data origin: Tanneries involved in the PCR elaboration; these variations have to be used as fixed specific data for the representative raw hide with weight Y. PAGE 16/24

Variable t s S dt ds Rs Rt S d t = d s R s Explanation Tannery Exporter country/slaughterhouse of rawhides Total number of exporter countries/slaughterhouse for tannery t Distance from average slaughterhouse to tannery t Distance from slaughterhouse s to tannery t Amount of rawhide supplied by the slaughterhouse s to the tannery t Total amount of rawhide supplied to the tannery t Figure 4. Generic scenario for transport of rawhides from slaughtering to tannery s R t 9 DOWNSTREAM MODULE The processes listed in Section 6.3 shall be included in the downstream module. The downstream module shall be based on relevant scenarios for the geographical area in which the EPD is valid. 9.1 TRANSPORT TO AN AVERAGE CUSTOMER Transport of the product to customer shall, as a first option, be based on the actual transportation distances. As a second option, it could be calculated as the average distance of a product of that product type transported by different means of transport or, even if such data are not available, it should be calculated as a fixed long transport such as e.g.1,000 km distance transport by lorry or 10,000 km by airplane, according to product type. Transport shall be differentiated between by lorry, train, ship or airplane, considering the actual mass of leather carried and the distance covered by every different transport mode. It is possible to use average transport modes and load factors that also consider the return path. In this case the database of origin shall be stated. 9.2 END-OF-LIFE OF PACKAGING For the calculation of the impacts related to the end-of-life of packaging a typical scenario of the area in which the product is mainly distributed can be used. The transport to the recovery or treatment site of the packaging waste can be modelled with a default distance of 50 km by lorry. 10 ENVIRONMENTAL PERFORMANCE-RELATED INFORMATION As a general rule the reporting of the environmental performance-related information shall follow the logic of the EPD, divided into core, upstream and downstream module. The upstream module and downstream module are mainly based on scenarios and the tanneries' capacity to control processes is concentrated to the core module. Therefore it is possible to communicate more in detail the impacts of the core module, for example by dividing the core module and breaking down the impacts for the major phases of the tanning processes. PAGE 17/24

10.1 USE OF RESOURCES The consumption of natural resources and resources per declared unit shall be reported in the EPD, divided into core, upstream and downstream module. Input parameters, extracted resources: Non-renewable resources - Material resources - Energy resources (used for energy conversion purposes) Renewable resources - Material resources - Energy resources (used for energy conversion purposes) Secondary resources - Material resources - Energy resources (used for energy conversion purposes) Recovered energy flows (such thermal) expressed in MJ Water use divided in: - Total amount of water - Direct amount of water used by the core process The following requirements on the resource declaration also apply: all parameters for resource consumption shall be expressed in mass, with the exception of renewable energy resources used for the generation of hydroelectric, wind electricity and solar energy, which shall be expressed in MJ; parameters shall not be aggregated but reported separately. Resources which contribute less than 5% in each category shall be included in the resources list as other ; nuclear power shall be reported among the non-renewable energy resources as kg of uranium calculated by converting the thermal energy (MJ) considering a reactor of III generation with an efficiency of 33%. 10.2 POTENTIAL ENVIRONMENTAL IMPACTS The potential environmental impact per declared unit for the following environmental impact categories shall be reported in the EPD, divided into core, upstream and downstream module: Emission of greenhouse gases (expressed as the sum of global warming potential, GWP, 100 years), in carbon dioxide (CO 2) equivalents. Emission of acidifying gases (expressed as the sum of acidification potential, AP) in sulphur dioxide (SO 2) equivalents. Emissions of gases that contribute to the creation of ground level ozone (expressed as the sum of ozonecreating potential, POCP), in C 2H 4 (ethylene) equivalents. Emission of substances to water contributing to oxygen depletion (expressed as the sum of eutrophication potential, EP), in phosphate (PO 4 3- ) equivalents. Emission of ozone-depleting gases (expressed as the sum of ozone-depleting potential in mass of CFC 11- equivalents, 20 years. The recommended characterisation factors to use are available on the website, www.environdec.com. PAGE 18/24

10.2.1 SPECIFICATIONS FOR GWP CALCULATIONS This section is adopted from the General Programme Instructions, Section A.8. Both emissions to the atmosphere and removals from the atmosphere shall be accounted for the assessment of the overall GHG emissions of the product being assessed. This assessment shall include the gases arising from both fossil and biogenic sources for all products, with the exception of human food and animal feed products. Emissions and removals of biogenic carbon shall be reported separately Where some or all removed carbon will not be emitted to the atmosphere within the 100-year assessment period, the portion of carbon not emitted to the atmosphere during that period shall be treated as stored carbon. Following issues shall be taken into account: carbon storage might arise where biogenic carbon forms part or all of a product (e.g. wood fibre in a table), or where atmospheric carbon is taken up by a product over its life cycle (e.g. cement), while forest management activities might result in additional carbon storage in managed forests through the retention of forest biomass, this potential source of storage is not included in the scope of the International EPD System. GHG emissions offset mechanism shall not be used at any point in the assessment of the GHG emissions of the product. The organisation could declare its participation to some offsetting program in the other information section of the EPD or single issue EPD. If this PCR is used as a relevant CFP-PCR for Carbon Footprint calculations according to ISO/TS 14067, GWP calculation rules of ISO/TS 14067 take priority. 10.3 WASTE PRODUCTION Waste generated along the whole life cycle production chains shall be treated following the technical specifications described in the General Programme Instructions. When the amount of waste has to be declared, the following information shall be reported: Hazardous waste, in kg (as defined by regional directives) Non-hazardous waste, in kg 10.4 OTHER ENVIRONMENTAL INDICATORS The following indicators per declared unit shall be reported in the EPD, divided into core, upstream and downstream module: Materials/substances that are subject to legal requirements and customer demands (in particular Cr and formaldehyde) 10.5 ADDITIONAL ENVIRONMENTAL INFORMATION Information on the producer related to the application of Environmental Management Systems (EMAS, ISO 14001, etc.) as well as the adoption of processes or use of substances to reduce environmental impact, can be reported. Use of recycled materials as well as energy from renewable sources can be reported, according to law. Furthermore in the EPD have to be declared the percentages of the different ranges of thickness that constitute the finished leather. In case the EPD is done for a single product (case A, see clause 2) or a family of similar products (case B, see clause 2), the EPD shall declare some further characteristics of the product: the end-use of the finished bovine leather product; the geographical origin of the rawhides used for the production of the analyzed leather; if the finished bovine leather is full grain leather or corrected grain leather; PAGE 19/24

if the finished bovine leather is part of one or more of these categories: aniline leather, semi aniline leather, pigmented leather and/or nubuck leather. Further characteristics that have to be declared in case A and B are listed in the table in annex 1. The type of characteristics that have to be declared depend on the end-use of the leather as specified in the table. In case the EPD is done for a family of similar products (case B, see clause 2) the values of the physical characteristics have to be reported as weighted ranges of the different products that are part of the family under study. 11 CONTENT OF THE EPD As a general rule the EPD content: must be verifiable; must not include rating, judgements or direct comparison with other products. EPD s can be published on several languages, but if the EPD document is not available in English, the organisation shall provide a summary in English including the main content of the EPD to be available on www.environdec.com. The EPD cover page (if existent) shall as a minimum include relevant information about the product, such as name and an image, the EPD logotype and date of publication and validity. 11.1 PROGRAMME-RELATED INFORMATION The programme-related part of the EPD shall include: Reference to the International EPD System as the programme operator EPD logotype Reference PCR document(s) and CPC codes EPD registration number as provided by the Secretariat Date of publication and validity. If relevant, the revision schedule may be indicated. Declaration of the year(s) covered by the data used for the LCA calculation Geographical scope of application of the EPD Reference to the website www.environdec.com and other relevant websites for more information For sector EPDs specific indication shall be given upfront stating that the document covers average values for an entire or partial product category (specifying the percentage of representativeness) and, hence, the declared unit is not available for purchase on the market. 11.2 PRODUCT-RELATED INFORMATION 11.2.1 SPECIFICATION OF THE MANUFACTURING COMPANY See 2.1. 11.2.2 SPECIFICATION OF THE PRODUCT See 2.2. PAGE 20/24

11.2.3 DECLARED UNIT See 3. 11.3 CONTENT DECLARATION See 4. 11.4 ENVIRONMENTAL PERFORMANCE-RELATED INFORMATION 11.4.1 USE OF RESOURCES See 10.1. 11.4.2 POTENTIAL ENVIRONMENTAL IMPACTS See 10.2. 11.4.3 WASTE PRODUCTION See 10.3. 11.4.4 OTHER ENVIRONMENTAL INDICATORS See 10.4. 11.5 ADDITIONAL ENVIRONMENTAL INFORMATION See 10.5. 11.6 MANDATORY STATEMENTS The following information is mandatory to include in the EPD: any omission of life cycle stages not making the EPD cover the full life cycle, with a justification of the omission, means of obtaining explanatory materials, for example references to chosen methodologies, a statement that EPDs within the same product category but from different programmes may not be comparable. The EPD shall also give the following information about the verification process: Product Category Rules (PCR) review was conducted by: The Technical Committee of the International EPD System. Chair of the review: Rita Schenck Contact via info@environdec.com. Independent verification of the declaration and data, according to ISO 14025:2006: EPD process certification EPD verification Third party verifier: Name and contact information Accredited or approved by: Name of the accreditation body. For individual verifiers: The International EPD System PAGE 21/24

11.7 DIFFERENCES VERSUS PREVIOUS VERSIONS OF THE EPD The main causes for changes in environmental performance in comparison with previous EPD versions shall be described. 11.8 REFERENCES The EPD shall, if relevant, refer to: The underlying LCA The name, CPC code and version number of the PCR used Other documents that verify and complement the EPD Instruction for recycling, if relevant The General Programme instructions of the International EPD System ISO 11646:2014, Leather - measurement of area 12 VALIDITY OF THE EPD The validity of the EPD is set at three years after which the declaration must necessarily be revised and reissued. During the validity period surveillance follow-up shall be agreed with the verifier in order to evaluate if the content is still consistent with the current situation. It is not necessary to perform a full LCA, only the monitoring of main parameters is requested. The tanning sector is characterized by continuous adjustments of the tanning recipes with minimal qualitative and quantitative changes. If the tannery declares that the mix of chemical products used in the year of surveillance is equivalent to the period at which the LCA study of the EPD is based on, the reference flows for chemical data don't have to be changed in the surveillance LCA. The surveillance verification could be organised as documental check aimed to the evaluation of the main environmental aspects relevant for the LCA calculation. The EPD shall be updated if one of the environmental indicators has worsened by more than 10% compared with the data currently published. 13 CHANGES IN THIS PCR DOCUMENT VERSION 1.0, 2011-09-28 Original version, based on PCR 2007:03. VERSION 2.0, 2015-06-11 Compliance with to the General Programme Instructions, Version 2.01. Use of the latest template The system boundary for the core model now explicitly excludes research activities and business travel by personnel. Specification for GWP calculation added from General Programme Instructions Change in reference database for cattle raising processes (from LCAfood to Agrifootprint) Update of cut-off rules for chemical products used in the core module PAGE 22/24