The U.S. Hide, Skin and Leather Association (USHSLA) has submitted comments to the European Commission commending its efforts to standardise and simplify the model certificates for the importation of animal products, including hides and skins, into the EU.
In a letter addressed to the EU’s Directorate-General for Health and Food Safety dated November 5, the USHSLA expressed “support for the purpose and spirit behind the EU’s proposed implementing regulation”, but detailed concerns about the language proposed in the regulation and model certificate and underscored the negative economic consequences for the U.S. cattle, beef, hides and leather industries.
Under the Draft Implementing Regulation – Ares (2018)5116374-05/10/2018, Annex II for import of certain animals goods, animal by-products or products of animal origin into the EU, an official seal number must be affixed to closed containers but which only applies if it is done so “under the supervision of the competent authority issuing the certificate”, meaning an official from the U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS) must be physically present to supervise the loading of the goods into the containers.
The USHSLA claims this new requirement, if interpreted to mean an employee of the competent authority (APHIS) must be present at all times during the loading of hides and skins into a container, “would effectively stop all U.S. exports to the EU of animal products under APHIS certification that are transported in ‘closed containers’” and that “this would be a tremendous disruption to trade in these products, especially for hides and skins”. The association proposes that relevant language in the Model Official Certificate be changed from “under the supervision of the competent authority” to “under the responsibility of the competent authority.”
“We believe this small but extremely important change to the proposed certificate Annex language would preserve the long term understanding between the EU and APHIS and avoid substantial trade interruptions in the hides, skins and leather industries,” says the USHSLA.