Written evidence submitted by the British Fur Trade Association (FUR0053)

 

ABOUT THE BFTA

HOW LARGE IS THE FUR TRADE IN THE UK?

 

  1. According to research published by the University of Copenhagen, in 2016 UK retail sales of fur products were £162m, an increase of 350% since 2011.
  2. We’re seeing growing support for fur sales on the high street. Canada Goose chose the UK to open their first European flagship store in November 2017 whilst Harvey Nichols have reversed their moratorium on selling fur.
  3. We’re experiencing a growth in BFTA membership, particularly among young, independent designers.
  4. Fur also remains popular among fashion students. The BFTA is working with 14 fashion colleges and universities across the UK to provide factual information regarding sustainability, ethics, animal welfare, fur production and processing and traceability. We give annual keynote lectures to students and help develop their technical skills. We do this by working with college staff and technicians to strengthen the fur component of courses, running practical workshops and arranging demonstrations with BFTA furriers.

 

HOW EFFECTIVE IS THE CURRENT LAW WITH REGARDS TO ANIMAL FUR, AND DOES IT GO FAR ENOUGH?

  1. The fur trade believes it’s vital that consumers can make informed buying decisions. Clear, concise, accurate and relevant labelling is key to this. It is illegal to intentionally misrepresent a product so you cannot sell real fur with a fake fur label or vice versa. It is the responsibility of Trading Standards to enforce compliance with existing legislation and we strongly encourage the Committee to ensure Trading Standards carry out their role in enforcement.

 

  1. Current labelling regulation that covers this area is contained in the EU’s Regulation 1007/2011 on textile fibre names and related labelling. In this, the presence of fur – or a number of other animal products – needs to be indicated only when the collective weight of these parts is less than 20% by weight of the textile component. The required label “Contains non-textile part of animal origin” is very general and fails, in our view, to provide clear information to consumers as to precisely which animals have been used.

Products outside of the scope of this directive

  1. In the current Regulation, only textile products are covered. This is defined as a product containing at least 80% textiles as identified from a list with contains synthetics but also items of animal origin including wool and silk. So an acrylic hat with a wool bobble is not covered. Nor for example, a cashmere hat with goat hair bobble. But a woollen hat with a fur bobble is. But only if the fur is less than 20% by weight of the total product.
  2. This regulation is therefore limited in providing meaningful information to consumers and also in the scope of products that come within its remit.
  3. It begs the question, what would a new, improved fur labelling scheme look like? We explore this and outline our vision in the next section.

 

WHAT IMPROVEMENT, IF ANY, CAN BE MADE TO THE CURRENT LABELLING OF FUR PRODUCTS AND FAKE FUR PRODUCTS, AND HOW COULD THESE BE ENFORCED?

CLEAR LABELLING SCHEME – CLARITY ON FUR AND FAKE FUR PRODUCTS:

  1. The incorrect labelling of products as fake fur when they contain real fur is an issue that concerns our industry. Consumers should be encouraged to report cases of mislabelling to Trading Standards in order to help crack down on this practise. It is clear, however, that distinguishing between real and synthetic furs can sometimes be difficult. That’s why we have recently written to Trading Standards to offer our support and expertise to help develop and implement a training programme to improve the abilities of their officers in identifying mislabelled products.

 

Clear label on all real fur products

  1. We recommend that all products that contain real fur should be labelled with the common name of the fur type, for example “Contains Mink Fur”. This should be made a legal requirement. This on its own does not address animal welfare standards (see next section) but would provide basic information about the type of fur used to create the product and provide a solution to the primary concern of this inquiry.

Clear label on all fake fur products

  1. Similarly, fake or synthetic fur products should also be labelled clearly. Not only does the public expect to see clear labelling on real fur, but they expect to see clear labelling on products that are synthetic fur, and not just as a way to distinguish between the two but in recognition also of the growing concern about the environmental impact of plastic and synthetic materials.

 

  1. Microplastics and microsynthetic fibres are now ubiquitous in aquatic and terrestrial ecosystems globally. Their abundance is set to increase as consumption of plastics and use of synthetic fibres in clothing continues to expand. The UK has already recognised this threat by banning the use of microbeads in personal products and yet the public are inadvertently contributing to the problem through the growing use of synthetic materials and, in particular, synthetic fibres.

 

  1. Earlier this year, the SIFO Research Institute at Oslo and Akershus University College of Applied Sciences published an extensive literature review on global research into Microplastic Pollution from Textiles and the results are alarming:

 

  1. In the oceans alone, it has been estimated that the mass of plastics by 2025 will equal one third of the mass of all fish (Mather and Ravasio 2016).

 

  1. Plastics accounted for 65% of debris recorded in the Tamar Estuary in the UK (Browne et al. 2010).

 

  1. Synthetic fibre production and consumption contributes significantly to the volume of total plastic waste in landfills and incinerators. Although accurate statistics are not compiled globally, the mass of discarded clothing is estimated to be in the order of millions of tonnes (Cobbing and Vicaire 2016).

 

  1. Quantities of microfibres in the influent of Water Treatment Plants were reported to range from 550 million to 440 billion fibres per day these were found to resemble those used in clothing, mostly polyester (78%) and acrylic (22%).

 

  1. Microfibres, predominantly of PVC, polyester and synthetic polyamide (nylon), make up 85% of all anthropogenic debris on global shorelines. Browne et al. (2011)

 

  1. Estimates of the proportion of microplastics in oceans that originates from synthetic textiles may be up to 35% Boucher & Friot (2017).

 

  1. Microplastic particles in aquatic environments have been found to be readily, and even preferentially, ingested by aquatic species. Ingestion has now been shown to occur across organism types from zooplankton to vertebrates.

 

  1. There is a direct risk to human health:

 

 

  1.            Microplastics retained in organisms used as human food sources can enter the human body where their fate is not known. This is particularly relevant to textile microfibres due to their greater retention in small organisms where entanglement reduces natural passage through the body; 


 

  1.            Microplastics easily adsorb chemicals from surrounding water, raising the risks of introduction of sorbed organic carcinogenic and non-carcinogenic compounds; 


 

  1.            Biological risks whereby microplastics host bacteria including some bacteria linked with human gastrointestinal infections (McCormick et al. 2014).

 

  1. A major primary source of these microplastics is the shedding of fibres from synthetic textiles during use, washing and disposal. There is also a risk that inhaled microplastic fibres may deposit in lung tissue due to their size and shape, and have been associated with tumours (Pauly et al. 1998).

 

  1. The SIFO have identified the extreme levels of both demand and waste of synthetic textiles by the fast fashion movement as a major contributor to the problem. They recommend promoting long-lasting garments (‘slow fashion’) based on increasing the proportion of natural, biodegradable fibre in the wardrobe, noting that “…fibres of plant or animal origin biodegrade naturally to harmless compounds which return essential nutrients back to soil or water for organism growth” and that “…policies and technologies to substantially reduce release of textile microfibres are urgently needed, in combination with consumer education programs to move away from overconsumption and arrest the current growth in ‘fast fashion’.

 

  1. However, even if little new plastic debris contamination were added to the environment, the legacy of plastic items, including textiles discarded to landfill sites, would ensure quantities of microplastic pollution continued to increase into the future. Hence, managing microfibre pollution is both a current and future challenge for the apparel and textile industries.

 

 

Recommendation

  1.            The growing awareness and concern among the public and environmental scientists of the devastating impact of the production, use and disposal of plastic and synthetic materials, particularly in marine ecosystems and landfill warrants a better labelling system for synthetic fur. So that consumers can make fully informed buying decisions, we would support a mandatory label on all synthetic fur products which advises consumers about the environmental risk posed by these materials. For example: ‘Contains synthetic fur. Please dispose of this product responsibly.’ Enforcement of such labelling would be the responsibility of Trading Standards.

 

E-commerce

  1. In a world of rapidly growing e-commerce consumers expect accurate product information however they make their purchases. Online retailers should be encouraged to display the information contained on all product label and we would welcome any moves to include details about the presence of real animal fur as part of that information online.

 

FURMARK – A COMPREHENSIVE ANIMAL WELFARE LABELLING SCHEME FOR FUR 

  1. We recognise that consumers expect to be able to make informed buying decisions. This means that clear, concise, accurate and relevant labelling is vital. As outlined above it’s our view that EU Regulation 1007/2011 does not go far enough in this respect. What is required is a new labelling scheme which provides clarity and reassurance for the consumers both here in the UK and globally.

 

  1. This is given increased impetus against the backdrop of both a growth in the retail of fur in the UK and changes in the type of produce that contains fur. Clothing containing fur (particularly trim) need not be prohibitively expensive and the fur market is increasingly associated with high street fashion products at a price point that makes them accessible to most people.

 

 

  1. FURMARK is a new comprehensive certification and traceability program that – from its launch in 2020 – will cover sustainability, animal welfare and the dressing and dyeing of fur. It is the fur industry’s vision for an umbrella certification and labelling scheme bringing together a number of global welfare certification standards. FURMARK will include fur produced in European fur farms and certified by Europe’s new WelFur scheme covering both mink, fox and finnraccoon and farmed and wild fur certified in the USA and Canada. When the FURMARK label is launched it will offer real reassurance about animal welfare standards.

 

  1. Although there is a regional variation in processes between the US, Canada and Europe, FURMARK ensures that protocols must be science-based, approved by independent experts and publicly available.

 

  1. In summary by 2020 this new welfare certification scheme will:

 

 

WelFur, Europe’s animal welfare certification scheme

  1. WelFur is a certification programme developed by independent scientists and based on animal welfare research conducted over the past 30 years. The project was voluntarily initiated by Fur Europe in 2009 and designed to provide reliable animal welfare assessment, consumer transparency and improvement of animal welfare in the European fur sector. The programme has been developed by independent scientists from seven European universities[1] and is based on the principles of the European Commission funded Welfare Quality® project (http://www.welfarequality.net/everyone). The system works as a farm level certification scheme that incorporates various angles on animal welfare considering all important welfare parameters, including:

 

 

  1. The principles are further divided into 12 welfare criteria. To assess these criteria the scientists reviewed 30 years of fur animal welfare science and, based on that, established species-specific measures to be assessed during farm assessments. For mink the researchers have selected 22 measurements and for fox scientists selected 25 measurements.

 

  1. The first protocols for farmed species (fox and mink) were published in 2013 and 2014 respectively and then tested in 10 different countries during 2015 and 2016. The protocol for Finnraccoon is currently in progress and the clear aim is that the protocols will be finalised, reviewed and implemented before 2020. These protocols work as science-based ‘manuals’ for the third parties assessing the individual fur farms. Third party assessments are undertaken by the independent global certification body Baltic Control. Baltic Control is internationally recognised and works for the UN, the EU and in Denmark, where they are the responsible auditors for the Danish Animal Protection Society’s animal welfare programme.

 

  1. In order to be able to participate in the WelFur certification programme, farmers must fulfil industry minimum standards. These standards are based on cage sizes as well as the number of animal per cage used, based on a Council of Europe Recommendation (1999). In most countries this is currently part of national law. Compliance with minimum standards is part of the assessment undertaken by Baltic Control.

 

  1. Since the official start of the implementation of WelFur in January 2017, approximately 80% of fur farmers in Europe signed up to start the assessments. European fur farmers’ willingness to participate in a certification programme measuring and documenting animal welfare on fur farms is significant. European fur farmers know that animal welfare on farms is a central part of the sustainable development of the fur sector.

Therefore, the main objectives of the programme are:

 

  1. To provide a reliable on-farm animal welfare assessment system based on scientifically proven measures and independent third-party assessments. 

  2. To improve animal welfare on European fur farms through analysis of the assessment data and education of farmers. 


 

  1. To provide consumer transparency on the welfare status on European fur farms by publishing assessment data. 


 

  1. In order to receive a WelFur certificate, a farm needs to be visited three times (one visit in each period of the production cycle). Each following year, the farm will need to be visited randomly in one of the 3 periods to maintain the certificate. A farm visit takes between 5-8 hours and based on the assessment result Baltic Control is solely in charge of issuing the WelFur certificates.

 

  1. Besides from that, the science-based scheme serves as a tool for farmers who want to improve animal welfare standards on their farms by providing them with support from specially trained WelFur advisors. This gives space for boosting areas in the farms where animal welfare can be improved under the supervision of animal experts.

 

  1. It is Fur Europe’s objective to certify all 4,000 European mink and fox farms between 2017-2020 and the approximately 100 European finnraccoon farms.

 

  1. By December 2018, the two European auction houses, Kopenhagen Fur and SAGA Furs, as well as the Canada- based North American Fur Auctions (NAFA) will be able to sell the first WelFur certified mink and fox skins. From 2020 also it will be possible to buy WelFur certified finnraccoon skins. By 2020 all European fur sold through the three international auction house will have to be WelFur certified. Welfur and similar certification schemes in USA and Canada, for both farmed and wild fur, will be brought together under the FURMARK by 2020.

 

  1. Traceability
  2. WelFur offers a reliable traceability system for consumers who are becoming more vocal when expressing concerns about traceability and the available information about the condition on farms. According to the latest survey by the European Commission from 2016 mapping the attitudes of Europeans towards animal welfare, almost two thirds of the respondents say they would like to have more information on how animals are treated.[2]

 

  1. To address the increasing expectation of consumer transparency, the WelFur scheme (as part of the FURMARK labelling scheme) will ensure the consumer knows that fur in any product comes from European fur farms with good welfare standards by means of objective scientific research, regardless of whether the product is composed of skins from different fur farms. The skins will arrive at the auction houses with a barcode and, as of December 2018, they will also arrive with a WelFur certificate from the farm.

 

WHAT IMPROVEMENTS SHOULD BE MADE TO THE REGULATION OF THE FUR INDUSTRY?

  1. The fur trade is already highly regulated. Around 90% of fur is produced on licensed farms that must operate under strict state, regional or national regulations.

 

  1. The remaining 10% is sourced from sustainable populations of wild species, mostly from Canada and USA which are signatories to the Agreement on International Humane Trapping Standards (AIHTS). Trapping is regulated by state, provincial and territorial wildlife biologists. Population management takes place for various reasons: to protect property and habitat; to prevent the spread of disease and to provide income for people living in rural or remote regions where alternative employment is often difficult to find. There is no trade in endangered species and the Convention on the International Trade in Endangered Species (CITES) is strictly adhered to.

 

  1. The use of chemicals is also highly regulated and all members of the International Fur Dressers and Dyers are fully compliant with European REACH (the Registration, Evaluation, Authorisation and restriction of Chemicals) which came into force on 1st June 2007. 

 

WHAT OPPORTUNITIES DOES BREXIT OFFER TO CHANGE CURRENT LEGISLATION?

  1. The UK fur trade fully supports the European fur sector’s commitment to WelFur and will remain an active partner after Brexit. Whatever the future relationship between the UK and Europe, we have an opportunity to make changes to the labelling of fur products in the UK to provide greater consumer assurance.

 

CONCLUSION

In summary:

 

  1. We recommend compulsory labelling of all products which contain fur, identifying the type of fur being used to clearly indicate the presence of real fur. We are happy to contribute to the process of setting up this labelling scheme with other interested parties.
  2. We would support the establishment of a new mandatory label for all synthetic fur products which both reassures consumers that fur is not real but also makes clear the environmental risks posed by these materials.
  3. FURMARK will be fully implemented shortly after Brexit, to provide further assurance to consumers that the fur sector is fulfilling its welfare and environmental responsibilities.

 

 

February 2018

1

 

[1]1 University of Eastern Finland (Department of Biosciences), MTT Agrifood Research, Finland (Animal Production Research), Aarhus University, Denmark (Department of Animal Health and Bioscience), Norwegian University of Life Sciences (Department of Animal and Agricultural Sciences),

Swedish University of Agricultural Sciences (Department of Animal Environment and Health), University of Utrecht, The Netherlands (Department of Animals in Science & Society), French National Institute of Agronomic Research.


 

[2]http://ec.europa.eu/commfrontoffice/publicopinion/index.cfm/Survey/getSurveyDetail/instruments/SPECIAL/surveyKy/2096