Tramaproof / Regulations / EUDR and leather

Is leather covered by the EUDR? Not since 18 September 2026.

No. Since 18 September 2026 bovine hides and leather are no longer covered by the EU deforestation regulation, Regulation (EU) 2023/1115. Commission Delegated Regulation (EU) 2026/2102 deleted them from its Annex I, so bovine leather needs no due-diligence statement under the EUDR. Their possible inclusion will be part of the general review of the regulation in 2030.

InstrumentRegulation (EU) 2023/1115, Annex I as amended by Delegated Regulation (EU) 2026/2102
Bovine leatherOut of scope since 18 September 2026: headings ex 4101, ex 4104 and ex 4107 deleted
PublishedOfficial Journal of 17 September 2026, in force the following day, with no deferred date for the deletion
Next reviewThe inclusion of hides, skins and leather of cattle will be part of the general review in 2030
The regulation applies30 December 2026; 30 June 2027 for micro and small undertakings

What changed

Annex I of the EUDR lists the products the regulation covers. Until 17 September 2026 it listed, under the commodity cattle, three leather headings: raw hides and skins (ex 4101), tanned or crust hides and skins (ex 4104), and leather further prepared after tanning or crusting (ex 4107).

Commission Delegated Regulation (EU) 2026/2102 of 13 July 2026 deletes the three entries. It was published in the Official Journal on 17 September 2026 and entered into force the following day. Some products it adds to the Annex apply only from 30 December 2027; the deletion of leather carries no such date and applies from entry into force.

Why the Commission removed leather

The recitals give the reasons. The leather value chain is distinct from the meat value chain, trade flows in meat and hides are asymmetric, and hides are worth relatively little compared with meat. Operators in the Union therefore have limited leverage to obtain from their suppliers the information the regulation requires. The recital adds that covering hides while leather goods further downstream were excluded made the approach fragmented for the sector.

The question is not closed. Under Article 34(2), the evaluation of the regulation's scope, including hides, skins and leather of cattle and derived products, is part of the general review in 2030, and the Commission will keep monitoring the products the amendment touched.

What it means in practice

For a tannery that places bovine leather on the EU market, and for a brand that buys it, the EUDR no longer requires due diligence or a due-diligence statement for that leather. Finished leather goods such as shoes, bags and belts were not listed in Annex I either.

A reference number collected for leather under the EUDR therefore answers no legal requirement today. Other rules on leather are unaffected by this change.

What the EUDR still covers that can reach fashion

The seven commodities remain: cattle, cocoa, coffee, oil palm, rubber, soya and wood. Three entries of the amended Annex I are the ones a fashion company is most likely to meet.

  • Articles of apparel and clothing accessories of vulcanised rubber, gloves included (ex 4015), when made with natural rubber from Hevea brasiliensis. Synthetic rubber is not covered, and neither are used and second-hand products.
  • Articles of paper and paperboard (ex 48), when placed on the market as products in their own right. Packaging used only to support, protect or carry another product, and labels or information material that only accompany it, are not covered.
  • Natural rubber and vulcanised rubber in plates, sheets and strips (ex 4001, ex 4008), again only from Hevea brasiliensis; used and second-hand sheets and strips are excluded.

The dates

For the products it still covers, the regulation applies from 30 December 2026 to operators and traders, and from 30 June 2027 to micro and small undertakings established by 31 December 2024. Both dates were set by Regulation (EU) 2025/2650.

Questions about the EUDR and leather

Is leather covered by the EUDR?

No, not since 18 September 2026. Delegated Regulation (EU) 2026/2102 deleted raw hides and skins, tanned or crust hides and skins, and further prepared leather of cattle from Annex I of Regulation (EU) 2023/1115.

Does a tannery still need an EUDR due-diligence statement for bovine leather?

Not under the EUDR. With the three headings deleted, bovine leather is not a relevant product, so the due-diligence obligations and the statement do not apply to it.

Could leather come back into scope?

The recitals state that including hides, skins and leather of cattle will be part of the general review of the regulation in 2030, under Article 34(2). Until an amendment is adopted, leather stays outside.

What does the EUDR still cover for a fashion company?

Among others, articles of apparel and clothing accessories of vulcanised natural rubber (ex 4015) and articles of paper and paperboard sold as products in their own right (ex 48). Packaging and labels that only accompany another product are not covered.

When does the EUDR apply?

From 30 December 2026 for operators and traders, and from 30 June 2027 for micro and small undertakings established by 31 December 2024.

Regulations

The rules that do apply to fashion, each with its dates and its sources.