Leather excluded from the EUDR: what changes for importers from 7 October

THURSDAY, 24 SEPTEMBER 2026

Delegated Regulation 2026/2102 removes hides and bovine leather from Annex I. But beef stays in, and in 2030 the Commission will reopen the file.

Leather excluded from the EUDR is now a legal fact: from 7 October 2026 raw hides, tanned hides and bovine leather leave the list of products covered by the EU deforestation regulation. Importers of these materials will therefore not have to file the due diligence statement that would have become mandatory at the end of December.

What Delegated Regulation 2026/2102 provides

The change comes with Delegated Regulation (EU) 2026/2102, adopted by the Commission on 13 July and published in the Official Journal of the European Union on 17 September. The act rewrites Annex I of Regulation (EU) 2023/1115, the EUDR, which is the table stating which customs codes fall under the obligations. Parliament and Council had two months to object: the scrutiny period closed in mid-September with no objections.

• 13 July 2026: adoption of the delegated regulation by the European Commission.
• 17 September 2026: publication in the Official Journal; entry into force on the twentieth day after, 7 October 2026.
• HS codes 4101, 4104 and 4107: raw hides, tanned or crust hides and finished bovine leather leave Annex I.
• 1.5%: the share of a bovine animal's value at the abattoir represented by the raw hide, according to the 2026 UNIDO guidelines cited by the tanning industry.
• 30 December 2026 for large and medium companies, 30 June 2027 for micro and small ones: the EUDR application dates, which remain unchanged.

Leather excluded from the EUDR: the Commission's reasons

The official rationale rests on two arguments. The first is economic: leather is a by-product of meat and dairy farming, and its weight in the animal's value is marginal, so it is not leather that decides whether a pasture is cleared from forest. The second is practical: tanneries buy hides from slaughterhouses and collectors, often along fragmented international chains, and are in no position to trace the plot of land the animal came from, which is exactly the geolocated data the regulation requires.

A consistency problem also weighed in. Finished leather products, such as bags and footwear, were not listed in the Annex: keeping the material in and the article out would have penalised European tanneries against those who work leather outside the Union and sell the finished product in Europe.

The other products going in and out

The delegated regulation does not cover leather only. Also leaving the scope are conveyor and transmission belts and other vulcanised rubber articles, most retreaded tyres, soybeans for sowing and car and aircraft seats. Coming in are soluble coffee, frozen cattle tongues and some oleochemical palm oil derivatives, but for these the obligation only starts on 30 December 2027.

Cattle remain one of the seven regulated commodities, together with cocoa, coffee, oil palm, rubber, soy and wood. Beef therefore remains subject to due diligence, and the same applies to the wood-derived products that stay in the Annex.

What it means for importers

For those buying tanned leather or finished leather outside the Union, the change is clear-cut: on codes 4101, 4104 and 4107 no due diligence statement will be needed, nor the collection of the farms' geographic coordinates. It is an obligation that had not started yet, since the EUDR applies from 30 December 2026, but many companies were already asking suppliers for data that is no longer legally required.

This does not close the issue. The exclusion concerns the deforestation regulation, not other rules: checks on chemical substances in finished leather remain, as do the traceability requirements many brands include in their specifications. The industry has developed the technical standard EN 18199 on minimum traceability levels, and it is worth asking suppliers whether they apply it.

The useful check, for importers of composite articles, concerns the materials that stay in scope. A product combining leather and wood, or shipped in paper and cardboard packaging, should be checked component by component against the customs codes actually declared, not by its main material.

The 2030 review question

The exclusion is not final. The delegated regulation provides that the Commission will reassess leather's position at the EUDR review scheduled for 2030, based on environmental, economic and trade data. Environmental organisations contest the choice and point out that pasture expansion remains the leading direct cause of deforestation in the Amazon.

The data does not show that leather will return to the regulation, but it signals that the window is a few years long. For those building a leather supply chain today, it is worth not dismantling entirely the origin documentation already collected: it may be needed again.

With La Merce, importers of leather goods from 7 October separate codes 4101, 4104 and 4107, now out of the EUDR, from the wood or paper components that remain in scope, and collect from the supplier only the data actually required.

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