Q&A: The impact of the recent European Commission decision to exclude leather from the EU Deforestation Regulation

Q1: What is the European Commission’s Deforestation Regulation?

The European Union Deforestation Regulation (EUDR) is an EU law designed to reduce the EU’s contribution to global deforestation and forest degradation. 

The regulation aims to:

• Reduce global deforestation linked to EU consumption.
• Cut greenhouse gas emissions associated with forest loss.
• Protect biodiversity and ecosystems.
• Promote more transparent and sustainable supply chains.

It requires companies placing certain commodities and products on the EU market—or exporting them from the EU—to prove they were not produced on land that was deforested after December 31, 2020. This would include full traceability of the listed commodities and products back to their origin, e.g. for leather, back to the birth farm of the animal from which the hide was sourced.

Q2. What products does it cover?

The EUDR currently applies to seven key commodities and many products made from them. These are listed in Annex 1 of regulation and include:

• Cattle (including bovine hides and leather)
• Cocoa
• Coffee
• Oil palm
• Rubber
• Soy
• Wood

Q3. What is the European Commission proposing for leather?

The European Commission has proposed excluding bovine hides and leather from the scope of the EUDR. This means that, assuming the changes are approved, bovine hides and leather would no longer be subject to the requirements of the regulation.

The Commission concluded that:

• the low value of cattle skins and hides and asymmetries in trade flows between meat and hides meant that tanners would have limited leverage to obtain information required to comply with the EUDR;
• the leather value chain was distinct from the meat value chain and as such, the links to farms was reduced and would result in a high compliance burden on the industry;
• as leather goods are not covered by the EUDR, importers of finished leather goods (such as footwear, handbags or other articles) could continue to place them on the Union market without being subject to the due diligence obligations, while operators producing leather goods within the EU would face compliance requirements, creating an unbalanced approach.

Q4. What does this mean for leather manufacturers and brands?

If adopted, leather manufacturers, tanneries, and brands would no longer need to demonstrate EUDR compliance for bovine hides, skins and leather. 

Q5. Does this mean leather is no longer expected to be sustainably sourced?

No. Although leather may be excluded from the EUDR, brands are still expected to source responsibly. Many companies will continue to follow environmental, animal welfare, and traceability standards to meet customer expectations, corporate sustainability commitments, and other regulatory requirements.