EUDR and Pakistan Leather: What the Scope Change Means

The Commission deleted three leather entries from Annex I, in force from 18 September 2026

The act is Commission Delegated Regulation (EU) 2026/2102. It amends Annex I to Regulation (EU) 2023/1115, the deforestation regulation itself. Its stated purpose is a set of limited technical fixes, but the published text both adds products and removes them. Three of the removals are leather.

Together, those three entries covered the chain from the fresh hide to the finished leather, so deleting them takes leather out of scope at every stage of preparation. The same act removed conveyor and transmission belting of vulcanised rubber, other vulcanised rubber articles and soybeans for sowing, and it narrowed the retreaded tyre entry to tyre treads.

It also added products, applying from 30 December 2027: frozen cattle tongues, soluble coffee, and a list of palm oil derivatives and oleochemicals. The Commission's deforestation regulation overview lists those additions and their dates, on the timetable it already set out. It says nothing about the deletions. That silence is how the old reading, with leather still in scope, survived a first check.

An exporter who was told last year that leather was in scope was not misled at the time. The position has moved since.

The Commission cited a separate leather value chain and trade-flow asymmetries

The recitals set out the reasoning. The Commission pointed to the differentiation of the leather downstream value chain from the meat value chain, and to asymmetries in trade flows.

The first is a factual observation about how hides move. A hide is a by-product of an animal raised for meat. On its way to a tannery it may pass through several hands, and each of them changes what can be documented about where the animal came from. A regulation built to trace a commodity back to a plot of land therefore sits awkwardly on a material whose supply chain was organised around a different product.

The trade flows raise a practical problem. A hide may leave one country as a raw material and be finished in another, and that flow does not line up with the point at which deforestation risk could be assessed. The Commission described those asymmetries as part of the basis for the change.

The Commission's announcement of the adopted act records the removals. So does its regulatory update for September 2026, which lists leather alongside retreaded tyres and soybeans for sowing.

Live cattle, the application dates and the 2020 cut-off are unchanged

Live cattle remain a covered commodity. Their entry was kept as a consolidated tariff line, and the accompanying note narrows it to cattle of the genus Bos, excluding buffalo and bison. A programme covering cattle hides is now out of scope. A programme covering live animals is not.

The obligations on operators handling cattle, soy, palm oil, wood, cocoa, coffee and rubber are unchanged, and so are their dates. Large and medium operators apply the regulation from 30 December 2026. Micro and small operators follow on 30 June 2027, except those already covered by the EU Timber Regulation, who start on 30 December 2026.

The cut-off is untouched. A product is deforestation-free only if it was produced on land not subject to deforestation after 31 December 2020. Taking leather off the list removes the duty to prove that for leather. It does not alter the standard for the commodities still listed.

Contracts are a separate question. A removal by delegated act is a change in EU law of the kind buyers hear about late, and an exporter whose European customer still has an EUDR clause in a purchase contract has a commercial conversation to have, whatever the regulation now says.

Chemical rules still bind Pakistani leather, and they most often decide whether a shipment moves

The obligations below apply to leather independently of the deforestation regulation, and several of them reach further into a tannery than EUDR ever did.

REACH limits apply to the finished article whatever the forest rules say. Chromium VI is the classic failure. It is a processing outcome, not a property of the raw material, so it can vary between batches from the same tannery.

On traceability, the Digital Product Passport is the next obligation to reach leather and footwear.

Keep the origin records you started, at a proportionate level of effort

An exporter who began mapping hide sources has two reasons to keep the work.

First, the record answers questions other regimes ask. Buyers doing due diligence under the Corporate Sustainability Due Diligence Directive (CSDDD) ask for supply chain visibility through a cascade of questionnaires, and a mapped hide source is direct evidence of it. Tti Labs' sustainability services, which support this work, treat traceability as a standing requirement.

Second, scope can move again. Leather was added at one point and removed at another, both times by amending a list. An exporter with an accurate record can respond in either direction without starting over.

Keep the file current, with less effort than a full EUDR programme and more than none. Put the effort saved into the chemical and material compliance that still governs each order.

What Tti Labs tests and inspects for leather and footwear exporters

• Testing under ISO/IEC 17025 accreditation through PNAC LAB-022, in a laboratory that has served Pakistan's leather and footwear industry since 2012.

• Leather and footwear testing covering physical and mechanical performance, colourfastness, and chemical and analytical testing, aligned to EN, ISO, AATCC, ASTM, SATRA and IULTCS methods.

• Chromium VI screening by ion chromatography to EN ISO 17075-2.

• Genuine leather verification by microscopy, FTIR and structural analysis.

• Inspection across the production cycle: pre-production and during-production inspection, pre-shipment inspection and loading supervision.

• Environmental and chemical compliance support, including ZDHC MRSL conformance and tannery wastewater testing.

• Lahore headquarters, with offices in Karachi, Faisalabad and Sialkot. Sialkot is the leather and footwear cluster itself.

Tti Labs tests and inspects material and reports what it finds. It does not determine whether a product falls inside or outside a regulation, and it does not lodge due diligence statements.

Discuss a leather and footwear testing programme with Tti Labs. UAN 111 786 001. ISO/IEC 17025 accredited through PNAC, LAB-022.

Related guides: Microplastics Rules and Pakistan Polyester: What Actually Applies.