EUDR and Pakistan Leather: What the Scope Change Means

What the delegated act removed

The act amends Annex I to Regulation (EU) 2023/1115. Three of its deletions are leather, covering the chain from fresh hide to finished leather:

The Commission's announcement lists the other removals: retreaded tyres, soybeans for sowing, articles of vulcanised rubber, conveyor and transmission belts, and aircraft and motor vehicle seats. The act also adds products, including frozen cattle tongues, which apply from 30 Dec 2027.

Which Pakistani leather products were ever in scope

The original Annex I listed cattle products only. Checked against the 2023 text, this is where common Pakistani export lines stand:

So a tannery working goat and sheep skins, or a factory making gloves, bags or shoes, did not have an EUDR duty for those products before the change either. The removal matters most to cattle hide and cattle leather suppliers.

Why the Commission removed leather

Recital 5 of the act cites three facts: the leather value chain is separate from the meat value chain, trade flows of hides and meat do not match, and hides are worth little compared with meat. As a result, EU operators have limited leverage to demand origin information, and the requirement could relocate deforestation risk rather than remove it.

That matches how hides move. A hide is a by-product of an animal raised for meat, and on its way to a tannery it may pass through several hands, each of which weakens what can be documented about the farm.

What did not change

• Live cattle stay in scope. A new note limits the entry to cattle of the genus Bos and excludes buffalo and bison.

• Application dates. Large and medium operators apply the regulation from 30 Dec 2026; micro and small operators from 30 Jun 2027, or 30 Dec 2026 if already covered by the EU Timber Regulation (European Commission).

• The cut-off. Products must come from land not deforested after 31 Dec 2020.

• Contracts. A buyer's purchase contract may still carry an EUDR clause written before the change. That is a commercial conversation, whatever the regulation now says.

The Commission's Sep 2026 update also lists leather among the removals.

The chemical limits that still apply to leather

These REACH Annex XVII restrictions apply to leather articles on the EU market regardless of the deforestation rules. Several reach further into a tannery than EUDR ever did.

Chromium VI is the classic failure. It is a processing outcome, not a property of the raw hide, so it can vary between batches from the same tannery. The 3 mg/kg limit equals the determination limit of EN ISO 17075, which the regulation describes as the only internationally recognised method for chromium VI in leather. The REACH testing guide covers the full test list.

Worked example: one leather shoe, three rules. A shoe with a cattle leather upper, a textile lining and a metal buckle:

• Leather upper: chromium VI (3 mg/kg) and azo amines (30 mg/kg).

• Textile lining: azo amines, plus formaldehyde at 75 mg/kg under entry 72, because the shoe is not made entirely of leather.

• Metal buckle, if in prolonged skin contact: nickel release of 0.5 µg/cm² per week.

• Whole article: the buyer's restricted substance list, which is often stricter than REACH, and ZDHC wastewater expectations for the tannery.

Digital Product Passport: footwear is not a first priority

The Commission's first ecodesign working plan (Apr 2025) puts textiles and apparel first, with an indicative adoption date of 2027. It treats footwear as a separate category with lower impacts and commissions a study, due by the end of 2027, on whether to regulate it.

Keep origin records, at a proportionate level

The EU due diligence directive was narrowed in 2026. Directive (EU) 2026/470 raised its thresholds to 5,000 employees and EUR 1.5 billion turnover and postponed application to 26 Jul 2029. Fewer EU buyers will be in scope, but the largest ones still send supply chain questionnaires, and a mapped hide source answers them directly.

Scope can also move again: leather was added and removed by amending a list. An accurate, light file of hide sources costs far less than a full EUDR programme and lets an exporter respond either way. Put the effort saved into the chemical compliance that governs each order. Sustainability services can support that traceability work.

What Tti Labs tests and inspects for leather and footwear exporters

• Testing under ISO/IEC 17025 accreditation through PNAC LAB-022, whose scope includes chromium VI in leather to ISO 17075-1 and ISO 17075-2.

• Leather and footwear testing covering physical and mechanical performance, colourfastness, and chemical analysis aligned to EN, ISO, AATCC, ASTM, SATRA and IULTCS methods, supporting the industry since 2012.

• Chromium VI by ion chromatography to EN ISO 17075-2, for interference-free confirmation in heavily dyed leather.

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

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

• ZDHC MRSL conformance certification and tannery wastewater testing.

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

Tti Labs tests and inspects material and reports what it finds. It does not decide whether a product falls inside 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. Contact the laboratory.

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