Compliance
Industry Insight
EUDR and Pakistan Leather: What the Scope Change Means
Leather has been removed from the EU Deforestation Regulation. What changed, why, and which EU obligations still bind Pakistani leather and footwear exporters.
Leather is no longer covered by the EU Deforestation Regulation, because on 13 July 2026 the European Commission adopted a Delegated Regulation amending the product list in Annex I, and that act removes cattle hides, skins and leather from the scope. The act was published in the Official Journal on 17 September 2026. It entered into force the following day. For Pakistani tanneries and footwear exporters who had begun building origin files, this changes the immediate compliance question, though not every obligation attached to leather.
Key Takeaways
Cattle hides, skins and leather are removed from Annex I of the EU Deforestation Regulation by Commission Delegated Regulation (EU) 2026/2102.
The removal covers three tariff entries: raw hides and skins, tanned or crust hides and skins, and finished cattle leather.
Live cattle remain in scope, and the obligations on operators handling cattle, soy, palm oil, wood, cocoa, coffee and rubber are unchanged.
Leather still faces chemical rules. REACH restrictions on chromium VI, azo dyes and formaldehyde apply to the finished article whatever the forest rules say.
The Digital Product Passport under the Ecodesign Regulation is the next traceability obligation reaching leather and footwear.
Origin records already assembled remain useful, because buyer due diligence questionnaires have not stopped asking.
What changed, and when
The Delegated Regulation amends Annex I to Regulation (EU) 2023/1115, the regulation itself, and it both adds products and removes them, while its stated purpose is a set of limited technical fixes.
Three deletions matter for leather.
Removed entry | What it covered |
|---|---|
ex 4101 | Raw hides and skins of cattle, fresh, salted, dried, limed or pickled, not tanned or further prepared |
ex 4104 | Tanned or crust hides and skins of cattle, without hair on, not further prepared |
ex 4107 | Leather of cattle further prepared after tanning or crusting, other than leather of heading 4114 |
Read together, those three entries covered the chain from the fresh hide to the finished leather, so deleting them takes the material out of scope at every stage of preparation. The same act also removed conveyor and transmission belting of vulcanised rubber, other vulcanised rubber articles, soybeans for sowing, and narrowed the retreaded tyre entry to tyre treads.
The act added products as well, applying from 30 December 2027: frozen cattle tongues, soluble coffee, and a list of palm oil derivatives and oleochemicals. Those additions sit on the same timetable the Commission set out on its deforestation regulation overview. The overview page carries the additions and the dates attached to them. It lists what the act adds and is silent on the deletions, and that silence is how an in-scope reading of leather survived a first check.
The timing is worth holding on to. Adoption was 13 July 2026, publication was 17 September 2026, and entry into force was 18 September 2026. An exporter told last year that leather was in scope was not being misled at the time. The position has simply moved.
Why the Commission removed leather
The reasoning is set out in the recitals rather than left to inference. The Commission pointed to the differentiation of the leather downstream value chain from the meat value chain, and to asymmetries in trade flows.
That is a factual observation about how hides move, because a hide is a by-product of an animal raised for meat, and its journey to a tannery may pass through several hands, each of which changes what can be documented about the origin of the animal. 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.
There is a second, practical consideration: a hide may leave one country as a raw material and be finished elsewhere, 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 own announcement of the adopted act and its regulatory update for September 2026 both record the removals, and the latter lists leather alongside retreaded tyres and soybeans for sowing.
What the removal does not change
Three things stay exactly as they were.
Live cattle remain a covered commodity. The entry for live cattle was retained as a consolidated tariff line, and the accompanying note narrows the genus considered to cattle of the genus Bos, excluding buffalo and bison. A programme covering cattle hides is now out of scope, while a programme covering live animals is not.
The dates for everything else are unchanged. Large and medium operators apply the regulation from 30 December 2026, and 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. Products are deforestation-free only if produced on land not subject to deforestation after 31 December 2020, and removing leather from the list removes the duty to prove that for leather, though it does not alter the standard that applies to the commodities still listed.
One caution belongs here. A removal in a delegated act is a change in EU law, the kind of change that 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.
What still binds Pakistani leather exporters
Removal from the deforestation regulation does not make leather a lightly regulated material, because the obligations below apply independently, and several of them reach further into a tannery than EUDR ever did.
Obligation | What it requires | Where it bites |
|---|---|---|
Limits on chromium VI, azo dyes releasing aromatic amines, formaldehyde and nickel release | Finished leather, footwear and accessories placed on the EU market | |
Chromium VI testing | EN ISO 17075 screening, with ion chromatography for interference-free confirmation in heavily dyed material | High-risk leather, where colorimetric methods can mislead |
Digital Product Passport | Product-level data on composition, origin, durability and recycled content under the Ecodesign Regulation | Textiles and footwear, as delegated acts are adopted |
Tannery wastewater monitoring against MRSL-linked guidelines | Wet processing and effluent discharge | |
Buyer restricted substance lists | Limits set by individual brands, often stricter than law | Every order, enforced by testing and declaration |
The chemical layer is the one that most often decides whether a shipment moves. Chromium VI is the classic failure, because it is a processing outcome rather than a raw material property, so it can vary between batches from the same tannery.
What to do with origin records you already started
An exporter who began mapping hide sources should not discard the work, for two reasons.
The first is that the record answers questions other regimes ask, because buyer due diligence under the Corporate Sustainability Due Diligence Directive and its questionnaire cascade wants supply chain visibility, and a mapped hide source is direct evidence of it. The sustainability services that support this work treat traceability as a standing requirement rather than a one-off exercise.
The second is that scope can move again. Leather was added at one point and removed at another, in both cases by amendment to a list. An exporter holding an accurate record can respond to either direction without starting over.
The practical position is straightforward. Keep the file current at a proportionate level of effort, lower than a full EUDR programme and higher than nothing, and spend the recovered effort on the chemical and material compliance that still governs the order.
How TTI supports leather and footwear exporters
Testing under ISO/IEC 17025 accreditation through PNAC LAB-022, in a laboratory serving 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, from pre-production inspection and during-production inspection through pre-shipment inspection and loading supervision.
Environmental and chemical compliance support, including ZDHC MRSL conformance and tannery wastewater testing.
Coverage from Lahore headquarters with offices in Karachi, Faisalabad and Sialkot, the last being the leather and footwear cluster itself.
One boundary, stated once. TTI tests and inspects material and reports what it finds. It does not determine whether a product falls inside or outside a regulation. It does not lodge due diligence statements.
FAQ
Is leather covered by the EU Deforestation Regulation?
No longer. Commission Delegated Regulation (EU) 2026/2102 removed cattle hides, skins and leather from Annex I, and it was adopted on 13 July 2026, published on 17 September 2026 and entered into force on 18 September 2026.
Which tariff entries were removed?
Raw hides and skins of cattle under ex 4101, tanned or crust hides and skins under ex 4104, and cattle leather further prepared after tanning under ex 4107.
Does this mean Pakistani leather exporters have no EU obligations?
No. REACH restrictions on chromium VI, azo dyes, formaldehyde and nickel apply to the finished article. Buyer restricted substance lists are often stricter. The Digital Product Passport will reach textiles and footwear as delegated acts are adopted.
Are live cattle still in scope?
Yes. Live cattle remain a covered commodity, and the accompanying note limits the definition to the genus Bos, excluding buffalo and bison.
When does EUDR still apply for other commodities?
Large and medium operators apply it from 30 December 2026, and micro and small operators follow on 30 June 2027, except those already covered by the EU Timber Regulation, who start in December 2026.
Is it still worth collecting hide origin records?
Yes. The records answer buyer due diligence questions under CSDDD and support traceability claims, and the scope list has changed in both directions before.
Conclusion
Leather came out of the EU Deforestation Regulation by delegated act published on 17 September 2026, covering raw hides, crust hides and finished cattle leather.
The Commission's stated reasons were the separation of the leather value chain from the meat chain and trade-flow asymmetries.
Live cattle, and the rules for every other covered commodity, are unaffected, and the 31 December 2020 cut-off still governs them.
Chemical compliance remains the obligation that decides whether leather shipments move. It is unchanged.
Origin records remain worth keeping at a proportionate level, because other regimes and buyer questionnaires still ask.
Discuss a leather and footwear testing programme with TTI. UAN 111 786 001. ISO/IEC 17025 accredited through PNAC, LAB-022.
References
Commission Delegated Regulation (EU) 2026/2102 of 13 July 2026 amending Annex I to Regulation (EU) 2023/1115 as regards the list of relevant commodities and products, EUR-Lex, https://eur-lex.europa.eu/eli/reg_del/2026/2102/oj/eng
Commission Delegated Regulation (EU) 2026/2102, Official Journal text, EUR-Lex, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ%3AL_202602102
Regulation (EU) 2023/1115 on deforestation-free products, EUR-Lex, https://eur-lex.europa.eu/eli/reg/2023/1115/oj/eng
Regulation on deforestation-free products, European Commission, https://environment.ec.europa.eu/topics/forests/deforestation/regulation-deforestation-free-products_en
EUDR: Commission adopted Delegated Act on the product scope, European Commission, https://ec.europa.eu/newsroom/env/items/948164/en
EU Deforestation Regulation update, September 2026, European Commission, https://ec.europa.eu/newsroom/env/newsletter-archives/79267
Substances restricted under REACH (Annex XVII), European Chemicals Agency, https://echa.europa.eu/substances-restricted-under-reach
ZDHC Wastewater Guidelines, Zero Discharge of Hazardous Chemicals, https://downloads.roadmaptozero.com/output/ZDHC-Wastewater-Guidelines
Sustainability services, TTI Testing Laboratories, https://ttilabs.net/sustainability/
Leather and footwear testing, TTI Testing Laboratories, https://ttilabs.net/leather-footwear
Contact, TTI Testing Laboratories, https://ttilabs.net/contact
Accreditation scope LAB-022 (ISO/IEC 17025:2017, first granted 13 May 2006, valid to 8 August 2027), Pakistan National Accreditation Council, https://pnac.gov.pk/pdfFiles/LAB-022
Chapter 7 Industry Summaries (leather: tannery wastewater under ZDHC programmes; chromium VI screening by ion chromatography to EN ISO 17075-2; genuine leather verification by microscopy, FTIR and structural analysis; leather and footwear scope aligned to EN, ISO, AATCC, ASTM, SATRA and IULTCS methods), TTI Global Reference Publication, June 2026, Authoritative Edition, TTI Testing Laboratories. The publication is an internal TTI document with no public URL.
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