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What is actually in scope: hides and leather, not the finished bag

The EUDR covers seven commodities and the products made from them. Cattle is one of them, and leather is a cattle product. [Reg. 2023/1115, Art. 1(1)] Annex I lists cattle hides and leather at three stages:

• Raw hides and skins of cattle — HS 4101.
• Tanned or crust hides and skins — HS 4104.
• Leather further prepared after tanning or crusting — HS 4107.

Notice where the list stops. Finished leather articles — handbags (HS 4202), footwear (6403), leather apparel (4203) — are not in Annex I. [Reg. 2023/1115, Annex I] That matters for your role: a brand that buys EU-placed finished leather and only assembles or sells the bag is not placing an in-scope commodity on the market for the first time. The obligation falls on the hide and the tanned or prepared leather — the input, not the output.

The draft act proposes removing leather — but it isn't law

On 4 May 2026 the Commission published a draft delegated act amending Annex I; its consultation closed on 1 June 2026. Among the proposed changes is the deletion of all three cattle hide and leather entries (4101, 4104, 4107), which would take leather out of the EUDR entirely. [Commission EUDR implementation page] The Commission's stated reasoning is that leather is a low-value by-product of meat with a supply chain that is hard to trace separately.

Here is the part that decides how you should act. As at 10 July 2026 that draft is still a draft. It has not been formally adopted, it has not been published in the Official Journal, and the European Parliament and Council scrutiny period has not run its course. A delegated act only becomes law once it is adopted and published, and until then Annex I reads as it does today — with leather in it. [Reg. 2023/1115, Art. 3] Leather is also the single most contested line in the review: some parties want it kept, so the final text may keep, narrow or change the removal.

Which role are you?

Assuming leather is in scope (the position today), your obligations turn on where you sit in the chain. [Reg. 2023/1115, Art. 2]

• You import raw, tanned or prepared cattle leather into the EU. You are the first operator: you run due diligence and file the Due Diligence Statement before the goods clear customs. [Reg. 2023/1115, Art. 4(2)]
• You buy leather already placed on the EU market, then cut and stitch. The importer is generally the operator who filed the DDS; you are downstream and keep the DDS reference number. A non-SME downstream operator also keeps the upstream records and may not place goods it knows are non-compliant. [Reg. 2025/2650]
• Your tannery sits outside the EU (UK, India, elsewhere). The non-EU tannery is not the operator — its EU customer is. The tannery's job is to pass the origin data up the chain. [Reg. 2023/1115, Art. 2(15)]

Deadlines follow the general timetable: 30 December 2026 for medium and large operators and traders, 30 June 2027 for micro and small ones that meet the size test. Cattle is not timber, so a small leather manufacturer may use the later date. [Reg. 2025/2650]

What to ask your leather supplier for

Whether you file the DDS or reference someone else's, you need origin data in the chain. For each hide lot, request: [Reg. 2023/1115, Art. 9 & Art. 2(28)]

• Geolocation of the plots where the cattle were raised — coordinates, and polygons for plots over 4 hectares.
• Production dates for the animals.
• Country of production (which sets the risk tier).
• Legality evidence for the country of origin.
• The DDS reference number, where the supplier is the operator that filed it.

Leather's honest difficulty is here: a hide is a by-product, so tracing it back to the farm that raised the animal is harder than tracing a coffee lot to its plot. That difficulty is exactly why the removal is being debated — and exactly why, while leather stays in, you should start the supplier conversation early rather than late.

What this determines — and what it doesn't

Screening your leather tells you scope, role, deadline and the documentary obligations you owe — including a clear read on where the pending removal leaves you. It does not verify that any pasture is deforestation-free; that depends on the geolocation-plus-evidence your suppliers provide and any satellite check. And it does not treat a draft as law: the position is that leather is in scope today, with the proposed removal flagged and dated so you can act on the real state of play.

General information about Regulation (EU) 2023/1115, not legal advice — and not a deforestation assessment. This kind of screening determines your scope, role, deadline and documentary obligations; it does not verify that any plot of land is deforestation-free, and it does not treat the draft May 2026 delegated act as if it were in force. Confirm your classification with counsel before relying on it for a market-access decision.

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