EUDR for leather, hides and footwear businesses: what the 2026 Annex I changes actually removed

If you make or import footwear, handbags, belts or jackets, the EUDR has never regulated you because of the leather, and it regulates you even less now. Finished leather goods and footwear were never listed in Annex I at all. The three codes that were ever there — raw hides, tanned hides and leather material, all bovine — came out of the regulation on 18 September 2026, under Commission Delegated Regulation (EU) 2026/2102.

What was ever in scope, and what never was

Annex I of Regulation (EU) 2023/1115 never had a line for footwear, handbags, belts, wallets or jackets, whatever they are made of. The regulation reaches into a commodity's raw and semi-processed forms, not into finished consumer goods several processing steps downstream. That is true even for rubber, a commodity the regulation does cover in some depth: natural rubber gloves and rainwear (CN ex 4015) are listed, but rubber-soled footwear is not, because footwear sits in a different customs chapter the Annex never reaches into. Leather never got even that far. The only leather-related entries Annex I ever carried, under the "cattle" commodity, were:

• CN ex 4101 — raw hides and skins of bovine or equine animals
• CN ex 4104 — tanned or crust hides of bovine or equine animals, without hair on
• CN ex 4107 — leather further prepared after tanning or crusting, bovine or equine, excluding leather of heading 4114

That is raw material and tannery output. A business buying finished leather to cut and stitch into shoes or bags was never filing anything under those codes, because what it buys does not carry them — the cutting, stitching and assembly into a consumer product happens after the Annex I boundary, not before it.

What Delegated Regulation (EU) 2026/2102 removed, and when

The Commission adopted the delegated act on 13 July 2026 under the Article 34(1) procedure, which lets it amend Annex I without a full legislative process. The European Parliament and Council scrutiny period closed without objection, the act was published in the Official Journal on 17 September 2026, and it entered into force the following day — 18 September 2026 — with no transition period for the removals. A business holding leather stock bought before that date gets no grace period specific to this change; there was simply no obligation left to wind down.

CN code	What it covered	Status after 18 September 2026
ex 4101	Raw bovine/equine hides and skins	Removed
ex 4104	Tanned or crust bovine/equine hides	Removed
ex 4107	Bovine/equine leather, further prepared	Removed
4202, 4203 and similar	Leather handbags, belts, apparel	Never listed
6401–6405	Footwear of any material	Never listed

The same delegated act removed re-treaded tyres and two general rubber entries, and added soluble coffee, certain palm oil derivatives and frozen cattle tongues to Annex I from 30 December 2027. None of that touches leather or footwear directly; it is covered in full in the Annex I changes guide if your business deals in rubber, tyres or coffee as well.

If your business only makes or imports footwear

You have never had an EUDR obligation arising from the footwear itself, and this change does not alter that, because there was nothing for it to alter. If you assumed footwear was in scope because leather is a regulated material in general terms, that assumption was always incorrect — the regulation works commodity by commodity and code by code, not material by material. Check the soles and components you buy in separately if you want to be thorough: a sole made from natural rubber sheet, rather than a pre-cut finished sole, could in principle touch a code that the rubber commodity still covers, but a pre-cut or pre-moulded sole bought as a finished footwear component is not something that regulation's Annex I entries describe, and nothing found this run suggests enforcement has ever treated it otherwise.

If your business only makes or imports finished leather goods

The same applies to handbags, belts, wallets, leather jackets and upholstery. These were never Annex I products. Buying finished leather — tanned, dyed, finished, ready to cut — from a tannery or leather wholesaler was never an EUDR-relevant transaction on your side of that purchase, even before September 2026, because the Annex I leather codes stopped at the tannery's output, not at what a goods manufacturer bought.

If you are a tannery, hide dealer or leather material trader

This is the part of the leather trade the regulation did reach, and the part where something has actually changed. If raw hides, tanned hides or finished leather material under CN 4101, 4104 or 4107 were the whole of your EUDR exposure, you came out of scope on 18 September 2026. That means no further due diligence statements, geolocation or risk assessments for that product line from that date. It does not retroactively excuse anything you were required to file before the removal took effect, and it is worth keeping your pre-removal compliance records regardless — the EUDR's own five-year retention rule stops applying to a product once it is out of scope, but a competent authority reviewing an earlier filing period can still ask about it within that window.

Check your own CN codes rather than taking "leather" as a single category. A trader handling both bovine hides (now out) and, say, exotic or non-bovine leather was never filing on the non-bovine material in the first place — it was never a cattle-commodity product — so nothing changes for it either way.

Other ways a leather or footwear business could still have an obligation

This removal is specific to three codes under one commodity. It says nothing about the rest of your business if you deal in anything else the EUDR covers:

• A tannery that is part of a group also trading in cattle meat or hides destined for other markets should check what the cattle commodity still requires for that side of the business.
• A footwear or accessories manufacturer sourcing rubber, cork, or wood components directly as raw or semi-processed material, rather than as finished parts, should check the specific code those components carry rather than assume the leather removal covers them too — it does not.
• A business that is in scope for an unrelated reason still has to meet the application date that applies to its size: 30 December 2026 for large and medium operators and traders, 30 June 2027 for micro and small operators.

Checking your own codes rather than trusting the word "leather"

The regulation has never worked material by material, and treating "I deal in leather" as a single yes/no answer is how businesses on both sides of this change get it wrong. What actually matters is the customs classification on your own import or purchase paperwork. If you do not know it, your customs broker or freight forwarder does — it is on every customs declaration you or your supplier has filed. Ask for the CN code, not just a product description, and check it against the table above rather than against a summary written before September 2026, including this one in twelve months' time.

This matters most for businesses that sit across a boundary: a workwear manufacturer buying both finished leather panels (never in scope) and raw hide offcuts for a sideline leather-crafts product (CN 4101, now also out, but was in scope before 18 September 2026) needed to track two different answers for the same broad material. After the removal, both lines are out, which simplifies that particular case, but the lesson — check the code, not the material name — still applies to whatever you deal in next.

If you already filed a due diligence statement for hides or leather

A due diligence statement filed in TRACES before 18 September 2026, while CN 4101, 4104 or 4107 were still listed, remains a valid record of what you did at the time. The removal does not retroactively undo it, and you do not need to withdraw or amend it. It simply means you do not file another one for that product line going forward, because there is no longer an Annex I entry requiring it. If a competent authority opens a review of a pre-removal filing period, the statement and the records behind it are still what you would produce; keeping them is simpler than trying to reconstruct the position later.

Quick reference

Business	Was it ever in EUDR scope for leather?	In scope now?
Footwear manufacturer or importer (any upper material)	No	No
Handbag, belt or leather apparel manufacturer	No	No
Tannery or hide dealer (CN 4101, 4104, 4107 only)	Yes, until 18 September 2026	No
Leather goods manufacturer buying finished leather from a tannery	No	No
Business also trading cattle meat, or another EUDR commodity	Yes, for that other product	Yes, for that other product

What to do next

If leather was your only reason to think about the EUDR at all, you can stand down the compliance work you built around it, and document why — the basis for that conclusion is worth having in writing if the question ever comes up again. If leather was one line among several, re-check only that line; the rest of your Annex I mapping is unaffected by this specific act.

Check whether anything else your business deals in falls under the EUDR, rather than assuming a single removed material clears your whole supply chain.