EUDR for pet treats, chews and rawhide importers

Pet treats, chews and rawhide products are not covered by the EUDR. Finished treats classify under CN 2309 (preparations for animal feeding) or CN 4205 (other leather articles) — neither has ever appeared in Annex I. The raw-material exposure that did exist, for businesses importing unprocessed cattle hide, ended when Delegated Regulation (EU) 2026/2102 removed hides and leather from Annex I in September 2026.

Why a finished treat isn't the regulated product

The EUDR does not regulate ingredients in the abstract. It regulates specific CN codes listed in Annex I of Regulation (EU) 2023/1115, and only the raw or semi-processed forms of seven commodities — wood, cocoa, coffee, palm oil, rubber, soya and cattle — carry an entry. A finished, retail-packaged pet treat sits downstream of that boundary almost however it is made, in the same way a pair of shoes sits downstream of the leather that went into it.

The Commission considered adding compound and mixed animal feed, classified under CN 2309, to Annex I while drafting the original regulation, and decided against it. FEFAC's professional recommendation to EU feed manufacturers confirms this directly for compound livestock feed: the finished feed is CN 2309, outside Annex I, even when it is made entirely from Annex I soya or palm material. Pet treats sit under the same heading. Customs classification doesn't distinguish a bag of cattle feed pellets from a bag of chicken-flavoured dog biscuits for this purpose — both are preparations of a kind used in animal feeding, and neither code is in the regulation.

The CN codes that actually govern pet treats

Product type	Typical CN code	In Annex I
Dried meat, offal or fish-based treats (jerky, tripe sticks, liver bites)	2309 10	No
Compressed or extruded chews with added nutrients, starch or preservatives	2309 10	No
Plain rawhide chews (dried, dehaired hide, no added ingredients)	4205 00	No
Real bone chews (dried animal bone)	0506	No
Dental chews, supplement-style chews	2309 10	No

HMRC's own Advance Tariff Rulings database bears this out for the rawhide case specifically: a ruling covering plain rawhide dog chews packed for retail sale placed them under commodity code 4205 00 90 00 — "other articles of leather or of composition leather" — not under any of the raw-hide or tanned-hide codes (ex 4101, ex 4104, ex 4107) that Annex I used to list. A separate ruling for a rawhide-derivative stick chew with added ingredients used 2309 10 31 00 instead, the same heading used for conventional pet food. Either way, the code lands outside Annex I.

Rawhide specifically: it was arguably never in scope

This is the detail the backlog question gets slightly backwards. The framing "now that cattle hides and leather are out of Annex I" implies rawhide chews lost coverage in September 2026. In practice, a finished rawhide chew — dried, shaped, knotted, packaged for a pet shop shelf — was classified as a leather article under CN 4205 before the removal too, not under the three codes Annex I actually listed (ex 4101 raw hides, ex 4104 tanned hides, ex 4107 leather further prepared). What the 2026 removal actually took out of scope covers the same pattern for footwear and leather goods: the regulation reaches a commodity's raw and semi-processed forms, not a finished consumer product made from it, whether that product is a handbag or a dog chew.

Where it gets genuinely closer to the line is a business that buys raw or minimally-cured hide directly — before tanning, before shaping into a chew — and processes it in-house. That purchase, before the September 2026 removal, could have sat under ex 4101. Since the removal took effect, it no longer does, whatever stage of processing the buyer does next. The full set of changes made by Delegated Regulation (EU) 2026/2102 sets out the commencement detail for that removal in full, including the point that some reporting on the exact date is inconsistent.

Meat, offal and bone-based treats

Same answer, different reasoning. Beef jerky treats, dried tripe, liver bites and similar products are made from cattle offal and meat, which is genuinely in Annex I — but under CN ex 1602 50, the code for prepared or preserved meat, offal and blood intended for human food. A product formulated, labelled and classified for animal consumption does not carry that code; it carries CN 2309 instead, under the long-standing customs distinction between food preparations (chapter 16) and animal feeding preparations (chapter 23). The ingredient is cattle-derived; the code the finished product actually clears customs under is not an Annex I code either way.

Bone chews made from dried animal bone generally classify under CN 0506 (bones and horn-cores, unworked or simply prepared), which has never appeared in Annex I for any commodity.

Where the real exposure still sits

The people who should read this carefully are not retailers or importers of finished treats — they are the businesses one step further back:

• A treat manufacturer that imports raw cattle hide itself, rather than buying already-processed rawhide sheet, was the operator for that hide under ex 4101 before September 2026. That exposure is gone now, but only for hide specifically — check what else the same import contract covers.
• A manufacturer whose treats are palm-oil coated or bound, where the palm oil itself is imported as crude or refined oil rather than bought already-placed from an EU supplier, is the operator for that palm oil under its own Annex I entry, regardless of what the finished treat's own CN code says. Palm oil traders and refiners covers what counts as in scope on the palm side.
• A manufacturer using soy protein or soy-based chew alternatives, if it imports raw soya beans, meal or oil itself rather than a finished, already-classified soy ingredient, has the same exposure under the soya commodity. EUDR for soya and animal feed businesses sets out exactly which soya CN codes are in scope and which aren't.

The pattern across all three: the finished treat's own CN code tells you nothing about whether a raw material upstream of it was in scope. Check the material you actually import, not the product you sell.

Scope by ingredient, at a glance

If your treats contain...	Finished product in scope?	Upstream exposure possible?
Rawhide (processed, shaped)	No	No, since September 2026
Raw/unprocessed hide bought in-house	No (finished product is 2309/4205)	Yes, before September 2026; no, since
Beef, offal, tripe, liver	No (classified 2309, not 1602 50)	Only if you import raw cattle meat/offal yourself as the first EU placer
Chicken, fish, pork, lamb	No	No — none of these are EUDR commodities
Soy protein, soy-based chew sticks	No	Only if you import raw soya beans, meal or oil yourself
Palm oil coating or binder	No	Only if you import crude or refined palm oil yourself
Wood-based chew additives (e.g. cellulose fibre)	No	Rare — check the specific wood product code if sourced as raw timber-derived material

Deadlines, for the businesses this does catch

If you are one of the upstream cases above — importing raw hide, palm oil or soya yourself rather than buying finished treat ingredients — the application dates are the general ones: 30 December 2026 for large and medium operators and traders, and for micro and small operators whose products were already covered by the EU Timber Regulation; 30 June 2027 for other micro and small operators. Which EUDR deadline applies to you covers the size test in full. For the finished-treat business with no raw-material exposure, no date applies, because there is no obligation to meet.

What to actually check before your next shipment

1. Ask your customs broker or freight forwarder for the CN code on your import declaration, not the product description. If it is 2309, 4205 or 0506, the finished product carries no EUDR obligation.
2. If you manufacture rather than just import finished treats, check separately whether any raw material you buy in — hide, palm oil, soya — comes in under its own Annex I code rather than as an already-processed, already-placed ingredient.
3. Do not assume a supplier's EUDR paperwork for hides, palm oil or soya is still required now that your own finished product is confirmed out of scope — the two questions are separate, and the raw-material one can still apply even though the finished-treat one does not.
4. Keep this check on file. A competent authority asking why you are not filing anything will want to see the CN code reasoning, not just an assertion that pet products are exempt.

Check what the EUDR requires of your specific pet product business, including whether any raw material you buy in yourself brings you into scope even though the finished product does not.