Draft Delegated Act incorporates targetted amendements to the EUDR product scope, including the removal of Leather.
On Monday 4th May 2026, the European Commission published a press release to confirm the simplification draft of the Delegated Act of the EUDR.
“The draft Delegated Act incorporates targeted amendments to the EUDR product scope. It updates the draft Delegated Act of last year and incorporates feedback from stakeholders during the consultation phase. The draft includes proposed additions of certain downstream products, such as soluble coffee and certain palm oil derivatives. It also proposes several exclusions of the scope, such as leather or retreaded tyres, as well as exemptions such as product samples, certain packing materials, used and second-hand products, and waste. The draft Delegated Act is open for public feedback until 1 June 2026.”
The full statement can be read here: EUDR Press Release
Additionally, the Commission have published a Commission Staff Working Document that outlines the methodology for the proposed simplification. A key extract from that document identifies the rationale for the decision making on in-scope commodities:
“Regulation (EU) 2023/11151 on deforestation-free products (hereafter EUDR) establishes rules for making available on the Union market and export certain commodities and derived products associated with deforestation and forest degradation. The goal of the EUDR is to minimise the EU’s contribution to global deforestation, greenhouse gas emissions and global biodiversity loss, in accordance with the EU’s international obligations.
Art. 2(1) of EUDR defines relevant commodities as cattle, cocoa, coffee, oil palm, rubber, soya and wood.
Art 2(2) of EUDR defines relevant products as products listed in Annex I of the same Regulation that contain, have been fed with or have been made using relevant commodities.
The products listed in Annex I are identified through codes from the customs combined nomenclature (‘Harmonised System’ or HS codes).
The impact assessment for the EUDR did not provide a detailed assessment of the relevant products based on HS codes.
The related Staff Working Document (SWD) also states that:
“the identification of derived products to be specified in the scope requires a specific study […] and subsequent implementing legislation”. This specific study needs to present: “an analysis of derived products, based on potential costs and benefits, similar to the analysis of commodities. The analysis would need to map which products would maximise the impact of the intervention – covering more ground in terms of embodied deforestation – at the smallest potential cost”.
Art. 34(1) of the EUDR, as amended by Regulation (EU) 2025/26502, enables the Commission to adopt delegated acts in accordance with Art. 35 to amend the list of relevant products in Annex I of that Regulation (not the commodities).”
The above extract outlines clearly why leather is now being removed from scope – the Commission did not do an impact study on the leather industry for either (a) leather as a driver of deforestation or (b) the economic harm to the European leather industry by including it in the scope.
This is what the leather industry associations have been lobbying the Commission to recognise and act accordingly. The proposed simplification remedies this oversight and brings factual evidence into the decision making progress. You can read the full Working Document here:
Other useful information can be found here:
- Updated FAQs and Guidance documents
- A draft Delegated Act on the product scope, now open for a four-week public feedback period, accompanied by a Staff Working Document with the methodology underpinning the proposed changes
- A Report to the European Parliament and the Council
A meeting of the Multi-Stakeholder Platform for Deforestation has been scheduled for this coming Friday, 8th May to run through all the simplification measures that are contained in the proposed Delegated Act. We will of course keep you posted on any additional news or updates that are discussed then.
The public feedback for the simplification ends on 1st June, after which the proposed Delegated Act should be approved. As always, until we get to that point, we can not be 100% certain of the removal of leather, but we can now be extremely optimistic.
Finally, we would urge all our partners that efforts towards robust and traceable material should continue as traceability is still the cornerstone for all other incoming regulations such as CSRD, CSDDD, DPP and GCD. We can gladly accept the relief that our value chains will no longer be damaged by the need to have geo-coordinates of all plots of land where cattle was raised, but we do still need to ensure provenance of material for sustainable businesses in the future.
