Trase warns against removing leather from EU Deforestation Regulation

Trase has submitted a formal response to a European Commission consultation advising policymakers not to exclude leather from cattle from the EU Deforestation Regulation (EUDR) as it would significantly undermine the regulation's effectiveness. Trase data shows that EU imports have a deforestation footprint the size of Rome every year, emphasizing the need for swift and effective implementation of the EUDR.

The EUDR, agreed in 2023, aims to reduce Europe’s role in driving deforestation and human rights abuses by preventing companies importing or exporting commodities that have been illegally produced or grown on recently deforested land. Since the European Parliamentary elections in 2024, there have been persistent attacks on environmental legislation which have resulted in the law being delayed twice and the Commission proposing to “simplify and streamline” the EUDR.

While Trase is pleased that the Commission’s simplification review recognizes the need to implement the EUDR and does not propose changes to the detail of the regulation itself, we are concerned at the proposal to change the list of regulated products at such a late stage.

Of most concern is the Commission’s decision to remove bovine leather, hides and skins (HS Codes 4101, 4104 and 4107) from the scope of products. This is despite the Commission’s own data showing that removing leather would continue to allow 39,000 hectares of deforestation per year to take place linked to the product – a 17% reduction in the amount of deforestation that EUDR could have prevented. Leather has a higher deforestation footprint for the EU than other products that are still within the scope of the EUDR including soy, palm oil, coffee, rubber and beef products.

The proposed removal is based on misleading and unevidenced inputs from industry lobbying. Yielding to these pressures sets a dangerous precedent and threatens the integrity of the entire regulation. Companies have had more than three years to prepare for the regulation, and there can be no excuses not to be ready for the current product scope.

The change is also at odds with investments made by downstream companies and industry to improve leather traceability. This is evidenced by Global Canopy’s latest Forest 500 assessment that shows many downstream companies exposed to deforestation linked to leather are reporting increased action on traceability. Examples include Spanish clothing company Inditex and automotive companies BMW Group and VW Group; French luxury goods company Kering (Gucci, Bottega Veneta, Saint Laurent brands); German sports shoe giant Puma; and Italian leather processor Rino Mastrotto.

Furthermore, in 2025, 20 companies that produce and/or source leather in high and unknown-risk regions were involved in collaborative action initiatives and partnerships including The Leather Working Group, The Certification of Origin and Traceability Implementation Initiative and the The Fashion Pact Network.

Aside from removing leather, the Commission plans to add soluble coffee and palm oil derivatives to the product scope. The addition of new products at this late stage risks calls for further delays from companies not being ready for these new additions.

Trase recommends that the Commission focuses on implementing the agreed regulation with no further changes as these only serve to undermine this focus and confuse regulated companies and enforcement bodies. The EUDR already contains a provision for a general review of the regulation by 30 June 2030. The EU should wait until this opportunity to fully and properly assess the impact of the EUDR based on evidence of its effectiveness.

Read Trase’s response to the European Commission consultation