Bovine Leather Removed from the EUDR: What Changes

Bovine hides and skins are out of the scope of the EUDR. Delegated Regulation (EU) 2026/2102, published in the Official Journal on 17 September 2026, deletes from Annex I of Regulation (EU) 2023/1115 the three headings that covered bovine leather: ex 4101, ex 4104 and ex 4107.

The change entered into force the day after publication, on 18 September 2026, with no transition period. In plain terms: companies importing raw, tanned, crust or finished bovine hides and skins into the European Union no longer need to file a due diligence statement for those products.

Which leather headings leave EUDR Annex I

CN code	Description	Status
ex 4101	Raw hides and skins of bovine animals (fresh, or salted, dried, limed, pickled or otherwise preserved, but not tanned), whether or not dehaired or split	Deleted
ex 4104	Tanned or crust hides and skins of bovine animals, without hair on, whether or not split, but not further prepared	Deleted
ex 4107	Leather further prepared after tanning or crusting, and parchment-dressed leather, of bovine animals, without hair on, whether or not split, other than leather of heading 4114	Deleted

Heading 4114 was already outside Annex I and stays outside: the text of 4107 explicitly excluded it.

Why the Commission is taking leather out of the deforestation regulation

Recital 5 of the delegated act gives four reasons, and they are worth reading together because none of them stands alone:

1. The leather value chain separates early from the meat value chain. These are distinct downstream stages, with distinct operators.
2. Trade flows for meat and for hides are asymmetric. They do not travel together or to the same destinations.
3. The economic value of hides is low compared with meat within total cattle production.
4. The consequence of the three above: EU operators have limited leverage to obtain from their suppliers the information the EUDR requires. It is not unwillingness, it is a lack of commercial leverage.

There is a fifth reason, about coherence: because processed leather goods (footwear, leather goods, upholstery) were never inside Annex I, keeping only the hides created a fragmented and incoherent approach for the whole sector. The Commission warns this could cause relocation of deforestation risk rather than its elimination: the hide enters through another door, already processed, and the problem is not solved but moved.

What does not change: cattle stays in, with wider scope

This is where the headline misleads. The same delegated act that removes leather widens the cattle scope in two places:

Change	Before	Now	Applicable from
Live bovine animals	0102 21 and 0102 29 (two codes)	ex 0102 — the whole heading	18 Sep 2026
Bovine tongues	Fresh or chilled only (ex 0206 10)	Frozen tongues added (ex 0206 21 00)	30 Dec 2027

The reasoning behind tongues is the same coherence logic in reverse: leaving frozen tongues out while fresh ones were in created a fragmented approach and an easy circumvention route.

Is the removal permanent?

No. Recital 2 states it explicitly: bovine hides and skins and their derived products will be part of the 2030 general review foreseen in Article 34(2) of Regulation (EU) 2023/1115. Until then, the Commission will keep monitoring the products affected by these Annex I amendments.

Translated into business decisions: companies building hide traceability should not dismantle it. They should put it in maintenance mode.

The other changes in the same delegated act

This is not only about leather. The act touches several commodities at once:

Product	What happens	Applicable from
Coffee extracts and concentrates (2101 11 00) — instant coffee	Added to Annex I	30 Dec 2027
Soap (3401 11 00 and 3401 20)	Added to Annex I	30 Dec 2027
Cocoa shells and waste (1802)	Waste as defined in Directive 2008/98/EC is excluded	18 Sep 2026
Bovine hides and leather (ex 4101, ex 4104, ex 4107)	Removed from Annex I	18 Sep 2026

The full code-by-code breakdown of the act, including palm derivatives and the timber and soy clarifications, is in our complete guide to Delegated Regulation (EU) 2026/2102.

Key takeaways

• Headings ex 4101, ex 4104 and ex 4107 (bovine hides and skins) left EUDR Annex I on 18 September 2026.
• There is no transition period: from that date no due diligence statement is required for those products.
• 4114 was never in scope, and neither were footwear and leather goods: that asymmetry is one of the reasons for the removal.
• The official rationale is supply chain feasibility, not environmental impact: the staff working document acknowledges the environmental benefit forgone.
• Cattle scope widens: the whole ex 0102 heading from 18 Sep 2026 and frozen tongues ex 0206 21 00 from 30 Dec 2027.
• The removal is not permanent: leather is included in the 2030 general review under Article 34(2).
• General EUDR dates are unchanged: 30 December 2026 for medium and large companies.

What to do now, depending on who you are

1. If you import bovine hides or skins into the EU. From 18 September 2026 you no longer need a due diligence statement for those headings. Review statements already filed and those in preparation, and confirm the exact tariff classification of what you import: the exemption covers 4101, 4104 and 4107, not the whole of Chapter 41. If the code is unclear, requesting binding tariff information before you stop declaring is recommended.
2. If you work with beef, offal or live cattle. The leather removal does not affect you; the widening does. Check whether you handle frozen tongues and prepare heading ex 0206 21 00 for 30 December 2027, and make sure your live animal scope covers the whole ex 0102 heading, not just the two former codes.
3. If you are a non-EU exporter. If you were shipping hides to Europe, your customers will stop asking for geolocation on those headings. If you export cattle or beef, they will ask for the same or more.
4. In every case. Keep the documentation for statements already filed, and do not dismantle any hide traceability you have built: the 2030 review may bring leather back onto the list.

Keeping scope current heading by heading, and knowing at any moment which product needs a statement and which does not, is exactly the kind of control that becomes unmanageable in a spreadsheet. At Coolx we centralise suppliers, geolocation data and documentation, and we generate and submit due diligence statements to TRACES from a single system. If you want to see how your scope looks after this change, get in touch with our team.

Frequently asked questions

Is leather out of EUDR scope right now?

Yes, from the day after publication of the delegated act in the Official Journal, 18 September 2026. There is no transition period.

Does this affect footwear and leather goods?

Nothing changes for them, because processed leather products were never in Annex I. That asymmetry is precisely one of the reasons for the removal.

What about leather that is not bovine?

The three deleted entries refer expressly to hides and skins of bovine animals. The EUDR covers seven commodities and leather from other species was not included as such in those headings.

Do I have to withdraw due diligence statements already filed for hides?

There is no obligation to withdraw them. Keep them as documentation; the EUDR maintains record-keeping duties for five years for submitted statements.

Could leather come back into scope?

Yes. It is expressly included in the 2030 general review under Article 34(2) of Regulation (EU) 2023/1115.

Sources

• Commission Delegated Regulation (EU) 2026/2102 of 13 July 2026 (OJ L, 17 September 2026)
• Regulation (EU) 2023/1115 (EUDR), consolidated text
• European Commission — Adoption of the delegated act (13 July 2026)
• European Commission — Official EUDR page