Overview
The EU Deforestation Regulation prohibits relevant commodities and products from being placed on the EU market or exported unless they are deforestation-free, produced lawfully, and covered by a due-diligence statement.
EUDR has limited direct applicability to fashion following the Commission’s 13 July 2026 Delegated Act removing cattle hides, skins and leather, along with several rubber products, from Annex I. Fashion companies should still assess whether other materials or products they place on the market fall within the remaining commodity/product scope. Until the Delegated Act completes European Parliament and Council scrutiny and is published in the Official Journal, treat the Annex I update as Commission-adopted but confirm formal entry into force.
Application starts on 30 December 2026 for large and medium-sized operators (and micro/small operators already covered by the EU Timber Regulation), and on 30 June 2027 for other micro and small operators.
Key requirements
- Map products against the current Annex I list, noting the Commission’s July 2026 removal of cattle hides, skins, leather and several rubber articles.
- Collect geolocation and legality evidence from upstream suppliers for any remaining in-scope commodities/products.
- Submit due-diligence statements before placing in-scope products on the EU market.
- Retain records and mitigate deforestation risk in the supply chain.
Who’s affected by EUDR
Operators and traders placing remaining in-scope commodities or derived products on the EU market. For most fashion/leather businesses, direct EUDR exposure is now limited after the Commission’s Annex I update, but residual in-scope materials should still be checked.
Timeline
29 June 2023
EUDR published / enters into force path.
13 July 2026
Commission adopts Delegated Act updating Annex I, including removal of cattle hides, skins and leather and several rubber products (subject to EP/Council scrutiny before OJ publication).
30 December 2026
Application for large and medium operators (and micro/small operators already covered by the EU Timber Regulation).
30 June 2027
Application for other micro and small operators.
How Carbon Trail helps
How Carbon Trail can help
- Map which products, markets and legal entities fall in scope.
- Structure product, supplier and emissions data needed for disclosures and EPR reporting.
- Track timelines, owners and evidence gaps across overlapping fashion regulations.
Frequently asked questions
Does EUDR still apply to fashion leather?
The Commission’s 13 July 2026 Delegated Act removes cattle hides, skins and leather from Annex I. Once that Act completes scrutiny and is published in the Official Journal, those leather codes are out of scope. Cotton apparel remains generally out of scope; check any other remaining Annex I products you place on the market.
