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Does the EUDR Still Apply to Leather from India? EU Buyer Guide 2026

8 hours ago
5 min read

No. As of October 2026, the EU Deforestation Regulation (EUDR) no longer applies to leather from India: a Commission delegated act adopted on 13 July 2026 removed cattle hides, skins and leather (HS 4101, 4104 and 4107) from Annex I, effective 18 September 2026. EU importers still need traceability, chemical compliance and supplier evidence.

Key Takeaways

  • Updated October 2026: cattle hides, skins and leather (HS ex 4101, ex 4104, ex 4107) are out of EUDR scope.

  • The European Commission adopted the delegated act on 13 July 2026, and it entered into force on 18 September 2026.

  • Finished leather goods such as footwear (HS 6403), leather apparel (HS 4203) and bags (HS 4202) were never listed under cattle in Annex I.

  • The EUDR still applies to beef and live cattle from 30 December 2026 for large and medium operators and 30 June 2027 for micro and small operators.

  • Leather's exclusion will be reviewed in 2030, so hide-origin traceability is still worth building into supply contracts.

What changed for EUDR leather from India in 2026?

The European Commission took leather out of the regulation. On 13 July 2026 it adopted a delegated act deleting the cattle entries ex 4101 (raw hides and skins), ex 4104 (tanned or crust hides) and ex 4107 (finished leather) from Annex I of Regulation (EU) 2023/1115.

According to the Commission's EUDR update of 17 September 2026, the scope delegated act entered into force on 18 September 2026 after the two-month scrutiny period. The Commission's stated reason was the relatively low economic value of hides compared with meat, as summarised by DLA Piper.

For Indian exporters this reverses earlier guidance. The Council for Leather Exports had told members that hides and leather under HSN 4101, 4104 and 4107 would need geolocation data for the cattle's place of production, which is very hard to collect for hides bought through Indian markets and traders.

Which leather products from India were ever in EUDR scope?

Only hides and leather as materials were listed; finished leather products were not. This table shows the position as of October 2026:

Product from India

HS heading

Listed in Annex I before Sept 2026?

Status from 18 Sept 2026

Raw cattle hides and skins

ex 4101

Yes

Removed from scope

Wet blue or crust cattle leather

ex 4104

Yes

Removed from scope

Finished cattle leather, including upholstery hides

ex 4107

Yes

Removed from scope

Leather footwear

6403

No

Not in scope

Leather jackets and apparel

4203

No

Not in scope

Handbags and small leather goods

4202

No

Not in scope

Non-leather components follow their own rules. A wooden sofa frame, for example, can fall under the wood entries of Annex I, so check it separately from the leather cover.

Do EU importers of Indian leather still need traceability?

Yes, for commercial reasons rather than under the EUDR. Brands still set their own sourcing policies, and the Commission will review leather's place in the regulation in 2030.

European tanners have said they remain committed to existing traceability schemes, according to the Euroleather press release on the delegated act. Audits under the Leather Working Group (LWG) certification also look at how a tannery records where its raw material comes from, so certified supply chains already hold much of the evidence buyers ask for.

Other EU product rules have not changed. Chrome-tanned leather articles must still meet the REACH chromium VI limit, which we explain in our guide to chromium VI testing for leather from India.

What should EU buyers ask an Indian leather supplier now?

Ask for evidence you can file, not promises. A short checklist for hides, finished leather and leather goods:

  1. Country of origin of the hides, and the hide supplier where it is known.

  2. The tannery's name and its LWG certificate or audit status.

  3. Batch or lot numbers that link finished leather back to hide purchases.

  4. A chromium VI test report (EN ISO 17075) for chrome-tanned leather.

  5. Material declarations for non-leather parts such as soles, linings, hardware and wooden frames.

  6. Agreement on what changes if leather returns to the EUDR after the 2030 review.

Who gains most from leather leaving the EUDR?

Buyers of hides and finished leather gain most, because those were the products directly in scope. EU tanneries, upholstery firms and furniture makers that buy wet blue, crust or finished leather from India no longer need EUDR due diligence statements for it.

For footwear, jacket and bag brands, little changes in law, because their finished products were never listed. The practical gain is upstream: Indian factories no longer face pressure to collect cattle geolocation data for the leather they use, which had been a risk to supply continuity.

Timing still matters for cattle products that remain in scope. The EUDR applies from 30 December 2026 for large and medium operators and from 30 June 2027 for micro and small operators, as noted by World Footwear. If you also follow trade terms, our India-EU FTA guide for leather import duties covers the separate question of tariffs.

How Sanwas International works with EU brands

For EU buyers we supply leather hides and finished leather as well as finished products, with MOQs under 500 units per style, sampling from 72 hours, bulk production from around 30 days and AQL inspection before shipment. Our certifications page lists what we hold. To discuss documents for your next order, request a quote from Sanwas International.

Frequently Asked Questions

Do I need EUDR geolocation data for leather hides imported from India?

No. Since the delegated act entered into force on 18 September 2026, cattle hides, skins and leather under HS ex 4101, ex 4104 and ex 4107 are no longer listed in Annex I of the EUDR, so no geolocation data or due diligence statement is required for them under that regulation. Many EU brands still ask for hide-origin information under their own sourcing policies, so agree what you need in your supply contract.

Yes, as of October 2026, finished cattle leather under HS 4107 no longer needs an EUDR due diligence statement in Italy or any other EU member state. Normal EU import rules still apply, including customs classification, rules of origin and REACH chemical restrictions such as the chromium VI limit for leather articles.

Possibly, but nothing has been decided. The delegated act includes a review of leather's place in the regulation in 2030, so buyers who keep hide-origin and tannery records now will be ready if the scope changes again.

No. The EUDR is a due diligence rule for market access, not a tariff. EU import duty depends on the product's HS code and origin, including any preference under a trade agreement once it applies, and it is paid by the importer whether or not a product is in EUDR scope.

Expect a commercial invoice, packing list and bill of lading or airway bill, plus a proof of origin if you claim a tariff preference. For leather, also ask for a chromium VI test report for chrome-tanned material, a copy of the tannery's LWG certificate if one applies, and any hide-origin declaration your contract requires.

Sourcing Leather or Hides for the EU? Request a Quote

EU brands, sourcing managers, tanneries and furniture makers can share the product or leather type, target quantity, destination country, preferred Incoterm and target delivery date, along with any traceability documents you need. First samples are complimentary, and Sanwas International supplies buyers across India and exports worldwide.

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