COTANCE: The Confederation of Tanners of the European Community welcomes the European Commission’s proposal to exclude hides, skins and leather from the product scope of the implementing measures under Regulation (EU) 2023/1115 on deforestation-free products (EUDR) published in the Draft Delegated Regulation.
This proposal reflects the specific characteristics of the leather value chain and ensures that the Regulation remains focused on relevant products that can directly drive deforestation. It also contributes to regulatory coherence and proportionality in implementation.
COTANCE has always supported the objectives of combatting deforestation and forest degradation. Traceability was a key concern for the leather industry long before the introduction of the EUDR and tanners remain committed to strengthening it through their supply chains. However, traceability can only be fully ensured within a sector’s own value chain. In the case of tanneries and leather production, this value chain begins at the abattoir (slaughterhouse) stage and is distinct from that of meat and dairy production.
The considerations set out in the attached document are intended to ensure that the application of the EUDR remains targeted with the structural realities of agricultural and industrial value chains.
The exclusion of hides, skins and leather reflects:
- The by-product nature of hides within livestock production, where raw hides account for 1.50% of a bovine’s total value at the abattoir - as confirmed by the 2026 United Nations Industrial Development Organisation (UNIDO) Guidelines for Leather;
- The leather value chain only begins at the abattoir stage, separate from the cattle value chain;
- Asymmetries in trade flows between meat and hides, as meat is commonly a domestically produced and consumed product while hides are traded globally;
- The avoidance of an incoherent approach where goods produced with EU leather are included, while goods produced with non-EU leather are excluded, resulting in the relocation risk of hundreds of thousands of rural jobs outside the EU.
This approach strengthens the EUDR by keeping its scope focused where it matters most.
Read our full position at
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/18053-Deforestation-proposal-to-amend-and-simplify-the-rules-and-make-technical-fixes-to-Annex-I/F33431429_en