Is Leather Footwear in EUDR Scope, and What Do You Collect?
The finished shoe is not in Annex I and the cattle leather is. Which Annex I lines reach it, why ex matters here, and what Article 9 requires.
Direct answer
The finished shoe is not in Annex I. The cattle hide and leather it is made from are. Footwear classifies in Chapter 64 and Chapter 64 does not appear in the annex, so the obligation attaches to the leather when the leather is placed on the market, not to the shoe when the shoe is.
That is not a loophole, and reading it as one is the mistake this page exists to prevent. If you import leather and make shoes in the Union, you are the operator placing a relevant product on the market and the obligations are yours. If you import finished shoes, the leather in them was placed on the market by somebody else, somewhere else, and your exposure is commercial and reputational rather than a due diligence statement of your own.
The main obligations apply from 30 December 2026, and from 30 June 2027 for qualifying micro and small undertakings. Both dates are on the dates page.
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Summary
Commodity Cattle In scope raw hides and skins of cattle, tanned or crust hides, and leather of cattle further prepared after tanning Out of scope the finished shoe, bag or garment, because Chapters 42 and 64 are not in Annex I Applies from 30 December 2026, or 30 June 2027 for qualifying micro and small undertakings You must collect the eight categories in Article 9(1), on the hide rather than on the shoe
The Annex I lines this rests on
Under the relevant commodity Cattle, the three that matter to a leather business:
ex 4101 Raw hides and skins of cattle (fresh, or salted, dried, limed, pickled or otherwise preserved, but not tanned, parchment-dressed or further prepared), whether or not dehaired or split ex 4104 Tanned or crust hides and skins of cattle, without hair on, whether or not split, but not further prepared ex 4107 Leather of cattle, further prepared after tanning or crusting, including parchment-dressed leather, without hair on, whether or not split, other than leather of heading 4114
Quoted from the annex as published. Check the consolidated Regulation before relying on a line.
Every one carries ex, and here the ex is doing real work: headings 4101, 4104 and 4107 cover hides and leather of several animals, and the annex reaches only cattle. Sheep, goat and pig leather in the same headings are not relevant products. A tannery running mixed inputs has to separate them, and a supplier declaration that says "leather" without saying which animal has not answered the question.
ex 4107 also carves out leather of heading 4114, which is chamois, patent and metallised leather.
Why the finished article is out, and what follows from that
The commodity chain for a shoe is hide, then leather, then upper, then shoe. Annex I stops at leather.
Three consequences worth designing for:
- If you tan or finish leather in the Union, you are placing a relevant product on the market and the full obligation is yours.
- If you buy finished leather and cut it, the leather was already placed on the market. Whether that was done by somebody who discharged the obligation is a question for your contract, not your due diligence statement.
- If you import finished shoes, no relevant product is being placed by you. That does not make the deforestation risk go away, and a customer asking about it will not accept a classification answer.
What you have to collect
Where you are the operator, Article 9(1) applies in full: product description and species name, quantity, country of production and parts of it, the geolocation of all plots of land where the commodity was produced with the date or time range of production, supplier and customer names and contact details, and the information demonstrating the commodity is deforestation-free and was produced in accordance with the law of the country of production.
For cattle the geolocation question has its own shape. The plot definition and the precision the Regulation sets are on how precise a plot geolocation has to be, and the polygon rule there does not apply to cattle.
Species name in point (a) is not a formality for this commodity. It is the field that makes the cattle-or-not question answerable downstream.
If you also make rubber-soled footwear
Most shoe companies are in two commodities. The sole is rubber and the upper is cattle leather, and they arrive on separate chains: see tyres and rubber under EUDR for the chapter 40 lines. Neither commodity's evidence answers for the other, and the two are usually held by different suppliers in different countries.
What this page does not do
It does not classify your product, and it does not tell you whether your leather is cattle. Both are determinations with consequences and neither is a Knowledge page's to make.
It does not restate the unpublished amendment: does the July 2026 change to Annex I apply yet.
It does not cover the footwear Digital Product Passport, which is a different regime on a different timetable, owned by the footwear category page.
What would change this answer
Recheck if:
- Annex I is amended to add a chapter 41, 42 or 64 line, which would change the answer
rather than refine it;
- the application dates in Article 38 move;
- Article 9(1) is amended.
Last verified 12 September 2026.
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Sources and legal basis
Does this reach your products?
Give ActivateDigital one product and it works out which obligations apply from the product's own character, and says which it cannot decide.