Is Leather or Footwear in EUDR Scope After the 2026 Annex I Amendment?

What changed

Regulation (EU) 2026/2102 was published on 17 September and entered into force on 18 September 2026. Its Annex deletes the cattle hide/leather lines that previously supported the main worked example on this page.

What changed in EUDR Annex I? sets these deletions in the wider amendment.

What should a footwear business do now?

1. Re-run any rule that relied on the old leather entries

If a product, supplier questionnaire or evidence workflow was triggered by 4101, 4104 or 4107, mark that rule as superseded and re-classify against the amended Annex.

2. Do not preserve obsolete evidence requests by inertia

The fact that a business previously collected geolocation or due-diligence evidence for cattle leather does not make the deleted Annex route continue as law. Retain historical evidence where needed for auditability, but do not describe the old scope rule as current.

3. Classify other components separately where relevant

A footwear product can contain materials that have their own separate EUDR pathways. Rubber is the obvious example, but its Annex treatment also changed in 2026. A separately placed-on-the-market rubber component has to be checked against the current rubber entries and the Hevea brasiliensis commodity boundary.

See Tyres and rubber parts under the amended EUDR Annex.

Does a rubber sole make the finished shoe an EUDR product?

Not by itself. The finished shoe's own CN classification still matters. An EUDR-relevant material in the supply chain does not automatically convert the finished article into a relevant product.

If you buy or sell a separate rubber article that has its own listed CN pathway, classify that article independently.

What data should you collect?

Collect EUDR due-diligence data only after establishing a current relevant-product pathway and the business's legal role. Do not use the old leather entry as a blanket reason to demand:

• cattle plot geolocation
• production-date evidence
• due-diligence statement references
• no-deforestation evidence

for a footwear product or leather input that is no longer within Annex I through the deleted lines.

Separate commercial traceability, animal-origin, product-safety or DPP data needs may still exist under other regimes. They should not be labelled as EUDR evidence unless EUDR requires them.

What this page does not do

This page does not classify every shoe, leather good or rubber component. It owns the current worked EUDR boundary for leather and footwear after the 2026 Annex amendment.

Use EUDR scope for the general classification method and the core EUDR page for due diligence, geolocation, dates and roles.

What would change this answer

A later Annex I amendment that reintroduces cattle hide/leather products, a relevant CN restructuring or another legal act changing the treatment of the worked product families would require this answer to be revisited.

Sources and legal basis

• Regulation (EU) 2023/1115 and Annex I
• Commission Delegated Regulation (EU) 2026/2102 amending Annex I