Brussels has locked in the final product list for the EU Deforestation Regulation, excluding cattle hides, skins, and leather from its scope and allowing companies to pull wood and palm oil out of its reach by labelling them as waste. That is according to the European Commission, which yesterday formally rewrote Annex I of the regulation alongside an implementing act setting the technical rules for the Information System that will process due diligence statements.
“The decision to exclude leather from the EUDR is deeply disappointing,” Fyfe Strachan, the Earthsight policy lead, said, having warned after November’s parliamentary vote that lawmakers had voted to press pause on protecting forests. Eight in ten citizen submissions on leather during the Commission’s consultation backed keeping it in scope, according to Earthsight, which provided a statement to Wood Central.
Standing behind the decision, EU Environment Commissioner Jessika Roswall argued the package delivers the clarity and predictability that businesses, member states and trading partners need before the law applies at the end of 2026: “We have completed the simplification review and put in place the necessary measures,” Roswall said. Monday’s adoption completes the simplification package Brussels delivered on 4 May, a package Wood Central revealed would come without a third rewrite of the law’s primary text.
Escape hatches inside the act reach beyond leather, because wood and palm oil now leave the law’s scope the moment they are labelled as waste, a change campaigners told ENDS Europe risks incentivising biofuels fraud.
Earthsight warns the waste palm carve-out will feed an existing loophole for fresh palm oil fraudulently mislabelled as waste, with analysis of EUROSTAT and shipment records finding the exemptions could take more than a quarter of all EU palm oil imports from Indonesia and Malaysia out of scope, worth €1.7 billion in trade in 2025 figures.
Wood Central understands that the adopted act goes further on waste than the 4 May draft, which listed waste among general exemptions without naming wood or palm oil. Beyond the waste route, enforcement gaps persist at the border, with illegal timber still able to reach Europe through hubs like Singapore and Hong Kong despite both ranking as low risk under the bloc’s country benchmarking.
Brussels’ own staff working document valued the environmental benefits of keeping leather inside the law at between €979 million and €1.96 billion a year, compared with compliance costs the Commission itself put at €16.7 million annually. Cattle ranching accounted for 42 per cent of global deforestation between 2001 and 2022, according to peer-reviewed research cited by campaigners, and hides leave the abattoir on the same supply chain as the beef the regulation still polices.
“Converting a by-product of livestock into leather does not drive deforestation,” COTANCE secretary general Edoardo De Paola said when the draft act appeared in May, crediting the Commission with correcting a flaw Europe’s tanners have contested from the start. Behind the exclusion sits a lobbying push that Earthsight analysis found reached far-right parliamentary groups, with leather bodies holding at least 22 recorded meetings with EU lawmakers and officials since 2021.
Six years of investigations feed the criticism, with Earthsight tracing hides from stolen Indigenous land in the Paraguayan Chaco to the seats of Europe’s luxury cars in its 2020 Grand Theft Chaco report, and linking leather suppliers of the fashion brand Coach to illegal cattle ranching on Indigenous land in Brazil’s Pará state in last year’s The Hidden Price of Luxury. Italy still receives more than half of Paraguay’s global hide exports and 99 per cent of those sent to the EU, according to the group’s most recent trade data.
What the final list means for wood…
Timber remains fully inside the law as one of seven commodities, alongside cattle, cocoa, coffee, palm oil, rubber and soy, and every operator selling wood products into Europe must still prove they are deforestation-free and legally produced. New horizontal exemptions, however, carve out samples, used and second-hand goods, and packing material from the scope, with the packing carve-out covering the single-use and reusable materials and containers set out in the May draft.
Re-treaded tyres, soybeans for sowing, articles of vulcanised rubber, conveyor and transmission belts and vehicle seats exit the list alongside leather, while additions covering soluble coffee, certain palm oil derivatives and frozen cattle tongues only become subject to the regulation from 30 December 2027. Micro and small timber operators already covered by the EU Timber Regulation start on 30 December 2026, rather than the 30 June 2027 date given to other small firms.
Following technical updates, the Information System reopened at the end of June, nine months after the platform’s stress-test failures pushed Brussels into a second delay, and company training sessions began in late July.
“There are no remaining excuses for delay,” Béatrice Wedeux, the senior policy officer for forests at WWF, told Euractiv after the adoption, arguing companies and member states now hold every tool needed to move decisively to full implementation.
Corporate readiness tells a harder story, because one in three companies trading forest-risk commodities still holds no deforestation commitment, a share unchanged from a year earlier.
Momentum is now moving toward national alignment after Britain confirmed last month that it will mirror the EUDR’s commodity and traceability rules. Wood Central understands that the delegated act now heads to the European Parliament and the Council for scrutiny before entering into force, and the Commission has confirmed the law takes effect for large and medium operators on 30 December 2026, two full years behind the start date first written into the regulation.
