Public comments on the EUDR changes are visible, but can be submitted anonymously. It’s unclear how many brands have taken a public stance on leather’s inclusion in the law, despite many brands having policies on deforestation-free leather sourcing.
“For some companies, it would be just the difference between going from their own policy to moving into a political space, which I understand can seem like a bit of a step,” says CFJ’s Håkansson. “But it’s really important, because fashion is inherently political, so the industry has an obligation to engage in that space.”
The industry has made its own commitments through multi-stakeholder agreements and funds. In June 2023, Textile Exchange and Leather Working Group launched the Deforestation-Free Call to Action for Leather with brand signatories including Adidas, H&M Group, and Inditex. In the same year, Kering reinforced its commitment to ending deforestation in its supply chains by 2025. Then, in 2025, WWF and Tapestry (which owns Coach, Kate Spade, and Stuart Weitzman) launched the Deforestation-Free Leather Fund, which planned to raise $10 million from brands to support farm-level investment into traceability systems and improvements. Leather Working Group, Kering, and Tapestry declined to publicly comment on the EUDR.
In many ways, silence from brands reinforces the need for regulation, says Rycroft. “The EUDR was introduced to stop deforestation by halting the market dynamics that continue to perpetuate the cycle. It levels up the floor for companies and brands that are slower to move on sustainability issues, and so everybody gets lifted up to a minimum performance.”
Anke Schulmeister‑Oldenhove, manager of Forests at the WWF European Policy Office, added over email: “Excluding leather — one of the commodities with the highest deforestation footprint among those originally covered by the law — shows disregard for clear evidence of environmental harm. The exemption leaves consumers without confidence that the products they buy are truly deforestation‑free and forces responsible brands to operate in an imbalanced market.”
With a suite of laws targeting fashion on the horizon, Rice says that leather’s exclusion from the EUDR could set a precedent that emboldens lobbyists. “If leather is excluded on the basis of industry arguments, which are being debunked, it is setting a very bad example for other industries,” he says. “They might think: ‘We don’t necessarily need to have science on our side, we don’t need to show that we are already sustainable and deforestation-free, we just need to have a very effective lobbying machine in Brussels to avoid scrutiny and legal obligations.’”
Rice from Client Earth says the EUDR’s inclusion of leather should be a “no-brainer” for brands. “Fashion brands will continue to carry the risk of sourcing leather that has been linked to deforestation in the Amazon, the theft of Indigenous lands, or human rights violations, and that kind of reputational damage carries a real price tag,” he says. “So not only do they stand to lose the benefit of an EU-wide mechanism to ensure that leather tanned in Europe is deforestation-free, traceable and legal, but they also carry the risks of sourcing dirty leather if it comes out of the law.”
Leather lobbies might be powerful, but Rycroft is reassured by the progress already made by brands to invest in cleaning up their leather supply chains. “I’m always an optimist,” she says. “There are those that are clearly lobbying against it, but there are a number of companies that have put in place robust internal systems, they’ve already made the investment within their value chain, they’re already making the shift, and so they are also engaging decision-makers to maintain the bar.”
