The European Commission has published its most consequential set of EUDR updates since the regulation was adopted. A draft Delegated Act revising Annex I, an updated Implementing Regulation, the third edition Guidance Document, the fifth iteration FAQ, the Simplification Review report, and the 4th edition Supply Chain Infographics all landed inside a few weeks. Together they reshape how the EU Deforestation Regulation (EUDR) applies to fashion supply chains. The EUDR is the EU law that requires companies to prove that products placed on the EU market are not linked to deforestation or forest degradation.
If your team has been preparing for EUDR over the last two years, the news is mostly good. Cattle leather is on its way out of scope. Brand and retailer obligations have been substantially reduced. And around half of import volume now qualifies for a simplified pathway. But the regulation has not gone away. The question for fashion teams is not whether you still need to act, but where the work now sits and how to redirect your readiness program accordingly.
Three changes matter most for fashion. First, cattle leather (HS 4101, 4104, 4107) is being removed from scope through the draft Delegated Act, which lifts the heaviest EUDR burden off most brands and footwear retailers. Second, the downstream model is now passive: brands and retailers no longer file their own Due Diligence Statements and only act when concerns are raised. Third, a simplified due diligence pathway opens for sourcing from low-risk countries, with around 51 percent of import volume now qualifying. The application date is 30 December 2026 for most operators and 30 June 2027 for SMEs.
The 2026 revisions tighten the scope of products covered, redistribute obligations across the supply chain, and create a simplified pathway for low-risk and small producers. Three legal acts and four guidance documents work together: the draft Delegated Act amending Annex I, Regulation 2025/2650 amending the core EUDR text, the updated Implementing Regulation on the Information System, and refreshed Guidance, FAQ, and Supply Chain Infographics from the European Commission.
Net effect on Annex I: seventeen HS codes added (mostly oleochemicals and palm-derived chemistry), three deleted (cattle leather), and one replaced (retreaded tyres narrowed to new tread only). Several horizontal exemptions have been codified, including bamboo, single-use packaging, marketing and information materials, samples of negligible value, used or second-hand goods, and recovered or recycled paper and pulp. None of this is bonus content for brands. Each item is a carve-out that removes work you would otherwise have had to do.
The Commission has concluded that including derived leather goods like footwear, handbags, and leather garments was disproportionate to the actual deforestation impact. The draft Delegated Regulation amending Annex I removes HS 4101 (raw cattle hides and skins), HS 4104 (tanned or crust hides), and HS 4107 (further-prepared leather).
The Commission Staff Working Document explains the reasoning: leather is a by-product of meat production with only 2.5 to 5 percent of the deforestation footprint attributable to the hide. Once the Delegated Act adopts, leather and finished leather goods fall outside EUDR. Cattle remain in scope, so the obligation sits with the meat side of the supply chain, not the leather side.
For your brand, this means: if your EUDR exposure was primarily through leather sourcing, that obligation effectively disappears. You may still want to maintain leather traceability for CSRD, CSDDD, and brand ethics commitments, but EUDR itself will not require a Due Diligence Statement on cattle leather. Use this descope as an opportunity to redirect compliance budget toward CSDDD readiness, where leather remains firmly in scope.
Under the revised EUDR, the operator who first places a product on the EU market carries the full due diligence obligation, while everyone further along the chain holds a passive collect-and-keep role. This is the single biggest shift in the regulation, formalised through Regulation 2025/2650 and clarified in the Commission's Supply Chain Infographics.
There are now three distinct actor types, each with a different set of duties:
Role is determined per product, not per company. A brand that imports natural rubber and uses it to make footwear soles is an upstream operator on the rubber input and a downstream operator on the new sole. The same logic applies to a sourcing team buying both EU-converted viscose pulp and direct-imported cotton trims.
For your brand, this means: most fashion sourcing teams are downstream operators or traders for products bought from EU suppliers. You collect the reference number from your supplier, store it for five years, and pass it on to your customer. You only become active if a Competent Authority raises substantiated concerns or if you receive credible information that a product may be non-compliant. Direct imports remain the exception: when you import an Annex I product yourself, you are the upstream operator and the full obligation lands on you.
Sourcing from countries classified as low-risk under the EU benchmarking system unlocks a simplified due diligence pathway, and around 51 percent of importing operators now source from these countries. Under Article 13 of the amended regulation, low-risk sourcing skips the formal risk assessment and risk mitigation steps.
Operators in this pathway still must collect Article 9 information including geolocation, evaluate supply chain complexity, and check for circumvention or mixing. Substantiated concerns still trigger full obligations. The simplification is real but not absolute: think of it as a faster track, not an exemption.
A second simplification targets micro and small producers. The new Micro and Small Primary Operator (MSPO) regime under Article 4a allows qualifying producers in low-risk countries to file a one-off Simplified Declaration rather than a per-shipment DDS. Postal address or cadastral information may replace geolocation when the location clearly corresponds. Cooperatives can act as authorised representatives and submit on behalf of their members.
For your brand, this means: audit your sourcing geography against the new country risk classification under Regulation 2025/1093. If most of your volume is from low-risk countries, the simplified pathway is likely your primary route. If you work with smallholders or cooperatives in those countries, the MSPO regime can dramatically reduce friction in onboarding them to compliance.
Fashion's exposure to EUDR is concentrated in a relatively narrow set of inputs: dissolving wood pulp for man-made cellulosics, natural rubber for soles and elastics, paper sold as a standalone product, and any palm-derived chemistry in own-label personal care lines. Cotton, wool, silk, and synthetic fibres are not in Annex I. Finished apparel made from these is not in scope either.
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IN SCOPE (REQUIRES DUE DILIGENCE) |
OUT OF SCOPE (NO DDS REQUIRED) |
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Dissolving wood pulp HS 4702 sourced directly for viscose, lyocell, modal |
Finished viscose, lyocell, modal yarn or fabric (HS 54 / 55) |
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Natural rubber HS 4001 (Hevea brasiliensis only) |
Synthetic rubber, balata, gutta-percha, guayule, chicle |
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Vulcanised rubber components HS 4008 imported as input |
Used or second-hand rubber items |
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Paper, paperboard, kraft paper sold as a product in its own right |
Cardboard, paper, polybags used as packaging for another product |
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Wooden frames, fittings, hardware HS 4414 |
Bamboo, rattan, reeds, rushes textiles and components |
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Cattle (live, meat, frozen tongue) HS 0102 / 0201 / 0206 |
Cattle leather and hides HS 4101 / 4104 / 4107 (post-Delegated Act) |
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Standalone B2B sale of paper cartons or wood pallets |
Hangtags, care labels, manuals, lookbooks, leaflets |
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Palm-derived soap, fatty alcohols, glycerol in own-brand toiletries |
Cotton, wool, silk, polyester, nylon, finished apparel from these |
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New rubber tread for retreaded tyres HS 4012 90 30 |
Showroom samples and lab swatches of negligible value |
A practical implication: hangtags, care labels, polybags, mailer envelopes, showroom samples, and recycled-content paper can be excluded from your DDS workstream. Document the exemption rationale and keep evidence for the five-year retention period.
The EUDR application date is 30 December 2026 for most operators and 30 June 2027 for SMEs and micro operators. The Information System reopens in June 2026 with new role registration, simplified declaration support, voluntary DDS grouping, and contingency reference numbers.
A few timeline anchors worth noting:
Products placed during the transitional window from 29 June 2023 to 29 December 2026 are subject to lighter rules. Downstream actors only need adequately conclusive proof of pre-application placement, not a DDS in the Information System. Mass balance chain of custody is not permitted under EUDR. Physical segregation is required at every stage of the supply chain.
Cattle leather is being removed from scope through the draft Delegated Act amending Annex I. HS codes 4101, 4104, and 4107 are deleted. Once the Delegated Act adopts, finished leather goods like footwear and handbags fall outside EUDR. Cattle (live, meat) remain in scope, so the obligation sits with the meat supply chain, not the leather side.
In most cases, no. Under the revised EUDR, brands and retailers buying products that have already been placed on the EU market are downstream operators or traders. They collect the upstream reference number, store it for five years, and act only if substantiated concerns arise. The exception is direct imports: when a brand imports an Annex I product itself, it becomes the upstream operator and the full DDS obligation applies.
An upstream operator is the first person or company to place a relevant product on the EU market, typically the importer or EU producer. They run full due diligence and submit the DDS. A downstream operator buys from an upstream operator and uses the product further along the chain. Downstream operators do not file a new DDS; they collect and forward the upstream reference numbers.
No. Mass balance is explicitly not permitted under EUDR. Commodities intended for the EU market must be kept physically segregated at every stage of the supply chain. This is reaffirmed in the 4th edition Supply Chain Infographics published by the European Commission.
Operators sourcing from countries classified as low-risk under the EU benchmarking system can skip the formal risk assessment and risk mitigation steps under Article 13. They still need to collect Article 9 information including geolocation, evaluate supply chain complexity, and check for circumvention or mixing. Substantiated concerns trigger full obligations regardless of country risk tier.
Use the descope window to redirect EUDR effort toward the obligations that remain. The biggest mistake brands can make right now is assuming the work is finished. The work has shifted, not disappeared.
TrusTrace helps fashion brands and retailers navigate EUDR readiness by combining supply chain mapping, geolocation data collection, and DDS management in a single platform. Whether you are an upstream operator running full due diligence on natural rubber imports or a downstream operator building reference number exchange with your tier-one suppliers, TrusTrace gives your team the data infrastructure to act with confidence. Trusted by brands representing over $200 billion in combined retail sales, TrusTrace turns regulatory complexity into operational clarity. Speak with one of our experts or explore our EUDR solution.
Disclaimer: This content is for informational purposes only and does not constitute legal advice. Please consult legal professionals for guidance specific to your situation.