On 21 October 2025, the European Commission unveiled its proposal for amending the EUDR — keeping it to enter into application within 2 months. After previously communicating a one-year postponement, this sudden reversal feels less like sound policymaking and more like a Halloween horror story for European industries.
So, what exactly is wrong with the EUDR amendment?
- The Commission now states that there will be no scope-related Impact Assessment under Article 34 — a legal obligation that was due in June 2025,
This is unacceptable. It denies the leather industry its legal right to evidence-based policymaking and leaves unanswered the fundamental question:
Do hides, skins or leather actually drive deforestation?
- Why does the Commission disregard the evidence put forward by the impact assessment commissioned to a University by the industry?
In the absence of a Commission-led assessment, the leather industry commissioned the Sant’Anna University of Applied Sciences in Pisa to conduct a study. Based on 94+ million data records, 29,200 active serial titles, 330,000 books, and 28 stakeholder interviews, the research found no scientific evidence linking leather to deforestation.
“There is no direct link between leather and deforestation. Leather is a by-product of the meat and dairy sectors — its production does not incentivise cattle farming”
- Can't the Commission hear the call of the global leather industry for a proper impact assessment?
The EU leather industry’s right to an impact assessment is also supported by the global sector, as reaffirmed in the Leather Manifesto for COP30, to be presented at the UN Climate Conference in Belém. The Manifesto calls for a full and proper impact assessment of the unsubstantiated claim that leather drives deforestation — and for evidence-based regulation that strengthens, rather than undermines, Europe’s sustainability goals.
The leather sector stands for transparency, responsibility, and facts — not ideological debates.
COTANCE urges the European Commission to respect its legal obligations and carry out the impact assessment required under Article 34, ensuring that leather, hides, and skins benefit from an evidence-based regulatory process.