Leather Product Regulations in the European Union: An Overview

Leather products imported or manufactured in the European Union are subject to various regulations and standards. These cover substance restrictions, deforestation, labelling, and other compliance requirements.

In this guide, we take a closer look at the REACH regulation, EUDR, and other requirements applicable to leather products in the European Union.

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Textile Labelling and Fibre Composition Regulation

The Textile Labelling and Fibre Composition Regulation sets labelling requirements for textile products in general.

The regulation also has specific labelling requirements for textile products that contain non-textile parts of animal origin. According to the regulation, if your textile product contains non-textile parts of animal origin, such as leather, you should:

a. Label or mark the product with the phrase “Contains non-textile parts of animal origin”, and

b. Ensure the label is easily understandable and not misleading.

Directive 94/11/EC on Labelling of Materials Used in Footwear

Directive 94/11/EC sets labelling requirements for footwear. It covers various types of footwear, including those made of leather, such as ankle boots and high-heeled shoes.

The directive sets the following definitions:

a. “Footwear” as products with a sole that covers or protects the foot,

b. “Leather” as tanned hide or skin that has a mostly intact natural fibrous structure that makes it resistant to decay, and

c. “Coated leather” as leather with an applied coating surface layer that is thicker than 0.15 mm but no more than one-third of its total thickness.

Annex I of the directive provides the pictograms and written indications for how you should label leather footwear.

You can use either the provided pictogram or a written indication, which specifies either “Leather” or “Coated leather” in various languages of the EU member countries. Here are the pictograms taken from the directive (the one for leather is on the left, while the one for coated leather is on the right):

Note that the pictograms concerning the material must be printed near the pictogram that specifies the relevant part of the footwear, which can be:

• Upper
• Lining and sock
• Outer sole

This is because different parts of the footwear could be made of different materials.

EU Deforestation Regulation (EUDR)

The EU Deforestation Regulation aims to ensure that certain products imported into or exported from the EU are free from deforestation and do not contribute to forest degradation. The regulation applies to the commodities and products listed in Annex I, such as leather of cattle and raw hides.

Covered leater products

Here are some examples of relevant products and their CN codes that concern cattle leather and hides:

41 07 – Leather of cattle, further prepared after tanning or crusting, including parchment-dressed leather, without hair on, whether or not split, other than leather of heading

41 01 – Raw hides and skins of cattle (fresh, or salted, dried, limed, pickled or otherwise preserved, but not tanned, parchment-dressed or further prepared), whether or not dehaired or split

41 04 – Tanned or crust hides and skins of cattle, without hair on, whether or not split, but not further prepared

Note that we could not find any indication that this regulation applies to “finished” leather products in general. We were only able to identify that the regulation applies to the materials.

EUDR requirements

The EUDR generally requires companies to:

a. Exercise due diligence by:

• Collecting details about the type of leather used in the product
• Performing risk assessments, and
• Applying risk-mitigation strategies (e.g. third party audits)

b. Provide a due diligence statement containing the information listed in Annex II

c. Retain due diligence documentation and provide it to authorities upon request

However, there are exceptions for SMEs and commodities and products that are imported from countries that are deemed low risk. You can find more information in our guide dedicated to the EU Deforestation Regulation.

REACH Regulation

The REACH Regulation restricts the use of certain substances used in products sold in the European Union, including leather and products made of leather.

You generally need to have your product undergo testing to ensure that it does not contain any prohibited substances or substances that exceed the allowable limits.

Annex XVII

Annex XVII to REACH contains substances that are restricted for use in some consumer products. It specifically lists the following three substances that apply to leather:

a. Chromium VI compounds, which are restricted to 0.0003% by weight of leather products and leather parts of products that come into contact with the skin

b. Nonylphenol C6H4(OH)C9H19 / Nonylphenol ethoxylates (C2H4O)nC15H24O, which is restricted to 0.1% by weight in leather processing, except processing without wastewater release and pre-treated water before biological treatment

c. Azocolourants and Azodyes:

• Prohibited from use in the dyed parts of leather toys and toys that include leather garments if more than 0.003% by weight of aromatic amines are released
• Restricted to 0.1% by weight if intended for use in colouring leather articles

Entry 43 of Annex XVII, which concerns Azocolourants and Azodyes, references “testing methods listed in Appendix 10”, which includes testing methods for leather:

EN ISO 17234-1 – Leather – Chemical tests for the determination of certain azo colorants in dyed leathers – Part 1: Determination of certain aromatic amines derived from azo colourants

EN ISO 17234-2 – Leather – Chemical tests for the determination of certain azo colourants in dyed leathers – Part 2: Determination of 4-aminoazobenzene

Note that some substances are restricted in articles in general. As such, these restrictions also apply to leather products. For example, some phthalates (e.g. DEHP, BBP, DBP) are restricted in plasticised materials, which can sometimes be found in coatings and paints applied to leather.

SVHC List

The Substances of Very High Concern (SVHC) Candidate List contains substances that can permanently harm the environment and human health. You should notify ECHA via the SCIP database if your product contains more than 0.1% of a specific SVHC.

Leather products may contain SVHCs, such as:

• Bisphenol A
• 4,4′-sulphonyldiphenol

Additional Requirements

This section lists other regulations and explains their relevance to leather.

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