The EUDR Simplification Package & Its Impact on the Apparel & Footwear Industry
As part of the EU’s commitments to protect forests globally, the Deforestation Regulation (EUDR) was first adopted in 2023. It bans the placement on the EU market of listed commodities, namely cattle, cocoa, coffee, palm oil, rubber, soy, and wood, plus their derived products, if they were produced on deforested land. It includes due diligence obligations for companies importing, exporting or placing on the market such products to ensure they are deforestation-free. In line with the larger agenda of the current EU Commission to cut red tape for companies across its sustainability legislation, the EUDR was postponed several times, with the last postponement measure including a targeted reduction of obligations for companies.
What is included in the simplification package?
On May 4th 2026, the EU Commission published the simplification package, a measure promised as part of the last amendment in late 2025, arguably as a compromise for stakeholders whose proposals were not included in the 2025 amendment. While the obligations and timelines for companies obliged to comply remain unchanged, the EU Commission’s text proposes an amendment to the list of products in scope of the EUDR obligations.
Leather
This amendment follows sustained lobbying efforts from the leather industry in the past months, which argued that leather is a by-product of the meat industry and should therefore be exempted. With this amendment, the leather industry has been effectively excluded from EUDR obligations. Two impacts are:
The EU is the second largest importer of Brazilian hides and skins. Some reports continue to evidence that leather is a key commodity in Amazonian deforestation. Removing it from scope would therefore be seen as a step backwards from the EUDR's ambition to ensure products sold on the EU market are deforestation-free.
Many brands in the textile industry have spent the last two years preparing for EUDR compliance on leather; securing leadership buy-in, funding traceability projects, and building internal processes. This last-minute exemption puts all of those investments at risk. For example, brands across the agri-cultural sector have joined forces to call on the EU Commission not to reopen the EUDR, underlining that no further amendment was needed for companies that have been investing in EUDR compliance: “If the regulation is reopened yet again after the April review, (...) all these investments will be put at risk.”
On top of this, this exemption raises a broader question: if leather is classified as a by-product for EUDR purposes, does it set an unusual precedent for considering it out of scope for the Product Environmental Footprint too?
Packaging
Certain packaging materials are now exempt, specifically 'single-use packaging materials' and 'packaging clearly suitable for repetitive use'. The term 'single-use packaging material' has not yet been defined in the context of EUDR. If existing legislation offers any interpretation, the implications could be far-reaching.
The Single Use Plastics Directive defines a single-use plastic product as one "not conceived, designed or placed on the market to accomplish, within its life span, multiple trips or rotations." The Packaging & Packaging Waste Regulation (PPWR) applies a similar logic. By that standard, is a shoebox for your newest sneakers, or a plastic bag for your new dress, designed for multiple uses? Most consumers and most producers would say no. Therefore, if that interpretation carries over to EUDR, a significant proportion of consumer-facing packaging used across the textile industry could fall outside of scope entirely.
How 2BPolicy supports brands & retailers
Keeping up with fast-moving policy developments and translating them into practical, actionable insights is increasingly demanding for companies already stretched on compliance. At 2B Policy, this is exactly what we do. If your organisation is navigating the implications of these EUDR amendments, we are here to help.
