It is essential the EUDR is implemented with no further delays

Global Canopy has submitted feedback to the public consultation on proposed changes to the EU Deforestation Regulation [EUDR]. It is crucial all stakeholders swiftly implement and prepare for its application at the end of 2026, with no further delays and no further weakening of the obligations it imposes on companies. In addition, we urge the EU not to remove leather from the product scope, as this is a wasted opportunity to tackle an important component of supply chains in the cattle sector – the single most important sector for global deforestation. 

The EUDR must be implemented as soon as possible

Global Canopy strongly supports the objectives of the EUDR and urges its swift and robust implementation as soon as possible. The latest Trase data shows EU imports continue to be linked to deforestation around the size of Rome every year. 

There is widespread support for the EUDR among businesses, investors, civil society organisations and the public.

• In December over 120 companies, investors and NGOs signed a joint statement calling on the European Commission to end the legal uncertainty and implement the EUDR. 
• In October 2025 major agri-food companies, including Nestle, Ferrero and Olam Agri, wrote to the EU Commission warning against any further delays.
• Ahead of COP30 in Belém, 51 institutional investors from across the world, collectively managing more than USD 4.5 trillion in assets, signed the Belém Investor Statement on Rainforests, calling for governments to implement strong policies, regulations and mechanisms to eliminate commodity-driven deforestation.
• Polling shows the overwhelming majority of Europeans support strong laws to combat deforestation. In the Savanta poll conducted in 2024, 84% of all respondents wanted to see implementation of the EUDR, while 73% believe it should be a key priority for the EU. 

When the EUDR was first passed, it stated the Union should be “a strong global actor, leading both by example as well as by taking the lead in international cooperation to create an open and fair multilateral system where sustainable trade acts as a key enabler of the green transition to fight climate change and reverse biodiversity loss.” Our latest Forest 500 data shows that even though the law has not yet been implemented, it has driven change: among the 500 most influential companies in the deforestation economy, improvements in traceability are reported across eight of the nine EUDR commodities. 

Companies have had more than three years to prepare for this regulation and many are well-advanced and ready for implementation. Businesses want certainty around the regulatory environment, which is why in July over 60 major companies including Nestlé, IKEA, Barry Callebaut, Unilever, Mars and Ferrero publicly backed the EUDR and opposed efforts to weaken it. These companies have invested in compliance systems and warn that changes now would undermine these investments, deepen regulatory uncertainty and cause further delays.

Producer governments have also invested in supporting EUDR compliance including in national traceability systems, geolocation of smallholders and forest monitoring systems and maps. This includes Kenya’s and Cameroon’s coffee sector, Costa Rica’s timber sector, and Peru’s coffee and cocoa sector. So further delays or changes to the EUDR would undermine the EU’s credibility and partnerships with producer countries.Key to effective implementation is enforcement. EU member states have a critical role in enforcement and each country needs to ensure they are sufficiently resourced to enforce the EUDR.  

Leather belongs in the EUDR product scope

The EUDR must address unsustainable cattle expansion – the world’s biggest cause of commodity-driven deforestation. The expansion of cattle pasture accounted for 42% of global deforestation driven by agriculture between 2001 and 2022. It is therefore essential that the EUDR applies to both major drivers of cattle expansion: beef and leather.

The EUDR was formally introduced in 2021 and passed in 2023, so companies have had years to adapt. Forest 500 also shows that many downstream companies exposed to leather are reporting increased action on traceability, meaning that inclusion in the Regulation would pull in the same direction as trends in buyer demand. Progress since the 2024 assessment includes:

• Spanish clothing company Inditex and automotive companies BMW Group and VW Group added traceability mechanisms for leather. 
• French luxury goods company Kering (Gucci, Bottega Veneta, Saint Laurent brands) bolstered traceability to the production unit by adding a compliance check against DCF standards. 
• German sports shoe giant Puma extended traceability to the processing facility (in 2024 it had traced just to the country of origin). 
• Italian leather processor Rino Mastrotto now traces to the production unit (in 2024 it traced to the processing facility). 

In 2025, 20 companies that produce and/or source leather in high- and unknown-risk regions were involved in collaborative action initiatives and partnerships including:

• The Leather Working Group
• The Certification of Origin and Traceability Implementation Initiative
• The Fashion Pact Network

Seven companies – including Adidas, Capri Holdings and Tapestry (Coach New York and Kate Spade New York brands) – joined the Deforestation-Free Call to Action for Leather, an initiative that asks signatories to commit to source all their bovine leather from DCF supply chains by 2030 or earlier. 

The EU has a vital opportunity to bolster and reinforce these sectoral efforts to tackle deforestation; removing leather from the EUDR now will send the wrong signal instead.

Read our evidence