Yes, the EUDR recognises cattle as one of the seven commodities to which the regulation applies, and the annex to the regulation links more products to that commodity than just live animals and meat. Leather and other hides are mentioned in it as a derived product. Whether a specific article you import actually falls under it depends on the product code under which it is imported, and that is something you must verify for each article.
This means that the question 'does this apply to my business' cannot be answered with a simple yes or no without looking at your own assortment. An importer of leather shoes, bags or upholstered furniture may be subject to the regulation, even though it feels like a different type of product than the beef trade that most people associate with cattle.
What the cattle commodity precisely encompasses
The seven commodities in the regulation are broad categories, and each commodity has an associated list of product codes (CN codes) indicating which goods belong to it. For cattle, it is not only live animals and fresh or frozen meat. The annex also mentions hides and skins, and this brings leather as a derived product into the picture.
This is a surprise for many SMEs. Those who work with coffee or cocoa often already know they fall under the regulation, simply because the word appears in every news report about the EUDR. With cattle, one tends to think more of meat processors and less readily of an importer of leather accessories or a furniture maker who uses leather upholstery.
Why leather is a point of attention
Leather is a processed product, and this raises a question for many businesses as to whether processing does not break the link with the original commodity. However, the regulation does not work that way: if a product is on the list of relevant CN codes, it falls under the obligations regardless of how many processing steps it has gone through. For leather, this means that the origin of the hide, i.e. the country and ultimately the plot where the animal was kept, may be relevant, even if the end product is a bag or chair that no longer seems to have anything to do with livestock farming.
This is consistent with how the regulation also works for timber and cocoa: a piece of furniture or a chocolate bar may fall under the obligations because the commodity is processed in it, not because the end product itself is on a list. With cattle and leather, exactly the same mechanism applies.
How you can verify whether your products are included
The most reliable way to determine this for your own assortment is to compare the product code under which you import against the list in the annex of the regulation. For an importer who does not work with customs codes on a daily basis, this is a cumbersome exercise, especially if the assortment consists of dozens of articles with different suppliers and different countries of origin.
It is therefore prudent not to base this assessment solely on a feeling. A supplier who says that 'leather never falls under those rules' has not thereby provided a legally conclusive answer, because it depends on the exact code and exact composition of the product. In case of doubt, it is advisable to consult the official text or involve a lawyer who is familiar with the annex.
What this means for your role in the supply chain
Whether you actually have an obligation, and what that obligation precisely is, depends not only on the product but also on your position in the supply chain: are you placing the product on the European market for the first time, or are you already buying and selling it within the EU. These two roles have different obligations and different timing for when they apply. in a few questions, see which role fits your situation provides an initial direction there, specifically tailored to the product and the role you specify.
Because cattle and the derived products thereof are not always the first commodity companies think of when it comes to the Deforestation Regulation, it is a subject that benefits from additional explanation. In the knowledge base per situation looked up the breakdown of all seven commodities with the associated product categories is set out, so you do not have to search through the full annex yourself.
A frequently asked question related to this is what happens if part of your assortment falls under the regulation and another part does not. That kind of practical question comes back in the collection of answers to questions that SMEs often ask, so you do not have to look up how the breakdown works again at each point of doubt.
Check for yourself whether your business is affected
The legal assessment of which obligation applies to your products remains with you as a market participant or trader, and this also applies to the question of whether leather or another cattle product in your assortment falls under the regulation. What we can do is help you answer that question in a structured way based on the product codes you provide, and show you which documentation goes with it once that is relevant to your situation.
Would you like to know where your own assortment stands? Take the free role check on eudri.com and read the topics that match your commodity and your role in the supply chain.