The direct answer: the scope of the EU Deforestation Regulation (EUDR — (EU) 2023/1115) changed significantly in 2026. The European Commission adopted Delegated Regulation (EU) 2026/2102 (in force from 18 September 2026), formally removing cattle hides, skins and leather, retreaded tyres, rubber transmission belts and sowing soybeans from Annex I — meaning Vietnamese leather exporters to the EU are no longer in EUDR scope. Paper and pulp (chapters 47/48, except bamboo and recycled paper), by contrast, STAY in scope. At the same time, Regulation (EU) 2025/2650 pushed back the general application dates: 30 December 2026 (medium and large companies) and 30 June 2027 (micro and small companies). Vietnamese businesses must re-read their entire compliance plan under the new framework — much existing guidance (including from this very campaign) is already outdated.
Leather out of scope: what (EU) 2026/2102 changes in detail
The delegated act (EU) 2026/2102, adopted 13 July 2026 and in force from 18 September 2026, amends Annex I of the EUDR. Removed: cattle hides, skins and leather — big relief for Vietnam’s leather and footwear exporters to the EU; retreaded tyres; rubber transmission or conveyor belts; and soybeans for sowing. Added, in the other direction: instant coffee, frozen bovine tongues, and certain palm-oil derivatives — applying from 30 December 2027. The Commission says leather will be reconsidered in the 2030 EUDR review, so “out of scope” today does not mean a permanent exemption. For leather businesses: stop spending on due-diligence-statement preparation for leather immediately — but keep the traceability system, because EU buyers may still demand it contractually.
Paper and pulp stay in: what paper businesses do with the new timetable
Paper, paperboard and pulp under chapters 47/48 of the Harmonised System (except bamboo and recycled paper) remain in EUDR scope — nothing in the 2026 amendments changes that. The new timetable under (EU) 2025/2650 (adopted by Parliament and Council 19 December 2025, published 23 December 2025, in force 26 December 2025): medium and large companies apply from 30 December 2026; micro and small companies from 30 June 2027. Beyond the postponement, (EU) 2025/2650 also: removes printed products (books, newspapers) from scope; creates a new “downstream operator” category (no due-diligence statement required); and lets micro/small primary operators file a one-off simplified declaration. Vietnamese paper businesses: use the extra time to finalise plot geolocation systems and due-diligence statements — do not read the postponement as “delayed indefinitely”; the Commission has said there will be no further delay.
Warning: much old guidance is outdated — check three points before acting
Point one: the dates. Any document saying “applies from 30/12/2025 / 30/06/2026” is old — the new dates are 30/12/2026 and 30/06/2027. Point two: product scope. Any checklist still listing leather is wrong; any checklist missing instant coffee, frozen bovine tongues and palm-oil derivatives (from 30/12/2027) is incomplete. Point three: downstream-operator obligations. If a business only processes or packs at the end of the chain, it may fall into the new “downstream operator” category and be exempt from the due-diligence statement — but it must correctly identify its position in the chain, not assume. Recommendation: check the full texts of (EU) 2025/2650 and (EU) 2026/2102 on EUR-Lex (English) directly rather than relying on secondary summaries, because summaries written before September 2026 do not reflect this amendment round.
Frequently asked questions
- Is leather still under the EUDR?
- No. Delegated Regulation (EU) 2026/2102 (in force 18/9/2026) removed cattle hides/skins/leather from EUDR Annex I. Leather will be reconsidered in the 2030 review, so this is not yet a permanent exemption.
- What about paper and pulp?
- Still in scope (chapters 47/48, except bamboo and recycled paper). The 2026 amendments change nothing for this group.
- What is the current EUDR application timetable?
- Under (EU) 2025/2650: 30/12/2026 for medium and large companies; 30/06/2027 for micro and small companies. The Commission says there will be no further postponement.
- What is a “downstream operator”?
- A new category created by (EU) 2025/2650: operators at the downstream end of the chain are not required to submit a due-diligence statement. Businesses must correctly identify their chain position before relying on it.
