The Leather Rulebook: A Scannable Guide to the Circularity Rules Hitting Hides, Skins, and Finished Leather

By Kevin Latner, Vice President, LHCA

The big picture: Leather is getting swept into a wave of EU and California circularity rules written for cotton and polyester, not for it. Below is every rule that touches leather, in one line each, with headers so you can jump to the one you need and skip the rest.

Why it matters: The parts of these rules that matter most for leather, fee treatment, certification recognition, what a leather Digital Product Passport eventually requires, are still unwritten. That's a closing window to shape them, not a settled outcome.

Status current as of August 2026. Items marked VERIFY are not yet final; confirm before republishing or quoting externally.

California: SB 707, live now, cost still unknown

The state of play: SB 707 is the first US state EPR law for textiles. It covers finished apparel, footwear, and accessories, leather handbags and shoes included.

• Every producer had to join an approved Producer Responsibility Organization by July 1, 2026.
• CalRecycle's needs assessment is due March 2027; implementing regulations, which set the actual fee structure, aren't expected before July 1, 2028.
• Full program rollout is set for July 1, 2030.

More: SB 707: California's Textile EPR Law Explained — Anthesis

EU: Waste Framework Directive, broader, and leather isn't carved out

The state of play: The revised WFD makes textile and footwear EPR mandatory EU-wide, with national schemes running by roughly 2028. Unlike SB 707, the EU text doesn't exempt leather, it names it directly: Annex IVc lists “textile-related materials such as leather, composition leather, rubber or plastic” among the products in scope.

• France's Refashion program is the closest working model, and it exempts 100% leather and fur garments from EPR fees, even though leather goods generally still fall inside the broader TCLF (Textile, Clothing, Leather, and Footwear) sector Refashion administers.
• Whether the EU-wide scheme follows France's narrower exemption, or treats leather the same as polyester, is one of the biggest open questions in this entire landscape.

More: Revised Waste Framework Directive enters into force — European Commission

Packaging: PPWR, catches almost everyone, registration starts now

The state of play: The Packaging and Packaging Waste Regulation is a second, separate EPR obligation, for the shoe box, the polybag, the pallet, the wrap. It's now confirmed to apply to B2B raw-material shipments too, a tannery shipping hides to a manufacturer needs a Declaration of Conformity for its own shipping materials, not just finished goods.

• Application date: August 12, 2026.
• Recycled-content minimums and reuse quotas phase in through 2030.
• (Full member guidance on packaging obligations is a separate memo, ask if you need it.)

More: The 'E' of ESG: an overview of the new EU Packaging Regulation (PPWR) — Freshfields

Digital Product Passport, footwear isn't in scope yet

The state of play: The DPP is the EU's tracking mechanism: a QR code or RFID tag carrying verified material composition, durability, chemical compliance, and carbon data for a product's whole life.

• Textiles are in the DPP's first working plan. Footwear is not, it's on a separate track.
• A Commission study on footwear-specific rules isn't due until end of 2027.

Translation: the requirements that will eventually apply to leather goods haven't been written yet.

More: ESPR Delegated Acts: Status by Product Group & Working Plan Timeline — DPP Tool

Raw materials: a different rulebook entirely

The state of play: Selling raw hides, wet blue, crust, or finished leather to a manufacturer, not to a consumer, puts you outside SB 707 and the EU textile EPR rules. Those attach to whoever places a finished consumer product on the market.

• The rule that does reach raw hides and leather directly is the EU Deforestation Regulation (EUDR), geolocation due diligence proving cattle weren't raised on land deforested after 2020.
• The European Commission adopted a Delegated Act on July 13, 2026 that removes three specific HS codes, 4101 (raw hides), 4104 (wet blue), and 4107 (finished leather), from EUDR's scope. Live cattle remain a regulated commodity; it's specifically the hide and leather trade that's excluded.
• The act still has to clear a two-month scrutiny period with the European Parliament and Council, with Official Journal publication expected mid-September 2026, and carries its own review clause in 2030.

LHCA covered this in full in a separate article, “Leather Is Out of the EU Deforestation Regulation,” on usleather.org.

More: Commission updates product scope and tools to support EUDR — European Commission

Marketing claims: EmpCo cuts both ways

The state of play: The Empowering Consumers for the Green Transition Directive (EmpCo, Directive (EU) 2024/825) bans vague environmental claims and anything based purely on carbon offsetting. Member states had until March 27, 2026 to transpose it; the directive's own rules apply EU-wide starting September 27, 2026.

• It limits how members can market leather's genuine strengths.
• It also limits competitors making unverified “plant-based” or “vegan leather” claims without backing them up.

More: Empowering Consumers for the Green Transition Directive: Dos and Don'ts — EU Textiles Ecosystem Platform

New: the EU ban on destroying unsold goods

The state of play: A separate rule under the same ESPR framework as the Digital Product Passport bans large companies from destroying unsold clothing and footwear outright.

• In application for large companies since July 19, 2026; medium-sized companies follow in 2030.
• Explicitly names “unsold clothes, clothing accessories and footwear” as covered. No leather carve-out.
• Destruction is now permitted only in narrow cases, unsafe, damaged, counterfeit, or rejected-by-donation goods, with documentation and annual reporting required.

More: Ban on destruction of unsold clothes and shoes enters into application — European Commission

Marketing claims: EmpCo cuts both ways

The state of play: Expected autumn 2026, still undrafted. Meant to tie the above rules together, not replace them. Textiles are already named as a sector it will touch, worth watching, nothing to act on yet.

More: The EU Circular Economy Act: a critical opportunity — Ellen MacArthur Foundation

Also worth watching

The state of play: A few adjacent rules don't reach leather the same way, but are worth tracking.

• France's eco-score (affichage environnemental) explicitly excludes leather from its current scope, it only covers specific textile-based apparel categories.
• France's broader AGEC law is a different story: leather is explicitly folded into AGEC's TCLF (Textile, Clothing, Leather, and Footwear) sector, so most leather goods must register and pay EPR contributions like any textile product, only the narrower garment-fee exemption inside Refashion singles leather out.
• Outside California, New York's SB 3217 defines “textile” to include leather directly and is now in the Senate Environmental Conservation Committee. Washington's HB 1420 has cleared committee and is in House Appropriations; its text doesn't specify leather either way yet.

More: Anthesis — The French Eco-Score Explained

Bottom line: Every rule above that could hurt or help leather specifically, fee treatment, certification recognition, DPP criteria, is still being decided, with windows closing gradually through 2027 and 2028. Next up in this series: why “recycled content,” despite being treated as the gold standard, isn't measuring what most people assume it is.