The big picture: Multiple jurisdictions across the globe are writing circular-economy rules for textiles and footwear. These rules include EPR (extended producer responsibility) fees, rules on packaging, due diligence for deforestation risk, digital product passports and more. Leather is getting caught in the fray even though most of these rules are being written with textile and apparel products in mind.
Why it matters: Rules built for cotton or polyester products measure leather by a yardstick that doesn’t apply to a by-product. Once locked in, that mismatch could have significant implications. While the details of these rules are being written, there’s an opening.
The mismatch
The problem: Recycled-content percentages don't mean much for a material that's already durable and biodegradable. A hazardous-substance test built around PVC or polyurethane risks penalizing chromium-tanned leather for chemistry it doesn't use.
- These rules started as textile and apparel rules, then got stretched to cover “footwear” as a category leather happens to sit inside.
- Regulators drafting these rules are not thinking about leather specifically.
What we've built
The map: We’re working on tracking current and pending rules that touch leather to understand what’s settled, what’s still being drafted, and how much runway is left on each. This helps us identify how we need to advocate for our sector.
The fact base: The evidence the advocacy has to stand on.
- Verification of actual global plastic and textile recycling rates.
- Comparison of leather’s real chemical profile against other materials such as PVC and polyurethane.
- Identifying where programs like LWG (Leather Working Group) and the Sustainable Leather Foundation should be recognized in the frameworks being built.
The publishing order, and why
The strategy: Credibility before asks.
- Start neutral, what the rules actually say, not what anyone wants them to say.
- Then evidence-based pieces on recycling and chemistry.
- Only then the direct asks: recognize LWG/SLF the way GOTS (Global Organic Textile Standard) and Bluesign already are; require the same composition disclosure from mycelium and cactus “leather” that natural leather itself already provides.
Asking for recognition before the credibility is earned reads as self-interested. That's why the order matters.
Where this is headed
Near-term: PPWR's packaging obligations are already live. The deforestation regulation's leather carve-out should be confirmed soon — both need member-facing compliance guidance, not advocacy.
Longer-term: The EU's ecodesign and product-passport rules for footwear don't take effect until a Commission study lands at **end of 2027**. That's the window to get durability and biodegradability counted before the criteria are set.
Bottom line: Leather didn't write these rules and wasn't in the room when most of them were drafted. Some of what's left to decide is closing fast. This project exists to be in the room for what's still open.
