Why LHCA Is Tracking the Circularity Rules

By Kevin Latner, Vice President, LHCA

The big picture: California and the EU are building a circular-economy rulebook for textiles and footwear, EPR (Extended Producer Responsibility) fees, packaging rules, deforestation due diligence, a digital passport. Leather is caught up in almost all of it. Almost none of it was written with leather in mind.

Why it matters: Rules built for cotton and polyester measure leather by the wrong yardstick. Once locked in, that mismatch is permanent. Several of these rules aren't locked in yet, that's the 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.
• Nobody drafting them was thinking about leather specifically.

What we've built

The map: Every current and pending rule that touches leather, tracked for what's settled, what's still being drafted, and how much runway is left on each.

• SB 707 (California), the EU Waste Framework Directive, PPWR, the Digital Product Passport, the Deforestation Regulation, EmpCo, the EU's new ban on destroying unsold goods, and the still-unwritten Circular Economy Act.

The fact base: The evidence the advocacy has to stand on.

• Verified the actual global plastic recycling rate.
• Compared leather's real chemical profile against PVC and polyurethane.
• Identified where LWG (Leather Working Group) and the Sustainable Leather Foundation (SLF) aren't yet 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 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, settled: PPWR's packaging obligations are already live, and now confirmed to reach B2B raw-material shipments, not just finished goods. The Deforestation Regulation's leather carve-out has a firm shape: a Delegated Act adopted July 13, 2026, pending a scrutiny period that should close by mid-September. Both need member-facing compliance guidance, not advocacy.

Longer-term, open: 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.