We recently wrote to the EU Commission who are considering relaxing the rules that prevent deforestation around the world, in order to allow more cattle grazing. This is specifically at the request of leather producers.
This is our open letter.
Date: 22 May 2026
To: European Commission Have Your Say – Public Consultation Re: Initiative 18053 – Deforestation: Proposal to Amend and Simplify the Rules and Make Technical Fixes to Annex I
Response to the Proposed Exclusion of Leather (Bovine Hides) from the EU Deforestation Regulation (EUDR)
Dear President von der Leyen, Commissioners and Officials,
Net Zero Heroes is a UK-based climate action platform dedicated to empowering individuals to understand and reduce their carbon footprint. Our mission is grounded in one principle: every tonne of carbon matters. It is from this evidence-based perspective that we write to formally oppose the European Commission’s proposal to exclude leather, hides, and skins (HS codes 4101, 4104, and 4107) from Annex I of the EU Deforestation Regulation.
We urge the Commission to reverse this proposal and maintain leather within the EUDR’s scope. The scientific, environmental, and ethical case for doing so is overwhelming.
1. Forests Are Indispensable to Global Net Zero Goals
The world’s forests are our single most important natural defence against climate change. According to the UN Food and Agriculture Organization’s latest data (October 2025), the world’s forests sequester approximately 3.6 billion tonnes of CO₂ annually, yet deforestation emissions of 2.8 Gt CO₂ per year during 2021–2025 are eroding that vital sink, reducing the net benefit to just 0.8 Gt CO₂ nearly half what it was a decade earlier.
The UN Environment Programme confirms that forests and woodlands absorb 30% of all emissions from industry and fossil fuels, while deforestation and forest degradation account for 11% of global carbon emissions. The latest UN Global Forest Goals Report (May 2026) warns that global forest area declined by more than 40 million hectares between 2015 and 2025, and that progress is “not at the pace or scale required” to meet 2030 climate targets.
Put simply: we cannot reach net zero while continuing to lose forests at this rate. Any regulatory weakening that enables further deforestation is directly incompatible with the EU’s own climate commitments under the European Green Deal and the Paris Agreement.
2. Cattle Ranching Is the World’s Leading Driver of Deforestation
The proposal to exempt leather cannot be separated from the commodity that produces it. A landmark study published in Nature Food (February 2026) found that the expansion of cattle pasture accounted for 42% of all global commodity-driven deforestation between 2001 and 2022, destroying an area of forest roughly the size of Spain (~51 million hectares), and was responsible for 52% of all carbon emissions caused by commodity-driven deforestation worldwide.
Brazil alone accounted for 26% of all commodity-driven deforestation globally during this period, with cattle expansion in the Brazilian Amazon four times larger than the next biggest commodity driver (palm oil from Indonesia). According to WWF, extensive cattle ranching accounts for 80% of current Amazon deforestation and is responsible for the release of 340 million tonnes of carbon to the atmosphere every year. That’s equivalent to 3.4% of current global emissions.
In 2024, the tropics lost 6.7 million hectares of primary rainforest more than any other year in the past two decades, the equivalent of 18 football pitches being cleared every minute.
3. Leather Is Not a Mere “By-Product”. It Is an Economic Driver of the Cattle Industry
The leather industry’s central argument (that hides are simply “waste” from beef production) is contradicted by the evidence. In 2024, leather accounted for one quarter of the total value of all cattle products in the EUDR’s scope imported by the EU. In Brazil, the leather industry generates over US$1.1 billion in exports annually, with the EU as the second largest destination market.
Research by Natural Intelligence (2023) found that Brazilian slaughterhouses operating on profit margins of 2% or less would cease to be viable businesses if they could no longer supply the European leather market. Leather demand directly shapes the economics of the cattle sector and, by extension, the incentive structure for forest clearance.
As the Environmental Investigation Agency has stated: “This massive multibillion-dollar industry is built up around this product that they say is irrelevant to cattle ranching. This just completely defies some basic logic.”
4. Excluding Leather Creates an Absurd and Dangerous Policy Incoherence
If this proposal proceeds, beef from a cow raised on illegally deforested Amazon land would be prohibited from entering the EU market, while the hide from that very same animal could be sold freely and without due diligence. This is not simplification. It is a loophole that fundamentally undermines the integrity and credibility of the entire regulation.
It also sets a dangerous precedent. If one powerful industry can lobby its way out of the EUDR, what stops cocoa butter, palm kernel oil, or soymeal producers from seeking identical carve-outs? The regulation’s strength lies in its comprehensive, evidence-based approach. Removing leather on the basis of lobbying rather than science erodes the foundation on which the EUDR was built.
5. Traceability Is Feasible — and Already Happening
Claims that tracing cowhides is impractical do not withstand scrutiny. EU member states already have cattle traceability systems in place, as do major non-EU suppliers including New Zealand, Australia, Uruguay, and the United Kingdom. Brazil is developing a national individual animal traceability system, and the state of Santa Catarina has operated one for nearly a decade.
If the most complex step tracking cattle movements prior to slaughter is already being addressed, then tracing leather through subsequent processing stages is a comparatively straightforward administrative task. The challenge of traceability is no greater for the leather sector than for other covered commodities.
6. The Carbon Arithmetic Demands Action, Not Retreat
At Net Zero Heroes, we help individuals understand that their choices; what they buy, how they travel, what they invest in have a measurable impact on global emissions. We cannot credibly ask individuals to reduce their carbon footprints while the EU simultaneously relaxes regulations that protect the world’s most critical carbon sinks.
The numbers are stark:
| Metric | Figure | Source |
| Annual forest carbon sequestration | 3.6 Gt CO₂ | FAO, 2025 |
| Annual deforestation emissions | 2.8 Gt CO₂ | FAO, 2025 |
| Share of commodity deforestation from cattle | 42% | Nature Food, 2026 |
| Share of carbon emissions from cattle deforestation | 52% | Nature Food, 2026 |
| Amazon deforestation from cattle ranching | 80% | WWF |
| Global forest loss 2015–2025 | 40+ million ha | UN, 2026 |
Every hectare of forest lost to cattle pasture is carbon released into the atmosphere that we may never recover. Every regulation weakened is a signal that economic convenience outweighs planetary survival.
Our Position
Net Zero Heroes strongly opposes the exclusion of leather from Annex I of the EUDR. We call on the European Commission to:
- Maintain leather (HS codes 4101, 4104, 4107) within the full scope of the EUDR, in line with the scientific evidence on cattle-driven deforestation and carbon emissions.
- Resist industry lobbying that prioritises short-term commercial interests over the long-term health of our forests and climate.
- Uphold the EU’s global leadership on climate action — the world is watching, and exemptions driven by politics rather than evidence will damage the EU’s credibility at a critical moment for international climate cooperation.
- Recognise that forests are non-negotiable infrastructure for achieving net zero — they are not an obstacle to trade, but the foundation of a liveable planet.
The climate crisis does not offer us the luxury of loopholes. We urge the Commission to hold the line.
Yours sincerely,
Bryony Doughty
CEO
Net Zero Heroes