Which EU anti-greenwashing rules apply to leather products in 2026?

The main EU rule is Directive (EU) 2024/825, which has applied since 27 September 2026 and bans generic environmental claims, uncertified sustainability labels and offset-based climate claims. The separate Green Claims Directive is blocked and not in force, and leather was removed from the EU Deforestation Regulation in September 2026.

Last updated: October 2026

EU rules affecting leather environmental claims (October 2026)
Rule	Status	What it means for leather brands
Directive (EU) 2024/825 (Empowering Consumers for the Green Transition)	Applies since 27 September 2026	Bans generic environmental claims, uncertified sustainability labels, whole-product claims based on one aspect, and offset-based climate claims in consumer marketing
Unfair Commercial Practices Directive 2005/29/EC	In force	Any misleading environmental claim can be treated as an unfair commercial practice
Green Claims Directive (proposal)	Blocked since June 2025 — not law	Would add pre-approval of claims; no obligations today
EU Deforestation Regulation (EUDR)	Leather removed by Delegated Regulation (EU) 2026/2102 (17 September 2026)	No EUDR due diligence for cattle hides, skins and leather; scope to be reviewed in 2030
Ecodesign for Sustainable Products Regulation (ESPR)	In force; no leather or footwear passport adopted	Ban on destroying unsold footwear for large companies since 19 July 2026; Digital Product Passport requirements for leather not yet set
CSRD, as amended by Omnibus I Directive (EU) 2026/470	Narrowed scope	Mandatory sustainability reporting limited to companies above 1,000 employees and €450 million turnover
Forced Labour Regulation (EU) 2024/3015	Applies from 14 December 2027	Products made with forced labour, including components, cannot be sold in or exported from the EU

What changed in 2026

The biggest change is that greenwashing rules now apply directly to consumer marketing. Under Directive (EU) 2024/825, words such as “eco-friendly”, “green” or “environmentally friendly” can no longer be used on their own unless the trader can show recognised excellent environmental performance. Sustainability labels must be based on a certification scheme or set by a public authority.

At the same time, leather left the scope of the EU Deforestation Regulation. Delegated Regulation (EU) 2026/2102 removed cattle hides, skins and leather from the EUDR product list from 18 September 2026. Deforestation-free sourcing remains a common retailer requirement and a credible voluntary claim, but it is no longer an EUDR legal obligation for leather.

Outside the EU

In the United Kingdom, the Digital Markets, Competition and Consumers Act 2024 lets the Competition and Markets Authority fine businesses up to 10% of global turnover for misleading consumer claims, including environmental claims, alongside its Green Claims Code.

ISA Next-Gen Materials provides the evidence brands use to keep leather claims specific: LWG Gold ratings at all four leather manufacturing facilities, per-article LITE Index data, chemical test documentation, and farm-level traceability through the Greener Pastures™ program.

This page summarises regulations for general guidance as of October 2026 and is not legal advice. Rules and national transposition continue to change.

Frequently asked questions

Is the EU Green Claims Directive in force?

No. The Green Claims Directive proposal has been blocked since June 2025, when the final negotiating round was cancelled. It is not law. The rules that apply now come from Directive (EU) 2024/825, which has applied since 27 September 2026.

What does Directive (EU) 2024/825 ban?

Generic environmental claims without recognised excellent environmental performance, sustainability labels not based on a certification scheme or public authority, environmental claims about a whole product when they concern only one aspect, and claims of neutral, reduced or positive climate impact based on carbon offsetting.

Has every EU country transposed the greenwashing rules?

Not yet. In May 2026 the European Commission opened infringement procedures against 20 Member States for late transposition. Brands selling across the EU should check the national law in each market.

Is leather still covered by the EU Deforestation Regulation?

No. Delegated Regulation (EU) 2026/2102, published on 17 September 2026, removed cattle hides, skins and leather from the EUDR product list. Beef and live cattle remain in scope, and the Commission will review leather again in 2030.

Does leather need a Digital Product Passport?

Not yet. No Digital Product Passport requirement has been adopted for leather or footwear under the Ecodesign for Sustainable Products Regulation. Textiles are the first priority group, with a delegated act expected around 2027.

References

Next step

Request compliance documentation for your leather program