Your Cotton May Be Safe Under EUDR. Your Entire Bill of Materials May Not Be: A Component-Level Perspective for Apparel Supply Chains

The European Union Deforestation Regulation (EUDR) does not identify cotton as a regulated commodity. This has led many apparel manufacturers and exporters to assume that cotton garments fall outside the Regulation's scope. This commentary argues that such an interpretation may be incomplete from a product compliance perspective. A finished garment is not defined solely by its primary fibre but by the complete Bill of Materials (BOM), which may include components manufactured from materials regulated under EUDR. Depending on the product design, tariff classification, and the specific products listed in Annex I of the Regulation, natural rubber, wood or wood-derived materials, and paper or paperboard packaging may require additional assessment. The article also discusses the European Commission's 2026 proposal to remove leather and certain related products from the Regulation's scope, noting that the proposal has not yet been adopted and therefore should not be treated as current law. With the implementation deadlines of 30 December 2026 for large and medium-sized operators and traders, and 30 June 2027 for most micro and small enterprises, sourcing organisations have limited time to prepare robust documentation and supplier due diligence systems where applicable. Rather than viewing EUDR solely through the lens of the garment's primary fibre, this commentary proposes a practical component-level BOM review as an early risk-screening approach. Such an approach can help merchandising, sourcing, procurement, and compliance teams identify potential obligations before production reaches critical milestones, strengthen supply chain transparency, and support more informed buyer engagement.