The material has to pass chemical limits, and the hangtag now has to pass consumer-protection law. As of 27 September 2026, “eco-friendly vegan leather” is a claim you have to prove in the EU.
Short answer: Faux leather sold into the EU and US in 2026 has two separate compliance jobs. The material must meet chemical limits: REACH restricts DMF (the classic PU solvent) at 0.3% and four phthalates at 0.1% of plasticised material, and California’s Prop 65 lists DMF. The marketing must survive the EU’s new rules on environmental claims, which apply from 27 September 2026 and ban generic claims such as “eco-friendly” unless you can show recognised excellent environmental performance. In Italy, calling a non-animal material “leather” in any form is already prohibited.
Key Takeaways
- REACH Annex XVII entry 76 restricts DMF at ≥0.3%. The derogation for polyurethane coating on textiles ran until 12 December 2024, so it now applies to PU leather production for the EU market.
- REACH entry 51 has restricted DEHP, DBP, BBP and DIBP at ≥0.1% of plasticised material in articles since July 2020. This matters most for PVC.
- From 27 September 2026, Directive (EU) 2024/825 bans generic environmental claims like “eco” or “green” without proof of recognised excellent environmental performance, and bans sustainability labels not based on a certification scheme or public authority.
- “Vegan” describes animal content, not environmental impact. Keep the two kinds of claim separate and evidence both.
DMF: The Solvent Behind Most PU Leather
N,N-dimethylformamide (DMF) has long been the standard solvent for making solvent-based PU coatings and the wet-coagulated layer in many PU and microfiber leathers. It’s now restricted on both sides of the Atlantic.
- EU: Commission Regulation (EU) 2021/2030 added DMF to REACH Annex XVII as entry 76. It restricts placing DMF on the market, and its use, on its own or in mixtures at 0.3% or more from 12 December 2023 unless worker exposure limits are met. The derogation for polyurethane coating of textiles and paper, and for PU membranes, ran until 12 December 2024, according to TÜV Rheinland’s summary.
- California: DMF has been on the Proposition 65 list as a carcinogen since 27 October 2017. Products that can expose consumers to it need a warning unless exposure is below the safe-harbour level.
What to ask your supplier: whether the PU is made by a solvent-based (DMF), waterborne or solvent-free process; a residual DMF test report on the finished material; and, for EU-bound goods, confirmation that the production line complies with entry 76 conditions. Waterborne or solvent-free PU removes most of this risk at the source.
Phthalates and Other Restricted Substances
PVC leather needs plasticizers to be soft, and older formulations used ortho-phthalates. Under REACH entry 51, as amended by Regulation (EU) 2018/2005, articles containing DEHP, DBP, BBP or DIBP at 0.1% or more (individually or combined) by weight of the plasticised material can’t be placed on the EU market. This has applied since July 2020, as ChemSafetyPro’s summary explains. The definition of plasticised material explicitly includes PVC, polyurethanes, coatings and finishes, so PU leather isn’t automatically exempt.
Beyond phthalates, a typical faux leather RSL test package covers:
- Short-chain chlorinated paraffins, organotins and heavy metals (lead, cadmium) in pigments and stabilisers.
- PFAS, if a stain- or water-repellent finish is applied. Check your markets’ current PFAS rules, which are tightening in several EU countries and US states.
- Azo dyes releasing restricted amines, and allergenic disperse dyes on textile backings.
- For children’s products, market-specific rules such as CPSIA in the US.
The EU Green-Claims Rules Now in Force (27 September 2026)
Directive (EU) 2024/825, known as the “Empowering Consumers for the Green Transition” directive or EmpCo, amends the EU’s Unfair Commercial Practices Directive. Member states had to transpose it by 27 March 2026, and it applies from 27 September 2026. For faux leather marketing, the practical effects are:
- Generic environmental claims are banned unless you can demonstrate recognised excellent environmental performance relevant to the claim (for example, via the EU Ecolabel). That covers “eco-friendly”, “green”, “nature-friendly” and “eco-leather”.
- Sustainability labels must be based on a certification scheme or set by public authorities. Self-created “planet-positive” badges on hangtags are out.
- Whole-product claims based on one aspect are banned. “Sustainable bag” doesn’t hold if only the lining is recycled.
- Carbon-neutral claims based on offsetting are banned where the claim is about the product’s own impact.
The separate, more detailed EU Green Claims Directive proposal is in limbo: the Commission announced in June 2025 that it intended to withdraw it, and its formal status remains unresolved (Latham & Watkins). That doesn’t soften EmpCo, which is already law.
In the US, the FTC’s Green Guides (16 CFR Part 260) take a similar line: unqualified general environmental-benefit claims are hard to substantiate and should be avoided or qualified with specific, provable benefits.
Can You Call It “Leather” at All?
Depending on the market, possibly not. Italy’s Legislative Decree 68/2020, in force since 24 October 2020, reserves “pelle” and “cuoio” for materials derived from animal hides. The ban extends to prefixed and suffixed forms such as “eco-pelle” and “vegan leather” for non-animal materials. Leather industry bodies are pushing for similar protection at EU level, so treat “leather” in product names for non-animal materials as a growing risk in EU channels.
Footwear adds another rule. Under EU Directive 94/11/EC, the materials of the upper, lining and sock, and the outer sole, must be labelled (by text or pictogram) when they make up at least 80% of that component. The “leather” and “coated leather” categories are for real hide, so PU and PVC uppers fall under “other materials”.
Buyer’s Compliance Checklist for 2026
| Item | Ask for | Applies to |
|---|---|---|
| DMF | Process declaration + residual DMF test | PU, microfiber (EU, California) |
| Phthalates | REACH entry 51 test report; plasticizer declaration | PVC (and plasticised PU coatings) |
| Full RSL | Test to brand RSL or AFIRM RSL | All faux leather |
| Prop 65 | Test data or warning decision for listed chemicals | Products sold in California |
| Environmental claims | Evidence file for each claim; certification for any label | All EU marketing from 27 Sep 2026 |
| Bio-based / recycled content | ASTM D6866 (bio-based) or chain-of-custody certificate (recycled) | Any product with content claims |
| “Leather” naming | Legal review of product names per market | Italy; watch other EU markets |
| Footwear labelling | Component material labels per 94/11/EC | Footwear sold in the EU |
Put compliance on the spec sheet, not in an email
Write the regulations, test reports and report age into the purchasing spec so every lot is covered, not just the first sample.
Get the Spec Sheet TemplateFrequently Asked Questions
Is PU leather DMF-free?
Not by default. Conventional solvent-based PU and many microfiber leathers use DMF in production. “DMF-free” normally refers to waterborne or solvent-free PU processes. Ask for the process declaration and a residual DMF test report on your specific article.
Can I still call faux leather “eco-friendly” in the EU?
From 27 September 2026, only if you can demonstrate recognised excellent environmental performance relevant to the claim, as required by Directive (EU) 2024/825. In practice, most brands are replacing generic claims with specific, documented ones (for example, a tested bio-based percentage or a certified recycled backing).
Is “vegan leather” a legal term?
No harmonised EU definition exists. “Vegan” describes the absence of animal content, while “leather” is protected in some countries: Italy prohibits using “pelle” for non-animal materials, including “vegan leather” forms. Use neutral names like “PU material” or “leather alternative” where naming rules apply.
Does PU leather contain phthalates?
PU usually needs less added plasticizer than PVC, but plasticised coatings and finishes fall within REACH’s definition of plasticised material. Test rather than assume, especially for coloured or printed finishes.
Bottom Line
- Material compliance: DMF, phthalates and a full RSL, proven by reports on your article.
- Claim compliance: no generic “eco” wording in the EU from 27 September 2026, only specific, evidenced claims.
- Naming: check whether “leather” can appear in the product name in each market.
Choosing the material itself? Start with PU vs PVC vs microfiber leather, then set performance levels with the testing standards guide.