Reviewed 31 August 2026 · next review 30 November 2026
EUDR commodities and Annex I product scope
Scope is decided by the current Annex I list, matched against the customs classification of the concrete product. The annex has changed and another Commission-adopted amendment is still pending, so do not rely on an old product list.
Last updated · Written and reviewed by Jonatan Tensetti · Tensetti Tools
The commodity list is still seven items: cattle, cocoa, coffee, oil palm, rubber, soya and wood. The product list underneath them is more detailed and can change. A sensible scope review therefore starts with the exact CN/HS codes used in your customs and product data, checks them against the current Annex I, and records which legal version was used.
Status on 31 August 2026. Regulation (EU) 2025/2650 is already in force and removed the former ex Chapter 49 printed-products entry from Annex I on 26 December 2025. The Commission then adopted delegated regulation C(2026)4920 on 13 July 2026. That act proposes further changes — including removing cattle hides, skins and leather, narrowing several rubber entries and adding products such as soluble coffee and some palm derivatives. EUR-Lex still shows it without an Official Journal regulation number as of this review. The table below therefore describes the currently consolidated Annex at a high level and flags the pending July changes separately rather than pretending they are already in force.
| Commodity | Current areas to check | 2026 scope note |
|---|---|---|
| Cattle | Live cattle, meat/offal and the currently consolidated hide/leather entries under Chapter 41. | C(2026)4920 proposes removing ex 4101, ex 4104 and ex 4107 and adding frozen cattle tongues. Check whether that delegated act has entered into force before relying on either change. |
| Cocoa | Chapter 18 products including beans and several cocoa/chocolate preparations. | Use the exact Annex I subheading rather than assuming every food containing cocoa has the same treatment. |
| Coffee | Current coffee entries under Chapter 09. | The July 2026 delegated act proposes adding soluble coffee. Treat that addition as pending until the act enters into force. |
| Oil palm | Relevant oil-palm products and derivatives across the Annex I entries. | The July act proposes additional palm-derived products plus targeted exclusions, including medicinal-product uses for specified entries. Verify the live annex before classifying a derivative. |
| Rubber | Natural rubber and a range of rubber preparations and articles, including new pneumatic tyres in the currently consolidated annex. | The July act proposes removing or narrowing several entries, including treatment of retreaded tyres and certain vulcanised-rubber products and belts. Do not use an old blanket 'Chapter 40' rule. |
| Soya | Soya beans, flour/meal, oil and oilcake entries currently listed in Annex I. | The July act proposes a targeted change for soybeans for sowing; check the final published text before using that distinction. |
| Wood | Chapter 44 wood products, pulp and paper in Chapters 47–48 and specified wooden products in Chapter 94. | Printed books/newspapers and other ex Chapter 49 paper products are no longer in Annex I: Regulation (EU) 2025/2650 deleted that line from 26 December 2025. |
The table is deliberately not a substitute for Annex I. Entries prefixed with ex cover only the products described by the legal wording under that code, and amendments can add technical exclusions or narrower subheadings. Record the exact code and legal text you relied on.
Five scope traps worth checking
- Packaging. Packing material presented with another product to support, protect or carry it is not automatically an EUDR product in its own right. The current annex already contains a packaging carve-out, and C(2026)4920 proposes further clarification for packing materials and containers. Classify what is actually being placed on the market.
- Printed material. Do not use pre-2026 lists that still include Chapter 49. Regulation (EU) 2025/2650 deleted the printed-products line from Annex I.
- Leather. Hides and specified cattle leather remain in the currently consolidated Annex I at this review date, but the Commission's July 2026 delegated act proposes deleting those entries. This is exactly the kind of scope decision that needs a dated source reference.
- Rubber tyres and articles. "Tyres are in scope" is too coarse. The current annex distinguishes rubber entries, and the pending delegated act would narrow some of them further. Work from the exact subheading and description.
- Products added by a future amendment. C(2026)4920 defers application of newly added product categories to 30 December 2027. That future date matters only if the delegated regulation survives scrutiny, is published and enters into force.
A defensible scope workflow
- Export the distinct CN/HS codes actually used by the relevant legal entity.
- Match each code and product description against the current Annex I, including every "ex" qualifier.
- Record the legal version, review date and named person responsible for the classification.
- Track adopted-but-pending amendments separately so a proposed change is never mixed into today's legal scope.
- Only after scope is resolved, map the transaction role and start the relevant data/evidence workflow.
This order avoids two expensive mistakes: collecting plot data for a product that is not in the current annex, and treating a Commission proposal or adopted-but-not-yet-effective delegated act as if it were already the law in force.
Primary sources
Reviewed 31 August 2026. Always confirm against the current official text.
- Regulation on deforestation-free products — implementation overview — European Commission. Current application dates, implementation overview and links to Commission resources.
- Commission update on product scope and implementation tools — European Commission. 13 July 2026 Commission update on proposed product-scope changes, the Information System, simplified declarations and the revised operating model. Product-scope changes described there must be checked against the delegated act's current legal status before being treated as effective.
- Regulation (EU) 2025/2650 — EUR-Lex. In-force December 2025 amendment covering revised operator/trader obligations, application-date provisions, the micro/small primary-operator route and removal of the former Annex I Chapter 49 printed-products entry.
- EUDR Information System resources — European Commission. Official implementation page linking the current Information System and related technical resources.
- Consolidated Regulation (EU) 2023/1115 — EUR-Lex. Current consolidated text at the 31 August 2026 review date. Use it for the in-force Annex I baseline and verify whether EUR-Lex has published a later consolidation before making a material decision.
- FAQ on EUDR implementation — European Commission. Commission implementation FAQ page refreshed in August 2026 and available in EU languages.
- Commission Delegated Regulation C(2026)4920 — Annex I amendment — EUR-Lex / European Commission. Adopted by the Commission on 13 July 2026. At the 31 August 2026 review date EUR-Lex still displayed an unnumbered delegated regulation rather than a published Official Journal act. Track this source for status changes before applying its proposed Annex I additions, removals and technical exclusions.
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This is a self-service readiness and documentation tool based on the information you provide and the sources listed for assessment version 1.0.0. It is not legal advice, an audit, certification, conformity assessment or an official filing. It does not submit a due diligence statement, validate Annex I classification or geolocation, certify deforestation-free status or determine negligible risk. Verify material decisions with the relevant authority or a qualified adviser.