Dejan Jasnic · Co-founder & Compliance Lead, Trusty · 20+ years anti-fraud & compliance · ACFE Swiss Chapter Board
With less than six months to go before enforcement begins, the European Commission has given businesses a clearer picture of what the EUDR product scope will actually require of them. On 13 July 2026, the Commission adopted two measures: a Delegated Act that narrows the list of covered products, and an Implementing Act that finalizes how the digital reporting system will work. Together they close out the simplification package the Commission first presented in May 2026.
If your compliance team has been waiting to finalize due diligence workflows until the rules stopped moving, this is the signal you’ve been waiting for.
Looking for EUDR software? EUDR Passport collects your supplier data, runs the risk assessment and files unlimited due diligence statements, from €90 per product profile per year.
What is the EUDR and who does it apply to?
The EU Deforestation Regulation requires that products placed on the EU market, or exported from it, are deforestation-free and produced in line with the laws of their country of production. It covers seven commodities: cattle, cocoa, coffee, palm oil, rubber, soy and wood, along with a range of products derived from them. Operators must submit due diligence statements demonstrating compliance (micro and small primary operators a simplified declaration) before these products are placed on the EU market or exported; downstream operators and traders do not submit them.
What changed in the July 2026 EUDR update?
The product list got shorter, and more specific
The Commission removed several product categories from scope entirely: cattle hides, skins and leather (HS 4101, 4104, 4107), retreaded and used tyres, soya beans intended for sowing, other articles of vulcanised rubber (HS 4016), conveyor and transmission belts, and aircraft and motor vehicle seats. At the same time, it added a handful of new items: soluble coffee, certain palm oil derivatives, and frozen cattle tongues.
It’s worth being precise about what this update does and doesn’t touch. The seven underlying commodities the Regulation covers, cattle, cocoa, coffee, palm oil, rubber, soy and wood, haven’t changed. This is a refinement of which derived products made from those commodities fall under the rule, not a change to the Regulation’s core scope.
Companies get a runway here too: products newly added to EUDR product scope won’t become subject to the Regulation until 30 December 2027, a year after the general application date.
New exemptions narrow the edge cases
The Delegated Act also confirms the general exclusions: waste within the meaning of Directive 2008/98/EC, samples of negligible value and products used up in testing sit outside the Regulation. Exclusions for used or second-hand goods, packaging and palm products for medicinal use apply only to the Annex I entries that state them. For companies that have been asking “does this technically apply to us,” these carve-outs should resolve a fair number of edge cases.
The reporting system now has finalized technical rules
The Implementing Act sets out how the EUDR Information System, the platform operators use to submit due diligence statements, will actually function. This includes simplified declarations for micro and small primary operators and updated API specifications for companies that want to automate submissions. The system itself reopened at the end of June after technical updates, with the Commission promising additional functionality later this summer and training sessions starting at the end of July.
Change | Products | Applies from |
|---|---|---|
Removed from Annex I | Cattle hides, skins and leather; retreaded and used tyres; soya beans for sowing; other articles of vulcanised rubber (HS 4016); conveyor and transmission belts; aircraft and motor vehicle seats | Delegated Act of 13 July 2026, in force since 18 September 2026 |
Added to Annex I | Soluble coffee; certain palm oil derivatives; frozen cattle tongues | 30 December 2027 |
Unchanged | The seven commodities: cattle, cocoa, coffee, palm oil, rubber, soy and wood | 30 December 2026 (operators, downstream operators and traders); 30 June 2027 (micro and small operators established by 31 December 2024, and natural persons, except EUTR Annex timber) |
When does the EUDR take effect?
The enforcement timeline hasn’t moved:
- 30 December 2026: application begins for operators, and for downstream operators and traders of any size
- 30 June 2027: application begins for micro and small operators established as such by 31 December 2024, and for natural persons, except for timber products listed in the Annex to the EU Timber Regulation
- 30 December 2027: newly added products come into scope
Why this matters for compliance and third-party risk teams
For compliance, risk, and third-party oversight teams, this is a tight window. If your organization sources or exports any of the seven covered commodities, directly or through derived products, the practical task now is auditing your supply chain against the updated Annex I, not the version that’s been circulating since 2023, and confirming whether your due diligence statement workflow is compatible with the API specifications the Information System now requires.
The guidance document that accompanies the Regulation has also been formally adopted in all EU languages for the first time, alongside an updated FAQ. That’s worth a look if your legal or compliance team has been relying on informal translations.
Is the EUDR product scope final?
Update, 4 November 2026: Delegated Regulation (EU) 2026/2102 was published on 17 September 2026 and entered into force on 18 September 2026, so the amended Annex I now applies. The Commission can still amend Annex I by delegated act in future.
Key takeaway
Start reconciling supplier and product lists against the updated Annex I now. Treat the enforcement dates as fixed and the amended Annex I, in force since 18 September 2026, as the product list that applies.
Sources: European Commission, Directorate-General for Environment, “Commission updates product scope and tools to support EUDR,” 13 July 2026.
Frequently asked questions
Cattle hides, skins and leather (HS 4101, 4104, 4107), retreaded and used tyres, soya beans intended for sowing, other articles of vulcanised rubber (HS 4016), conveyor and transmission belts, and aircraft and motor vehicle seats.
Soluble coffee, certain palm oil derivatives and frozen cattle tongues. Newly added products become subject to the Regulation on 30 December 2027, a year after the general application date.
No. Cattle, cocoa, coffee, palm oil, rubber, soy and wood remain the covered commodities, and application still starts on 30 December 2026 for operators and for downstream operators and traders of any size, and on 30 June 2027 for micro and small operators established as such by 31 December 2024 and natural persons, except for timber products listed in the Annex to the EU Timber Regulation.
Yes, for now. Delegated Regulation (EU) 2026/2102 entered into force on 18 September 2026, after publication on 17 September 2026. The Commission can amend Annex I again by delegated act.
30 DECEMBER 2026
FREE EUDR Obligations Checker: Answer a few simple questions and get an instant assessment of your EUDR obligations.