Dejan Jasnic · Co-founder & Compliance Lead, Trusty · 20+ years anti-fraud & compliance · ACFE Swiss Chapter Board
On 17 September 2026, the amendment to EUDR Annex I, the list of products covered by the EU Deforestation Regulation, was published in the Official Journal as Commission Delegated Regulation (EU) 2026/2102. It entered into force the next day. After months of scrutiny by the European Parliament and the Council, the list of products covered by the EUDR is now final and legally binding.
For many companies this settles the first compliance question: is my product in scope or not? Here is the answer.
2 minutes
Not sure if the new Annex I list covers your products? Answer a few questions and get an instant assessment of your EUDR obligations. No account needed.
Key dates
- 18 September 2026: the amended product list is in force. Removals and clarifications apply now.
- 30 December 2026: EUDR obligations apply to operators, and to downstream operators and traders of any size.
- 30 June 2027: obligations apply to 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. Timber products already covered by the EU Timber Regulation are the exception and follow the December 2026 date.
- 30 December 2027: the newly added products come into scope.
EUDR Annex I changes at a glance
Change | Products | Applies from |
|---|---|---|
Added | Soluble coffee, frozen cattle tongues, palm-based oleochemicals and soap | 30 December 2027 |
Removed | Cattle hides, skins and leather; rubber conveyor and transmission belts; other articles of vulcanised rubber (HS 4016) | 18 September 2026 |
Narrowed | Tyres (only tyre treads remain), soya beans for sowing, aircraft and motor vehicle seats, non-palm fatty acids, fatty alcohols and glycerol | 18 September 2026 |
Clarified out of scope | Buffalo and bison, babassu and non-Elaeis palm oils, synthetic rubber and other gums, bamboo and rattan, used goods, waste, packaging, recovered paper, marketing material, medicinal use | 18 September 2026 |
Unchanged | Every other Annex I product | 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 timber) |
Products added to the EUDR (from 30 December 2027)
Cattle
- Frozen cattle tongues. Fresh tongues were already covered.
Coffee
- Soluble coffee: extracts, essences and concentrates of coffee (2101 11 00).
Oil palm
The biggest expansion covers palm-based oleochemicals, used in paints, coatings, lubricants, cosmetics, detergents and food additives:
- Hydrogenated, inter-esterified or re-esterified palm and palm kernel oils
- Chemically modified palm oils and inedible fat mixtures made with palm
- Crude glycerol, glycerol waters and lyes from palm
- Palm-based fatty alcohols: octanol, lauryl, cetyl and stearyl alcohol, and other saturated monohydric alcohols
- Esters of acetic acid
- Oleic, linoleic, linolenic and undecenoic acids, their salts and esters
- Fatty amines, quaternary ammonium salts and acyclic amides
- Soap containing palm, both toilet soap bars and soap in other forms
- Other chemical products and preparations made with palm, not elsewhere specified
- Polyethers in primary forms made with palm
These products are covered only if they are made using oil palm. Several are exempt to the extent they are used to manufacture medicines for human or veterinary use.
December 2027 may sound far away, but it is not. Tracing an oleochemical back through chemical processors and refineries to the plantation plot is one of the hardest supply chains to map.
per product
Trading soluble coffee, palm-based soap or another newly added product? EUDR Passport collects plot data, assesses risk and files your due diligence statements in one place. Or book a walkthrough.
Products no longer subject to the EUDR
Removed completely (since 18 September 2026)
- Raw hides and skins of cattle
- Tanned or crust hides of cattle
- Cattle leather, further prepared
- Conveyor and transmission belts of vulcanised rubber
- Other articles of vulcanised rubber (HS 4016), such as gaskets, seals and mats
Narrowed
- Tyres: retreaded tyres, used tyres, solid and cushion tyres and tyre flaps are out. Only tyre treads remain. New tyres and inner tubes stay in scope.
- Soya: soya beans for sowing are out. All other soya beans remain.
- Seats: aircraft seats and motor vehicle seats are out. The entry now lists specific wooden seats only.
- Fatty acids, fatty alcohols and glycerol: covered only if made using oil palm. The same products made from other vegetable oils or animal fats are out.
Printed books, newspapers and other printed products were already removed in December 2025 by Regulation (EU) 2025/2650.
Clarified as out of scope: species and materials
- Buffalo, bison and other bovine animals outside the genus Bos
- Babassu oil and oils from palm species other than Elaeis
- Synthetic rubber, and balata, gutta-percha, guayule, chicle and similar gums not from Hevea brasiliensis
- Bamboo, rattan and other woody materials, and wood products made of them
Clarified as out of scope: goods in certain forms
These exclusions apply where the specific Annex I entry says so:
- Used and second-hand products: most wood products, wooden furniture and seats, pulp and paper, and several rubber products (sheets and plates, rubber apparel and gloves, hard rubber)
- Waste within the meaning of the EU Waste Framework Directive (Directive 2008/98/EC), for example waste palm oils, wood waste and paper waste
- Packaging carrying another product: single-use packing, and reusable packing such as pallets and casks once in use
- Recovered paper and pulp: waste and scrap, and products made from it
- Marketing and correspondence: letters, labels, brochures and other information material that accompany a product or are given away free
- Medicinal use: palm derivatives used to manufacture medicines
Excluded for all products
- Samples of negligible value, used only to obtain orders
- Goods sent for examination, analysis or testing that are used up or destroyed in the process
- Goods made entirely from end-of-life material that would otherwise be thrown away as waste
What this means for you
- If your only exposure was cattle leather, rubber belts or other articles of vulcanised rubber (HS 4016), you may now be out of scope. Check your full product list first: many companies carry more than one EUDR product.
- If you handle wood, paper or rubber, the exclusions for used goods, waste, packaging and marketing material can take part of your volume out of scope. They are specific to each customs code, so check product by product.
- If you trade soluble coffee, palm-based soap or oleochemicals, start collecting supplier data now for 30 December 2027.
- For everything else, nothing has moved: 30 December 2026 is only weeks away.
How EUDR Passport helps
EUDR Passport is built around the official Annex I list. You pick your product by name or customs code, and you see the conditions and exclusions that apply to that code. Your scope confirmation is recorded on the Product Profile, ready for any authority request.
- Building Product Profiles and collecting supplier data is free.
- You pay only for the risk assessment: from €90 per Product Profile per year. That includes unlimited DDS submissions and 12 months of monitoring.
- You can start online today, with no sales call and no implementation project.
Find out if EUDR applies to your business →
Sources: Regulation (EU) 2023/1115 (consolidated 18.9.2026) and Commission Delegated Regulation (EU) 2026/2102, OJ L, 17.9.2026. This article is for information only and does not constitute legal advice.
Related reading: Surprising Products in EUDR Scope: 9 Everyday Items You Didn’t Know Were Regulated and EUDR vs EU Timber Regulation (EUTR): What Changed?
Need software for EUDR due diligence? EUDR Passport is free to set up, free for your suppliers, and costs €90 per product profile per year with unlimited DDS.
30 DECEMBER 2026
FREE EUDR Obligations Checker: Answer a few simple questions and get an instant assessment of your EUDR obligations.