Dejan Jasnic · Co-founder & Compliance Lead, Trusty · 20+ years anti-fraud & compliance · ACFE Swiss Chapter Board
Finished products are the part of EUDR most compliance teams miss. The regulation doesn’t just apply to raw commodities coming off a plantation or out of a forest, it follows those commodities all the way through the supply chain, into the finished, branded, shelf-ready products that come out the other end. If your chocolate bar, your car tires, or your BBQ charcoal falls under a customs code listed in Annex I, EUDR’s due diligence requirements apply to it.
This matters more than it might seem. Companies that assume EUDR is “not really about us” because they don’t import raw timber or palm oil are often the same companies quietly building, packaging, or selling something that is already in scope. Below, we walk through nine everyday products that fall under EUDR, some already regulated today, others joining the list under the European Commission’s July 2026 delegated act, along with the mechanics of why, and what it means for your business.
What is the EUDR, briefly
The EU Deforestation Regulation (Regulation (EU) 2023/1115) requires that products placed on or exported from the EU market be deforestation-free, legally produced, and covered by a due diligence statement. It applies to seven core commodities:
- Cattle
- Cocoa
- Coffee
- Oil palm (palm oil)
- Rubber
- Soy
- Wood
Crucially, the regulation doesn’t stop at the raw commodity. Annex I of the regulation lists specific derived products, identified by their customs (HS) code, that also fall in scope. That’s the mechanism that pulls chocolate, tires, paper, and toilet soap into the conversation, even though none of them look anything like a log or a cocoa pod.
Why EUDR's scope catches companies off guard
Two things make EUDR’s scope harder to pin down than most regulations:
Classification determines coverage, not ingredient presence alone. A product containing palm oil is only in scope if its specific customs code appears in Annex I. That’s why, for example, palm oil-based biodiesel sits outside Annex I, even though palm oil clearly went into making it, while toilet soap containing palm oil (HS 3401 11 00) joins scope from 30 December 2027. The chemistry is similar; the classification is what matters.
The product list isn’t static. The Commission adopted Delegated Regulation (EU) 2026/2102 in July 2026; it was published on 17 September 2026 and entered into force on 18 September 2026. It both added and removed items from Annex I. Removed: cattle hides, skins and leather (HS 4101, 4104, 4107), retreaded and used tyres, soya beans for sowing, other articles of vulcanised rubber (HS 4016), conveyor and transmission belts (HS 4010), and aircraft and motor vehicle seats. Tyre treads remain in scope. Added from 30 December 2027: soluble coffee, further palm oil derivatives, toilet soap containing palm oil (HS 3401 11 00) and frozen cattle tongues. Printed products (Chapter 49) had already been removed by Regulation (EU) 2025/2650. The Commission can amend Annex I again by delegated act, so businesses tracking Annex I should check the current consolidated text rather than treat any single list as permanent.
Only a few general exclusions apply regardless of ingredient content: waste within the meaning of Directive 2008/98/EC, samples of negligible value and products used up in testing. Exclusions for used or second-hand goods, packaging and palm products for medicinal use apply only to the Annex I entries that state them.
How this plays out in practice
Picture a mid-sized consumer goods company that sells personal care products across the EU. Its compliance team has, reasonably, spent the past year focused on the parts of its business that obviously touch EUDR’s core commodities, say, a supplier relationship involving palm oil for a shampoo line. That’s the visible risk, so that’s where the attention goes.
Meanwhile, the same company’s product catalog includes disposable wipes packaged in wood-pulp-based nonwoven material, gift sets with printed cardboard inserts, and a private-label instant coffee sachet bundled into a wellness box. None of those products were on anyone’s EUDR radar, because none of them read as “commodity products” on a shelf. But under Annex I’s classification logic, several of them are already in scope today, and at least one is scheduled to join scope in December 2027.
This is the pattern that shows up again and again: the compliance risk that gets managed is the one that was already visible. The risk that causes problems later is the one buried a few SKUs down the catalog, in a product nobody thought to check because it didn’t look like timber, cocoa, or palm oil at first glance.
With that context, here are nine products that illustrate just how far EUDR’s reach actually extends.
in two minutes
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9 everyday products covered by EUDR
Already in scope
Your chocolate bar. Cocoa is one of EUDR’s seven core commodities, and the regulation follows it from bean to bar. Chocolate placed on the EU market must be covered by the operator’s due diligence statement. One DDS can cover several shipments of the declared quantity placed within one year of submission, provided due diligence covers the whole quantity. Cocoa butter and cocoa powder are covered too.
Your car tires. New natural rubber tires and rubber gloves fall under EUDR’s rubber category; hoses (HS 4009) are not listed in Annex I. Synthetic rubber does not, the regulation only follows commodities that trace back to a forest, and synthetic rubber’s supply chain doesn’t touch one.
Your toilet paper. Wood pulp sits squarely inside EUDR’s wood category, and that reach extends to paper towels, napkins, and paper cups as well. If a product started life as pulp, someone in the supply chain has to be able to trace it back to the forest it came from.
Your kitchen table. Wooden furniture (HS 9403) sits in EUDR’s wood category. A table or a bookshelf made of wood needs the same traceable timber behind it as the planks it was cut from.
Diapers and wipes. These sit in the same wood-pulp family as toilet paper. Being disposable doesn’t exempt a product from due diligence requirements.
Your BBQ charcoal. Wood charcoal is part of EUDR’s wood category, alongside furniture and paper products more broadly. Printed books, by contrast, left scope with Regulation (EU) 2025/2650.
Joining scope from December 2027
Your soap. Toilet soap containing palm oil (HS 3401 11 00) is added to Annex I and in scope from 30 December 2027. Lipstick and other finished cosmetics are not listed. If your product line includes palm-based soap, this is worth flagging now, well ahead of the application date.
Your instant coffee. Coffee has always been an EUDR commodity, but the regulated product list is expanding beyond whole beans. Soluble coffee, along with coffee extracts, essences, and concentrates, is joining the regulated list.
Frozen cattle tongue. Genuinely one of the more unexpected additions to Annex I, and a useful reminder that EUDR’s reach goes deeper into the supply chain, and into more specific product forms, than most companies initially expect. If a regulator can trace a due diligence requirement down to a single cut of meat by customs code, it’s a fair bet your own product catalog has something similarly specific hiding in it.
A pattern worth noticing across all nine: none of these are edge cases dreamed up to make a point. They’re ordinary retail products that happen to sit on the wrong (or right, depending on your perspective) side of a customs code boundary. That’s precisely why a commodity-level mental model, “we don’t deal in timber or palm oil”, isn’t a reliable way to rule your business out of scope.
Which EUDR deadlines do you need to know?
- 30 December 2026, Application date for operators, and for downstream operators and traders of any size.
- 30 June 2027, Application date 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, Application date for the newly added products (soluble coffee, further palm oil derivatives, toilet soap containing palm oil, frozen cattle tongues).
30 December 2026
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What is the EUDR, briefly
The practical takeaway isn’t “watch out for cattle tongues.” It’s that EUDR scope is determined by precise product classification, not by intuition about which products “feel” like commodity products. A business that has never thought of itself as a timber company, a palm oil company, or a cattle company can still find itself squarely inside EUDR’s due diligence obligations because of a paper component, a rubber component, or a palm oil derivative buried a few steps back in its supply chain.
That’s exactly the kind of gap that’s worth closing before an enforcement deadline, not after. Waiting until the December 2026 or June 2027 dates arrive leaves little room to fix a supplier relationship, request missing documentation, or restructure sourcing if a gap turns up. The businesses that handle EUDR smoothly tend to be the ones that mapped their full product catalog against Annex I early, rather than the ones that started from an assumption about which commodities “count” for them.
If you’re not sure whether your products, or your upstream suppliers’ products, fall under EUDR’s current or upcoming scope, it’s worth checking directly rather than guessing from a commodity list. Trusty’s FREE EUDR Obligations Checker walks through your role in the supply chain and the commodities you touch, and tells you what obligations apply in a couple of minutes.
Frequently asked questions
EUDR covers seven core commodities, cattle, cocoa, coffee, palm oil, rubber, soy, and wood, plus a specific list of derived products identified by customs code in Annex I of the regulation. This includes items like chocolate, furniture, paper products and tires and, from 30 December 2027, certain palm oil derivatives such as toilet soap.
Not automatically. Coverage depends on the product's customs (HS) classification matching an entry in Annex I, not simply on whether a regulated commodity was used somewhere in production. Two products with similar ingredients can fall on opposite sides of the scope line depending on how they're classified.
Operators must comply from 30 December 2026. Micro and small operators established as such by 31 December 2024, and natural persons, have until 30 June 2027, except for timber products listed in the Annex to the EU Timber Regulation. Downstream operators and traders of any size must comply from 30 December 2026. Products newly added to Annex I by Delegated Regulation (EU) 2026/2102 become subject to EUDR on 30 December 2027.
Delegated Regulation (EU) 2026/2102, in force since 18 September 2026, removed cattle hides, skins and leather (HS 4101, 4104, 4107), retreaded and used tyres, soya beans for sowing, other articles of vulcanised rubber (HS 4016), conveyor and transmission belts (HS 4010), and aircraft and motor vehicle seats from Annex I. Printed products (Chapter 49) had already been removed by Regulation (EU) 2025/2650.
The amended Annex I has been in force since 18 September 2026 (Delegated Regulation (EU) 2026/2102). It is not fixed forever: the Commission can amend Annex I again by delegated act, so businesses should check the current consolidated text rather than treat any list as permanent.
Start with the product's customs (HS) classification and check it against the current Annex I list, since coverage is determined by classification rather than by ingredient presence alone. Because the list has changed twice in recent years and differs by operator size and role in the supply chain, most businesses find it faster to work through a structured questionnaire, like Trusty's EUDR Obligations Checker, than to interpret Annex I line by line.
The bottom line
EUDR’s scope was never meant to stay confined to raw commodities, it was designed to follow deforestation risk all the way through the supply chain, into the products people actually buy. That design is exactly what makes it easy to underestimate. If your business touches cocoa, coffee, palm oil, rubber, wood, soy, or cattle at any point, even several steps removed from the raw material, it’s worth a few minutes to confirm where you stand with the EUDR obligations checker, and EUDR Passport takes it from there.
Sources: Regulation (EU) 2023/1115, Annex I, as consolidated on 18 September 2026; Delegated Regulation (EU) 2026/2102; Trusty, EUDR Product Scope Update 2026.
Related reading: whether you are an operator or a trader, what changed from the EU Timber Regulation, and the small business deadline.
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30 DECEMBER 2026
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