FAQEUDREU

EU Deforestation Regulation Annex I product lookup

Check Annex I by matching the product you place, make available, or export to a listed relevant product and its linked commodity.

Use supplier records, due diligence references, and trade data as evidence, but do not treat an unsupported CN, HS, or customs-code list as the source of truth.

Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Questions
4

Structured answer sets in this page tree.

Primary sources
2

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

Under the EU Deforestation Regulation, Annex I lookup is the scope check that connects a real product to a listed relevant commodity or derived product. The lookup should answer two questions: is the product listed in Annex I, and if yes, which operator, downstream operator, or trader obligations are triggered for that movement.

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4 of 4 questions
Question 1

How should a team check whether a product is in EUDR Annex I?

Start with the product that is actually being placed on the EU market, made available on the EU market, or exported. Then compare that product to Annex I, which is the regulation's product-scope list for relevant commodities and derived products.

A useful lookup record should name the product or SKU, the supplier, the relevant commodity family, the Annex I product match or non-match, and the role affected by the transaction. If the item is in scope, Article 3 connects the product to the EUDR conditions: deforestation-free status, production in accordance with relevant legislation of the country of production, and a due diligence statement or simplified declaration where required.

  • Identify the traded product, not only a marketing category or internal material group.
  • Check whether the product falls under one of the covered commodity families named in the EUDR: cattle, cocoa, coffee, oil palm, rubber, soya, or wood, including derived products listed in Annex I.
  • Record whether the business is acting as an operator, downstream operator, or trader for that movement.
  • If the product is in scope, link the lookup to the due diligence statement, simplified declaration identifier, or downstream supplier information required for the role.
  • If the product is out of scope, preserve the reason for the non-match and the evidence used, because product composition, suppliers, and trade descriptions can change.
Citations
Consolidated Regulation (EU) 2023/1115

Supports the Annex I scope trigger, Article 3 conditions, role definitions, and the need to connect in-scope products to due diligence or simplified declaration evidence.

Question 3

What supplier and trade evidence should support an Annex I lookup?

The lookup should be backed by records that let a reviewer connect the legal scope conclusion to the commercial movement. For an in-scope product, the file should show the supplier, the product identity, the commodity link, the transaction or shipment context, and the EUDR reference information available for the role.

Operators need due diligence evidence before placing relevant products on the market or exporting them. Downstream operators and traders need supply chain information, including supplier details and, when the supplier is an operator, due diligence statement reference numbers or declaration identifiers. Those records make the Annex I lookup usable after the original buyer or product owner leaves the team.

  • Product or SKU name, supplier part number, and trade description used for the lookup.
  • Supplier identity and upstream role, including whether the supplier provides a due diligence statement reference number or declaration identifier.
  • Commodity family and Annex I match used for the scope conclusion.
  • Invoices, purchase orders, import/export records, or shipment records that tie the conclusion to the actual movement.
  • Downstream recipient information where the business is required to keep supply chain information.
  • Review note for unresolved uncertainty, such as a supplier description that does not clearly identify the commodity basis.
Citations
Consolidated Regulation (EU) 2023/1115

Supports due diligence information collection, supply chain information, supplier details, due diligence statement references, declaration identifiers, and five-year recordkeeping.

Recommended next step

Build an EUDR product-scope evidence file

Use Sorena to keep Annex I product conclusions linked to official sources, supplier records, and due diligence references.

Question 4

What are the most common mistakes in EUDR Annex I product lookup?

The main mistake is treating Annex I lookup as a one-time legal label instead of a repeatable product-data control. A product can be misclassified when the team checks only the product name, only an internal category, or only a customs field without tying the conclusion back to the official scope source and supplier evidence.

Another mistake is using broad commodity claims without tracing the product to the role-specific obligation. If an item is a relevant product, the next question is not just whether EUDR applies; it is which party must hold or pass on the due diligence statement, simplified declaration identifier, or Article 5 supply chain information.

  • Do not assume every product connected to a covered commodity is automatically listed; check the product against Annex I.
  • Do not assume a product is out of scope because the supplier description avoids the commodity name.
  • Do not rely on unsupported copied code lists, stale tariff mappings, or internal material groups as the only evidence.
  • Do not separate the lookup from supplier due diligence references or downstream trade records.
  • Do not mark a product out of scope without keeping the reason and the source used for the conclusion.
Citations
Primary sources

References and citations

eur-lex.europa.eu
Referenced sections
  • Supports the distinction between Annex I product scope, Article 3 conditions, and role-specific operator, downstream operator, and trader records.
"Operator: places relevant products on the market or exports them"
environment.ec.europa.eu
Referenced sections
  • Supports the high-level commodity families covered by the EUDR.
"cattle, cocoa, coffee, oil palm, rubber, soya and wood"
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