EUDR in-scope commodities and products

The EUDR relevant commodities are cattle, cocoa, coffee, oil palm, rubber, soya, and wood. A product-scope review should first ask whether the product contains, has been fed with, or has been made using one of those commodities in a way that could connect it to Annex I.

Do not stop at commodity names alone. The Regulation applies to relevant commodities and relevant products; Annex I is the product lookup that turns a commodity connection into a regulated product category. Representative listed examples include cocoa beans and chocolate, coffee, natural rubber and new pneumatic tyres, soya beans and soya oil, and specified wood, paper, printed, and wooden-furniture products. These are examples, not a replacement for the exact Annex I wording and customs classification.

A practical Annex I check should pair the product description with the customs classification used by the business. If the evidence file only says 'wood product' or 'contains cocoa', it is too thin to support an EUDR scope decision.

This page does not publish a partial CN or HS code table. Partial code lists create false confidence when the full Annex I wording, exclusions, and product descriptions are not reproduced. Use the official Annex I text as the source of truth for the final scope match.

Once a product is in scope, the next question is role. An operator places relevant products on the market or exports them. A downstream operator places on the market or exports relevant products made using relevant products already covered by a due diligence statement or simplified declaration. A trader makes relevant products available on the market and is not an operator or downstream operator.

The role conclusion should be stored with the product-scope result because it determines which EUDR actions follow from the same Annex I match.

A scope file should be strong enough for a reviewer to understand why the product was treated as in scope before the due diligence work began. The product-scope record should then point to the due diligence evidence required for EUDR compliance.

For operators, due diligence includes information collection, risk assessment, and risk mitigation. The information file includes evidence such as geolocation of plots of land or establishments and documentation demonstrating deforestation-free and legal production.

Most weak EUDR scope files fail because they collapse several questions into one answer. A product can contain a relevant commodity but still need an Annex I check. A company can sell an in-scope product but have a different role from a supplier or customer. A due diligence statement reference number can support downstream handling, but it does not supersede the need to know which product and role the reference relates to.

Keep the scope conclusion narrow: one product or product family, one Annex I basis, one role conclusion, and one evidence file. Broader policy language can sit elsewhere, but it should not substitute for the product-level record.

A useful first record is short but concrete. It should let procurement, trade compliance, sustainability, and legal reach the same conclusion about whether the item is an EUDR relevant product and what must happen next.

Use the record as a living classification artifact. Update it when the product, supplier, country of production, customs classification, role, upstream reference number, or official EUDR source text changes.