EUDRProduct scopeEU

EUDR in-scope commodities and products

Use the seven EUDR commodities and Annex I product list to decide whether a shipment, SKU, material, or export is a relevant product.

The scope answer also depends on your role: operator, downstream operator, trader, or micro or small primary operator.

Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Sections
6

Structured answer sets in this page tree.

Primary sources
4

Cited legal and guidance references.

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

EUDR scope is not triggered by every sustainability-relevant material. It starts with the seven relevant commodities named in the Regulation, then narrows to the relevant products listed in Annex I. A defensible scope record should show the commodity connection, the Annex I product match or non-match, the actor role, and the evidence used to support the conclusion.

Section 1

Start with the seven EUDR relevant commodities

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 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.

  • Record the commodity candidate: cattle, cocoa, coffee, oil palm, rubber, soya, or wood.
  • Identify the physical product, SKU, customs classification, material composition, and whether the item is being placed on the EU market, made available on the EU market, or exported.
  • Check Annex I for the relevant product description and code instead of relying on a generic commodity label.
  • Document out-of-scope conclusions too, especially when a supplier describes a material with a commodity name but the final product is not listed in Annex I.
  • Escalate ambiguous cases to trade compliance or legal before supplier onboarding, customs filing, customer commitment, or due diligence statement submission.
Section 2

Use Annex I as a lookup, not a loose commodity table

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.

  • Keep the supplier product description and internal material master record next to the Annex I entry used for the decision.
  • Capture the customs code or classification relied on by trade compliance, but verify it against Annex I rather than treating the code as a standalone legal answer.
  • Separate commodity presence from product listing: both matter when deciding whether a product is an EUDR relevant product.
  • Version the scope record when the product composition, supplier, production country, customs classification, or Annex I source text changes.
  • When a product is in scope, route it into the EUDR due diligence workflow before market placement or export.
Section 3

Actor role changes what the scope decision triggers

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.

  • Operators exercise due diligence before placing relevant products on the market or exporting them and do not proceed without prior due diligence statement submission, unless the simplified declaration regime applies.
  • Operators keep due diligence statement records for five years and communicate due diligence statement reference numbers or declaration identifiers down the supply chain.
  • Downstream operators and traders must possess required supply chain information before placing, making available, or exporting relevant products.
  • Non-SME downstream operators and non-SME traders register in the Article 33 information system before placing, making available, or exporting.
  • Micro or small primary operators may use the simplified declaration regime when the conditions in the Regulation are met, including the specific low-risk-country condition in the definition.
Recommended next step

Turn EUDR product scope into a repeatable record

Use this page to structure a commodity, Annex I, role, and evidence review before an in-scope product is placed on the EU market, made available, or exported.

Section 4

Evidence needed for an in-scope product

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.

  • Product identity: SKU, description, material composition, supplier name, and customs classification used for the Annex I check.
  • Commodity link: the relevant commodity or commodities involved, with support from supplier specifications, bills of material, procurement records, or trade documents.
  • Annex I match: the official Annex I entry relied on, the date or version of the source text, and the reason the product matches or does not match.
  • Role and transaction: whether the company is acting as operator, downstream operator, trader, exporter, or micro or small primary operator for the specific transaction.
  • Supply chain evidence: supplier details, downstream recipient details where required, due diligence statement reference numbers or declaration identifiers when provided by an upstream operator.
  • Due diligence evidence for in-scope operator cases: geolocation or permitted substitute information, legality documentation, deforestation-free evidence, risk assessment, mitigation records where risk is not negligible, and the due diligence statement or simplified declaration record.
Section 5

Common scope errors to avoid

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.

  • Do not treat all products associated with a relevant commodity as automatically in scope without checking Annex I.
  • Do not publish or rely on a partial CN or HS list unless it is complete, current, and traceable to the official Annex I source.
  • Do not reuse an upstream due diligence statement reference number unless the product, supplier, and transaction chain are clear.
  • Do not classify the company once at entity level; classify the role for the transaction or product flow.
  • Do not submit or rely on a due diligence statement when the underlying geolocation, legality, deforestation-free, and risk evidence is missing or unresolved.
Section 6

Minimum scope record for search visitors to build

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.

  • Product and transaction: SKU or product family, supplier, customer or recipient, market placement or export path, and customs classification used.
  • Commodity assessment: which of cattle, cocoa, coffee, oil palm, rubber, soya, or wood is relevant, and what evidence supports that link.
  • Annex I assessment: official Annex I entry checked, match result, reviewer, and reason.
  • Role assessment: operator, downstream operator, trader, or micro or small primary operator analysis for this transaction.
  • Evidence status: missing, collected, reviewed, or approved for geolocation, legality, deforestation-free, risk assessment, mitigation, and statement or declaration identifiers.
  • Next action: not in scope, collect more classification evidence, request upstream reference numbers, complete due diligence, submit a due diligence statement, submit a simplified declaration, or stop shipment pending review.
Primary sources

References and citations

eur-lex.europa.eu
Referenced sections
  • Supports the practical record fields by tying product scope to Article 3 conditions, role definitions, due diligence steps, and downstream information duties.
"Relevant commodities and relevant products must not be placed or made available on the market or exported unless"
eur-lex.europa.eu
Referenced sections
  • Original EUDR legal source for the regulation and its product-scope architecture.
"relevant products, as listed in Annex I"
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