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.

Use the official Annex I wording, exclusions, and product descriptions for the final match. Reconcile any internal Combined Nomenclature (CN) or Harmonised System (HS) table against that text and retain the source version and review date.

Annex I generally excludes goods made entirely from material that completed its lifecycle and would otherwise have been discarded as waste. The exclusion does not cover by-products of a manufacturing process that used material that was not waste. Record the material evidence and the specific exclusion relied on; a recycled-content label alone does not establish this test.

Read Annex I with Commission Delegated Regulation (EU) 2026/2102, in force from 18 September 2026. It changes product descriptions, removals and exclusions. Specific added entries, including frozen cattle tongues and coffee extracts, apply from 30 December 2027. Check the exact amended entry and its date before deciding that a product is covered.

An operator first places relevant products on the EU market or exports them, excluding downstream operators. A downstream operator places or exports a relevant product made using relevant products that are all covered by due diligence statements or simplified declarations. A trader makes relevant products available commercially and is neither their operator nor their 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.

On the standard operator route, due diligence includes information collection, risk assessment, and risk mitigation where needed. Article 13 permits qualifying low-risk production to omit Articles 10 and 11 after the required checks. 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.

Update the classification record when the product, supplier, country of production, customs classification, role, upstream reference number, or legally effective Annex I changes.