The new EUDR Annex I is in the Official Journal: what leaves the scope tomorrow and what joins it in 2027

17 September 2026. The Commission published Delegated Regulation (EU) 2026/2102 in the Official Journal today. It amends Annex I of the Deforestation Regulation, the list of commodities and products that fall within scope, and under its Article 2 it enters into force the day after publication, so on 18 September 2026. The act was adopted on 13 July; neither Parliament nor Council objected during the two-month scrutiny period.

The product scope of the EUDR is therefore settled a little over three months before the rules start to apply. If you have been carrying your CN code mapping with a "provisional" flag, you can freeze it now.

What leaves the scope immediately

Three entries are deleted outright, and several others have been cut down to narrow code lists. Because the regulation enters into force tomorrow, these reliefs apply well before 30 December 2026.

Cattle hides, skins and leather. The entries `ex 4101` (raw hides and skins of cattle), `ex 4104` (tanned or crust hides and skins) and `ex 4107` (leather further prepared after tanning or crusting) are gone.

Conveyor and transmission belts. The entry `ex 4010` for conveyor and transmission belts of vulcanised rubber is deleted, as is `ex 4016` for other articles of vulcanised rubber not elsewhere specified in Chapter 40.

Aircraft and motor vehicle seats. The blanket entry `ex 9401` for wooden seats is replaced by a positive list of individual subheadings, among them `ex 9401 31 00` for swivel seats with variable height adjustment and `ex 9401 41 00` for seats convertible into beds. Aircraft and motor vehicle seats no longer appear on that list and are therefore out of scope.

One point that is being reported too simply: retreaded tyres are not fully removed. The old entry `ex 4012` is replaced by a single narrow subheading, `ex 4012 90 30`, tyre treads. A remainder stays in scope, so check the eight-digit level rather than assuming the whole heading has gone.

What joins the scope on 30 December 2027

The additions do not apply from December 2026 but a year later. The drafting technique is worth noting: the date does not sit in the enacting terms. It appears as a parenthetical note after each individual entry: “This provision shall apply from 30 December 2027.” Anyone checking their portfolio has to look code by code rather than assume a blanket transition rule.

Soluble coffee. `2101 11 00`, extracts, essences and concentrates of coffee.

Frozen cattle tongues. `ex 0206 21 00`.

Oleochemical palm oil derivatives. Among them `ex 1516 20` for palm, palm kernel and babassu oils that are wholly or partly hydrogenated, inter-esterified, re-esterified or elaidinised, plus a series of entries from Chapters 2915, 2916, 2921, 2923 and 2924.

Soap. This is the addition that several analyses reported as dropped and that is in fact in the text: `ex 3401 11 00` for soap in the form of bars, cakes or moulded pieces for toilet use, and `ex 3401 20` for soap in other forms, in each case where it contains oil palm or was produced using oil palm. For cosmetics and detergent manufacturers this is the single most consequential change in the act.

The new palm oil and soap entries consistently exclude products used in the manufacture of human or veterinary medicinal products falling under Directive 2001/83/EC, Regulation (EC) No 726/2004 or Regulation (EU) 2019/6.

Four clarifications that narrow the commodity definitions

Four new notes to the table settle boundary disputes quietly but effectively.

Cattle means only the genus Bos with its subgenera Bos, Bibos, Novibos and Poephagus under HS subheadings 0102 21 and 0102 29. Buffalo of the genus Syncerus and bison of the genus Bison are not covered.

Oil palm means Elaeis spp., including Elaeis guineensis. Babassu oil from Attalea spp. and other palm oils are outside.

Rubber means the rubber tree, Hevea brasiliensis. Balata, gutta-percha, guayule, chicle and similar natural gums produced with other species, as well as synthetic rubber products, are not covered.

Wood does not extend to bamboo, rattan and other woody materials, a category the text expressly defines as including reed, rushes, osier and willow, raffia, cleaned, bleached or dyed cereal straw and lime bark. Products listed under the wood commodity therefore fall outside to the extent that they consist of these materials.

A fifth note takes samples and specimens of negligible value out of scope, along with products subjected to tests, analyses or trials, provided they are consumed or destroyed in the process.

Packing material: read this one closely

The Commission's own summary of the packing material exemption is shorter than the text. Packing materials and containers fall outside the scope only where they are used to support, protect or carry another product that is placed on the market or exported. Placed on the market or exported as products in their own right, they remain in scope.

That applies expressly to packaging clearly suitable for repeated use: where such items are made available or re-exported as products in their own right, they are subject to due diligence. If you trade wooden reusable crates, pallets or load carriers rather than simply shipping goods in them, this is worth checking.

Separately, the phrase “not including used products and second-hand products” has been added to a number of entries, among them soft rubber sheets and the wooden seats. For circular business models this is the most useful clarification in the act.

What to do now

Freeze your mapping. If you have been checking your articles against the draft with a "provisional" flag, you can now fix the result. What matters is the CN code, not the description on the invoice.

Pass on the good news. If leather, conveyor belts, vehicle seats or other vulcanised rubber articles are in your portfolio, you can stop preparing for them and withdraw the supplier requests you sent. That saves more time than any software feature.

Start on the 2027 additions now. A year of extra time sounds relaxed, but geolocation data for coffee and palm oil production plots takes as long to collect as for any other commodity, and soap manufacturers sit in a supply chain that has never received this request before.

Read the ex codes individually. An "ex" in front of a heading means only part of it is covered. For seats and for tyres, exposure is decided at the eight-digit subheading, not at the four-digit heading.

The act changes nothing about the deadlines. They remain 30 December 2026 for large and medium-sized operators and for all downstream operators and traders that are not SMEs, and 30 June 2027 for micro and small enterprises that are operators. Who falls under which deadline is set out in Operator or trader? The four EUDR roles, the SME thresholds and the two deadlines; the continuously updated overall picture is in EUDR current status.

A full mapping table covering all 29 amendments to the product column, with a check procedure by CN code, follows in a separate article.

Source: Commission Delegated Regulation (EU) 2026/2102 of 13 July 2026 amending Regulation (EU) 2023/1115 as regards the list of relevant commodities and relevant products, OJ L of 17 September 2026. Codes, dates and the substance of each change were taken from the authoritative text. This article is not legal advice.

Photo: The Manh via Unsplash.