Filed under EUDR Commodities and Product Scope Explained
Plot record: legal status and review details
- Jurisdiction
- European Union
- Status
- Current consolidated Regulation, including 2025/2650 and the 2026 Annex I amendment; specified new entries apply from 30 December 2027.
- Application
- General obligations: 30 December 2026. Article 38(3) qualifying micro and small operators: 30 June 2027, except EUTR-covered products. Specified new Annex I entries: 30 December 2027.
- Relevant provisions
- Articles 1, 2 and 38; Annex I
Review this page when:
- Annex I amendment
- CN classification change
- Commission guidance update
- Application date reached
Answer: HS and CN are related, not identical
HS codes are the international Harmonized System classifications, commonly described at six digits. The EU Combined Nomenclature builds on that structure with eight-digit subdivisions. EUDR Annex I identifies goods using the Combined Nomenclature framework, while the due diligence statement information in Annex II refers to a Harmonised System code. Understanding both prevents a business from confusing product scope with a system data field.
A supplier's six-digit HS code is therefore useful starting information, but it may not identify the detail needed for an EU scope decision. The assessor must compare the actual product with the listed Annex entry, its description and any ex qualification. The EUDR product-scope framework explains the complete decision rather than reducing it to a code match.
Start with the classification hierarchy
The first two digits identify an HS chapter, four digits identify a heading and six identify a subheading. The EU adds further subdivisions through the CN. Other countries can add different national subdivisions after the shared HS structure. A foreign ten-digit tariff number should consequently not be copied into an EU product master on the assumption that its final digits carry the same meaning.
This matters when an overseas supplier has classified goods correctly under its own national tariff but the EU needs a different subdivision. Preserve the original information, then map it to the EU classification using the product specification and the applicable nomenclature. Do not shorten or extend a code mechanically and assume the underlying product description remains identical.
Annex I uses more than one level
An EUDR entry can cover a chapter, a heading or a more detailed code. Where a broader heading is listed, the company's detailed CN code may map within it. However, an ex entry restricts coverage to the described part. The number and the words are one legal test; matching only the numeric prefix leaves the assessment incomplete.
For example, customs categories for chemical substances may cover different raw-material origins. EUDR can limit an entry to substances synthesised using oil palm. The code does not necessarily reveal that source. Likewise, the rubber footnote limits the covered material even when a broader customs description names other gums. A commodity-specific specification supplements classification rather than replacing it.
Scope fields and statement fields serve different purposes
The product master may need a detailed CN code for customs and Annex mapping. A due diligence statement must contain the classification information prescribed by Annex II and the current Information System requirements. Those are related records with different functions. The scope decision establishes whether a product is relevant; the statement records required information for the appropriate product and actor workflow.
Avoid designing a database with one ambiguous field labelled customs code and no information about its system, length or version. A more useful structure records HS level, EU CN code, the year or version used and the matching Annex entry. Where customs uses additional tariff subdivisions, keep those separately so they are not mistaken for the legal scope definition.
Codes need supporting product facts
A customs code should follow the physical product and the applicable classification rules. The assessor may need composition, processing stage, dimensions, presentation, function or other characteristics. A commercial label such as instant beverage, rubber accessory or wooden component rarely provides enough detail by itself. Supplier documents should be checked for consistency with the actual goods.
A classification copied from an unrelated product can create two errors: incorrect customs treatment and an incorrect EUDR scope decision. When evidence is weak, identify the uncertainty explicitly. A customs specialist or binding tariff information process may help resolve classification. Neither a software-generated suggestion nor a buyer's preferred compliance outcome establishes the correct code merely by being recorded in a spreadsheet.
Nomenclature changes require maintenance
The Combined Nomenclature is updated periodically. A business should use the version appropriate to the relevant transaction and understand any change in code structure. EUDR Annex amendments can also change the product description or the scope of a code independently of a supplier's classification practice. These are separate update channels and both deserve monitoring.
Store the date of the assessment and the source consulted. If a code changes, review the mapping rather than assuming that a replacement number automatically carries an identical EUDR result. If Annex I narrows an entry, review current product status even when the customs code has not changed. This is especially relevant after the 2026 product-scope amendment.
A practical record connects both systems
For each SKU, retain the supplier description, technical specification, EU classification, corresponding HS level, Annex match and exclusion analysis. This creates a bridge between purchasing, customs and compliance teams. It also helps explain why two products under the same broad HS heading can have different EUDR statuses without implying that one team made an arithmetic mistake.
Use Annex I and Annex II of the current EUDR to verify the distinction between scope and statement information. Where the difficult question is whether a heading actually includes the goods, follow the customs-code scope analysis. The useful outcome is a supported classification and legal comparison, not simply a code of the expected length.
Primary sources on the record
Articles 1, 2 and 38; Annex I. This entry was checked against the consolidated text dated 18 September 2026. Consolidated texts are documentation tools; the authentic acts are those published in the Official Journal.
Check the current sources and the guidance of the relevant competent authority for your situation. This page is not legal advice or a compliance determination.