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: a derivative is covered when the listed entry covers it
EUDR can apply to products derived from the seven relevant commodities, including refined oils, chocolate, selected chemicals, paper and wooden furniture. The fact that a product has been processed does not remove it from scope. However, derivation alone is not enough: the actual goods must match a current Annex I entry and its qualifications.
The useful question is therefore which derived product is being supplied, rather than whether processing has occurred. Some chains contain several listed stages and an unlisted final output. Other chains remain within listed categories throughout. The commodity and product scope guide sets out the classification framework for following those changes.
Processing does not erase the commodity relationship
Cocoa paste and cocoa butter are processed forms of cocoa with their own listed headings. Soya oil and extraction residues have separate entries. Wood can become a listed panel or furniture article. These products remain connected to the production of the relevant commodity even though their commercial form and quantity differ from the original material.
An operator's evidence needs to preserve that connection through transformation. The production country of the commodity can differ from the country where the derivative was manufactured. A refinery address does not establish where oil palm was grown, just as a furniture factory does not identify the forest. Distinguish the processing-location record from the commodity-origin record rather than treating a finished-product origin declaration as a complete answer.
Not every downstream derivative is listed
The Annex is a defined schedule, not a rule covering any product with a detectable commodity connection. If a listed substance becomes an ingredient in a finished formulation outside the listed headings, that final formulation does not automatically become a relevant product. The earlier supply of the listed ingredient remains a separate transaction that must be assessed on its own facts.
For complex formulations, obtain the finished-product classification and examine the relevant description. Do not use an ingredient inventory as a substitute for classifying the goods. Conversely, do not assume that an extensive processing step must produce an unlisted output. A refined substance can remain squarely within a listed entry even when the manufacturer's process is technically sophisticated.
Feedstock can distinguish identical chemicals
Several palm-related chemical entries depend on whether a substance was synthesised using oil palm. A chemical name or CAS number can identify the substance without identifying its raw-material source. Two batches with the same analytical composition may therefore need different scope assessments when their feedstocks differ and the entry expressly makes that distinction.
Ask the manufacturer for evidence directed at the feedstock question, such as an appropriate technical declaration linked to the product or production line. Check whether substitutions are permitted and how the supplier communicates changes. A general statement that a factory uses vegetable materials may be too broad to distinguish covered oil palm from another source. The evidence should resolve the condition in the Annex rather than merely repeat a sustainability claim.
The 2026 amendment changes the derivative map
The amended Annex adds coffee extracts, essences and concentrates under 2101 11 00 with application from 30 December 2027. It also adds specified palm-derived oils, alcohols, acids, soaps and other chemical categories with express deferred dates. These additions should be mapped at the precise code-and-description level. They do not include every soluble-coffee preparation or every palm-containing consumer product.
Some palm entries also contain medicinal-manufacturing exclusions tied to specified EU legislation. The exclusion must be checked against the particular entry and use. Selling to a pharmaceutical business is not, by itself, proof that every consignment qualifies. A dated scope matrix should distinguish existing entries, new deferred entries and products that remain unlisted.
Transformation affects quantities and traceability
When raw material becomes a derivative, commercial quantities change through yield, moisture changes, co-products and processing losses. A traceability record should connect the input batches and their sources to the actual output. A simple one-to-one tonnage assumption can create impossible evidence even where the sourcing itself is well documented.
This does not require inventing a universal conversion factor. Use the actual process information and a documented explanation of allocation, blending and output. Where several origins contribute to the same relevant derivative, the evidence must support the sources actually involved. If the manufacturer cannot identify the inputs, the scope decision may still be clear while the compliance evidence remains incomplete. Those are different problems and should have different remediation actions.
Apply obligations after identifying the product and role
A manufacturer should not infer filing duties solely from the word derivative. Under the current actor model, the business may be an operator or a downstream operator depending on the supply-chain facts. Product classification answers what the goods are; role analysis answers which obligations attach to the business's activity. Keep both decisions visible and connected.
Use the consolidated Regulation and Annex I for the legal baseline. The page on products added in 2026 is useful when building the forward-looking derivative register. Review whenever processing, feedstock, supplier, classification or Annex wording changes, and retain the evidence that supported the previous result so the change can be explained.
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.