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: Annex I defines the product list
Annex I is the EUDR product-scope schedule. It links the seven relevant commodities to goods classified in the Combined Nomenclature. Its rows, qualifications and footnotes determine which products are relevant; the schedule is not merely an illustrative list of sectors. A business needs to read the actual entry that corresponds to its goods.
The current version incorporates important changes made in 2025 and 2026. A downloaded original Annex can therefore be accurate as a historical document while giving an incorrect current result. Use the 18 September 2026 consolidated text as the present editorial baseline, with the amending act when checking exactly what changed.
The two columns work together
The commodity column identifies cattle, cocoa, coffee, oil palm, rubber, soya or wood. The product column provides the codes and descriptions associated with that commodity. These columns should be read together. A product description copied without its commodity context may appear broader than the EUDR coverage actually intended, particularly where the customs heading contains products from several material sources.
For example, the oil palm section includes chemical substances whose classification can cover more than one feedstock. The description and footnotes identify the relevant connection to oil palm. A chemical procurement team therefore cannot establish coverage by asking only for the substance name. It needs the manufacturing-origin information necessary to test the entry. The product scope overview explains how this connects to the wider assessment.
Codes appear at different levels of detail
Some Annex entries use broad headings or chapters; others identify more detailed subheadings. The assessor must compare the product with the level actually listed. A company maintaining eight-digit CN codes can map them to broader listed headings, but that mapping still needs to preserve any qualification attached to the Annex description.
The prefix ex means the entry covers only part of the associated code. It is a restriction, not a decorative label. Goods sharing the same customs code can consequently receive different EUDR outcomes. The full description may restrict material, species, use or manufacturing source. This is especially important for mixed material categories and chemical derivatives, where a superficially correct numeric match can conceal a decisive difference.
Introductory language applies across the table
Before the commodity rows, Annex I excludes certain goods made entirely from material that has completed its lifecycle and would otherwise be discarded as waste. It also contains a manufacturing by-product exception. That language has to be considered alongside the relevant row, rather than overlooked because the assessor jumped straight to a familiar product code.
The word entirely matters. Recovered content does not automatically make the whole article excluded when virgin covered material is also present. Conversely, an article should not be treated as relevant simply because a broad code appears if the introductory exclusion genuinely applies. Record the source and status of recovered material, the manufacturing process and the reason the legal test is met or not met.
Product-specific exclusions need their own review
The amended Annex includes exclusions for waste, used and second-hand products and certain recovered products in particular entries. It also contains detailed packaging language. Those provisions are not identical across every row. A rule expressly attached to one heading should not be copied into an unrelated heading without checking whether the legal text supports that extension.
The wood and paper entries illustrate this approach. Listed packing goods can be distinguished from packing material exclusively supporting, protecting or carrying another product and presented with it. Reusable containers have specific wording about suitability for repetitive use and their use from the relevant point onwards. Marketing or information materials accompanying other goods receive separate treatment in the paper entry. Each condition deserves a recorded factual answer.
Footnotes can change an apparently obvious result
The cattle footnote limits the live animals covered and excludes buffalo and bison. The oil palm note distinguishes Elaeis species from other palm sources. The rubber note identifies Hevea brasiliensis and excludes specified other gums and synthetic rubber. The wood footnote addresses bamboo, rattan and other materials of a woody nature. These are substantive scope boundaries.
Another footnote provides conditional exclusions for negligible samples intended only to solicit orders and products undergoing specified examination, analysis or tests. The conditions prevent an ordinary commercial shipment from becoming exempt merely through its invoice description. When relying on such a provision, retain evidence of presentation, quantity, purpose and the relevant disposition of the test products.
Amendment markers are not application dates
Consolidated texts use markers to show where amendments changed wording. A marker identifies the source of text, not whether every obligation applies immediately. Several new entries expressly state that they apply from 30 December 2027. Existing entries remain subject to their own applicable rules. Always separate the Annex's content history from the operative date of the provision.
Use a versioned assessment containing the complete entry, not an isolated screenshot of a code. The 2026 product additions show why this is necessary. An amendment can add some products, remove others and refine exclusions at the same time. Reading the whole relevant entry is the simplest protection against treating that mixed change as a universal expansion or universal exemption.
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.