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: compare the actual product with Annex I
Check EUDR coverage by identifying the goods being supplied, establishing their customs classification and comparing them with the complete current Annex I entry. Read its description, ex limitation, footnotes and exclusions. Then check the relevant transaction and application date. A commodity name, supplier declaration or code alone does not finish the assessment.
The process should produce a reasoned result for a defined product, not a generic answer for a whole company. A business might import listed coffee while selling an unrelated unlisted accessory. It might also sell several similar chemical products made from different feedstocks. The EUDR scope framework explains why those facts can produce different outcomes.
Step one: define the assessment unit
Start with the exact SKU, material specification, production method, intended use and physical form. For mixtures, collect a bill of materials sufficient to identify potentially relevant commodities. For products whose Annex entry depends on species or feedstock, ask directly for that information. The assessor should know whether the question concerns a bag of beans, an extract, a finished food or an empty packing container.
Also identify what happens commercially. Is the product entering the EU, being manufactured and first supplied in the EU, being resold, or being exported? These facts later determine actor obligations. They can also matter for conditional exclusions, especially packaging supplied with another product. Do not start collecting plot coordinates for an undefined product family; first establish which goods and transactions require that work.
Step two: establish a defensible classification
Use the product's actual CN classification rather than a supplier's broad category. Check whether an existing code is current and supported by the technical description. Customs invoices often carry useful data, but the mere presence of a code does not prove that it was assigned correctly. Where classification is uncertain, involve a customs specialist or seek an appropriate customs determination.
For an imported chemical, the safety data sheet may identify composition without resolving the manufacturing feedstock. For a food preparation, the recipe and presentation can affect classification. For furniture, the material and particular article matter. Preserve the reasoning and technical evidence alongside the chosen code, so a reviewer can see how the goods were matched rather than having to reconstruct the decision later.
Step three: read the full Annex entry
Locate the code in the consolidated Annex I. If the entry starts with ex, compare its narrower description with the product. Read the commodity-column heading and the footnotes. The current rubber and oil palm footnotes, for example, restrict materials that may sit within broader customs descriptions. A numerical match can therefore be necessary without being sufficient.
Record the exact entry considered and the conclusion. A useful decision explains why the product satisfies or fails its conditions. If no Annex entry matches the finished good, state that basis. Avoid wording such as no forest risk, which answers a different question. An unlisted product might have environmental impacts without being a relevant product under this particular Regulation.
Step four: test any claimed exclusion
Identify the exclusion being relied on and collect evidence for every relevant condition. A recycled-content percentage does not establish that an article is made entirely from qualifying recovered end-of-life material. A second-hand claim must be checked against the specific amended entry rather than assumed to apply universally. A packaging exclusion depends on the current wording and the actual presentation and use of the packaging.
For an exclusion tied to medicinal manufacturing, document the relevant product and use within the legislation cited by the Annex. Do not extend it to every product sold to a pharmaceutical customer. Likewise, negligible samples and products for testing have specific conditions; simply describing a commercial shipment as a sample does not establish that those conditions have been satisfied.
Step five: assign present and future status
The main obligations begin on 30 December 2026. Article 38(3) gives a later 30 June 2027 date to the qualifying operators described there, with the EUTR-product exception. Some products added by the 2026 Annex amendment expressly apply from 30 December 2027. A product master should distinguish listed now, applicable later from outside the current list.
For example, an assessor considering coffee extracts should not simply copy the date assigned to coffee beans. The current entries differ. Record the date rule, the operator qualification if relevant, and the next review point. Where older timber is involved, examine the specific transition rather than treating every item in stock as subject to the same general deadline.
Step six: approve and maintain the result
The completed assessment should name an owner and retain the specification, code evidence, Annex version, exclusion evidence and applicable date. The outcome can be in scope, outside scope or unresolved pending identified information. An unresolved status should name the missing fact and the person expected to resolve it. That is more useful than a spreadsheet filled with unsupported yes or no answers.
After approval, connect in-scope products to the appropriate due diligence and actor workflow. Trigger reassessment when the recipe, feedstock, classification, intended use or law changes. Use the product-scope checklist as a controlled record rather than an automatic legal answer. A well-supported scope decision reduces unnecessary supplier requests and prevents genuinely relevant products from being missed.
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.