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: the amendment adds specific entries with deferred dates
Commission Delegated Regulation (EU) 2026/2102 changes EUDR Annex I and adds specified products whose new entries apply from 30 December 2027. These include frozen cattle tongues, coffee extracts and a range of palm-derived products. The amendment also removes or narrows other entries and adds exclusions. It should not be described simply as an across-the-board expansion.
A business needs the exact code, description and qualification for each new product. A familiar name such as soluble coffee, soap or palm chemical can be broader than the legal entry. The current scope framework explains how to map actual goods rather than using an undifferentiated list of commodity derivatives.
Frozen cattle tongues are a specific addition
The new cattle entry is ex 0206 21 00 for frozen cattle tongues, with application from 30 December 2027. It does not establish a new general deadline for every cattle product. Other listed meat and offal entries need to be assessed under their existing wording and dates. The cattle footnote also defines the covered animals and excludes buffalo and bison.
The same amendment removes the previous hides and leather entries. A cattle-products register should therefore show both directions of change: the newly added tongue entry and the removal of specified former products. A company that merely adds one new row to an old list without reviewing deleted rows will continue to give incorrect current scope answers.
Coffee extracts have their own entry
The amendment adds 2101 11 00 for extracts, essences and concentrates of coffee, expressly applying from 30 December 2027. This is distinct from the existing 0901 coffee entry. A product commonly marketed as soluble or instant coffee needs classification against the actual new entry rather than automatic treatment based on its label.
Do not extend the addition to every prepared beverage or mixture containing coffee. Other preparations can fall under different classifications. Record the product specification, code and reason it matches 2101 11 00. Maintain existing coffee-bean and roasted-coffee assessments separately so the deferred extract date does not accidentally postpone obligations for products already listed under another entry.
Palm oils and glycerol include new categories
New deferred palm-related entries include ex 1516 20 for specified modified oils, ex 1518 00 for the described modified oils and preparations, and ex 1520 00 for specified crude glycerol, glycerol waters and lyes produced using oil palm. These are qualified entries, not complete coverage of every substance within the broad customs descriptions.
The current Annex distinguishes covered Elaeis oil palm from other palm species and feedstocks. Some entries include exclusions tied to medicinal manufacturing. Identify the raw-material origin and the applicable use before concluding that a product matches. A substance name or tariff number without feedstock evidence may leave a decisive condition unresolved.
Several alcohol, acid and nitrogen-chemical entries are added
The deferred additions include specified palm-derived products under ex 2905 16, ex 2905 17 00, ex 2905 19 00 and ex 2915 39. They also include ex 2916 15, ex 2916 19 10, ex 2921 19, ex 2923 90 00 and ex 2924 19 00, within the detailed descriptions in Annex I. These entries contain exclusions and descriptive limits that cannot safely be replaced with their broad chemical-family names.
Some related palm chemicals were already listed and have amended descriptions rather than the same deferred new-entry treatment. Keep a change register that distinguishes a genuinely new deferred entry from a refinement to an existing one. A single rule applying 30 December 2027 to all palm derivatives would obscure that difference and can give the wrong deadline for an existing relevant product.
Soap and other chemical preparations also need mapping
The new deferred entries include ex 3401 11 00 for the specified toilet soap forms and ex 3401 20 for other described soap forms containing or made using oil palm. Further entries include ex 3824 99 for specified chemical products and preparations and ex 3907 29 for specified polyethers. Each must be checked against its full text rather than treated as an unrestricted heading addition.
Medicinal-manufacturing exclusions appear in several of these entries, with references to particular EU legislation. Apply them only where the product and use satisfy the stated conditions. A supplier's pharmaceutical customer base does not prove that every consignment qualifies. Separate technical feedstock evidence from evidence of the use supporting an exclusion.
Build a forward-looking product register now
Record current scope, future scope, matching entry, source evidence, exclusions and the express 30 December 2027 date for each qualifying addition. Assign an owner to unresolved classifications and feedstock questions. This allows procurement to obtain information in advance without falsely describing a future requirement as already applicable to every transaction today.
Use the delegated act together with the consolidated Annex. The scope assessment checklist provides a practical record. Review the act's removals, narrower entries and exclusions at the same time as its additions, so the register accurately reflects the whole amendment rather than only its expansion elements.
A practical implementation plan can prioritise products whose classification is already clear but whose feedstock is unknown. Ask those suppliers for manufacturing-source information first. Products with unresolved classification need a different workstream, because collecting plot evidence will not establish whether the finished goods belong in the new entry. Keep both tasks visible in the readiness register.
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.