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: map each legal relationship rather than counting ingredients
A product made using more than one EUDR commodity requires a structured scope and evidence assessment. First classify the finished goods and identify the Annex I entry or entries that make them relevant. Then establish which commodity inputs are covered by that legal relationship. The mere presence of several commodity names in a recipe does not automatically create several independently relevant finished products.
This is a mapping task, not a rule that the largest ingredient wins or that every ingredient is equally subject to the same statement. The product-scope framework explains the classification boundary. Difficult combinations should be checked against the actual entry and current official guidance rather than resolved through an invented universal percentage threshold.
Separate the output from the input transactions
Consider a manufacturer buying several listed ingredients and producing a mixed finished food. Each input may have been a relevant product when first placed on the market. The finished food must then be classified separately. Whether it is relevant depends on its Annex entry, not merely on whether its inputs arrived with EUDR references.
Keep those layers in the record. An unlisted output does not cancel obligations attached to an earlier relevant input. A listed output does not mean each ingredient becomes a separately traded product at the point the finished food is sold. The product register should therefore show the output SKU, its code, the relevant commodity relationship and the input records that support the assessment.
Do not confuse commodity relevance with mass proportion
A recipe can contain a small amount of a commodity and still fall within a listed preparation heading. EUDR does not offer a general permission to ignore covered material whenever its percentage is low. On the other hand, finding a trace ingredient does not itself bring an otherwise unlisted finished article into the Annex.
Use proportions where they are factually relevant to classification, manufacturing and quantity reconciliation. Do not convert them into a universal EUDR threshold that the Regulation does not provide. If the classification rules require detailed composition, obtain it. If the uncertainty concerns which feedstock produced a chemical ingredient, a percentage table without source information may not resolve the scope question at all.
Identify commodity-specific evidence paths
Different commodities can require different evidence. Wood brings the forest-degradation dimension as well as the deforestation-free and legality conditions. Cattle involves establishments where the animals were kept. Crop commodities generally lead back to production plots. A mixed purchasing file should preserve those distinctions rather than demanding one generic farm certificate for everything.
The supplier of a finished composite item might be a processor rather than the producer of any relevant commodity. Ask how its input batches connect to the output and which production sources were involved. A factory address is not a substitute for those sources. Where inputs were already covered upstream, examine the current actor rules and available references rather than automatically requiring a fresh first-operator filing for every transformation.
Avoid an overbroad interpretation of a commodity column
The Annex groups products under relevant commodities. That organisation matters when interpreting derived and composite products. A cocoa food preparation, for example, needs assessment under its actual heading and cocoa relationship. The presence of a palm-derived ingredient should prompt a separate examination of that input and the relevant current entries, rather than an unsupported claim that the entire food is simultaneously listed as every ingredient.
Likewise, a mixed-material article containing a wooden component should not automatically be treated as a wood product unless the finished article falls within the relevant listing. Record any uncertainty about the correct heading or applicable commodity relationship. Where the legal interpretation is genuinely unresolved, a targeted question to the competent authority is more useful than a blanket statement covering every composite product.
Keep feedstock and source changes visible
Multi-commodity formulations frequently change for cost, availability or performance reasons. A palm-derived substance can be replaced with one made from another source, or natural rubber can be replaced with synthetic material. Such substitutions can alter a scope condition even if the finished product's familiar name is unchanged.
The assessment should identify which specifications are decisive and require notification when they change. Store evidence at a level that can distinguish variants and batches where necessary. A supplier assurance covering one formulation does not establish every future formulation. Connect change control to procurement so an unresolved replacement is not automatically approved using evidence collected for a different material combination.
Produce one coherent assessment record
A useful record identifies the finished product and code, applicable Annex wording, each relevant commodity relationship, separately assessed inputs, source evidence, exclusions and dates. Add the responsible business role and the references required by that role only after those facts are established. This prevents the compliance system from treating a list of commodity tags as if it were a completed legal analysis.
Use the current EUDR definitions and Annex I for the scope test. The composite-product guide addresses the finished-article classification in more detail. Where evidence is missing, describe the exact missing relationship, such as unknown feedstock or unlinked input batch, so the supplier can provide information that actually resolves the assessment.
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.