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 commodity is the source, the product is the listed good
A relevant commodity is one of the seven source groups named by EUDR. A relevant product is a good listed in Annex I that contains, has been fed with or has been made using the relevant commodities within the Regulation's framework. The practical distinction is between the underlying material or animal and the specific good involved in a market transaction.
This comparison helps businesses map processing chains without assuming that every output inherits the legal status of its inputs. A commodity can pass through several listed products and then become part of an unlisted finished article. The product-scope framework explains the Annex comparison that must accompany that supply-chain map.
Follow one commodity through several products
Consider cocoa beans processed into cocoa paste and then a chocolate preparation. Cocoa is the underlying commodity relationship. Beans, paste and chocolate can each be relevant products under their respective listed headings. The product being supplied changes as processing occurs, and its classification and transaction need to be identified at each stage.
This does not mean the forest-risk evidence is unrelated between stages. Traceability connects the derived product back to the production of the relevant commodity. But the finished product record and its quantity are not interchangeable with a bag of raw beans. A manufacturer needs a supported link between inputs and outputs rather than a single commodity label that conceals transformations, mixing and changes of commercial unit.
A commodity connection does not list every output
If a finished article contains an ingredient made from a relevant commodity, first ask whether the finished article itself falls within Annex I. An ingredient's earlier relevant-product status does not automatically expand the Annex to every later article. This is especially important for complex food preparations, chemical formulations and multi-material consumer goods.
For example, a manufacturer may purchase a listed oil or chemical input and use it in an output outside the current listed headings. The input transaction still requires its own assessment, while the output should not be labelled relevant without a matching entry. These are separate decisions. Neither an unlisted output erases upstream obligations nor a listed input automatically creates an obligation for every downstream output.
The listed commodity is not a broad commercial family
The current cattle, rubber, oil palm and wood footnotes sharpen the commodity boundaries. Buffalo and bison are not covered simply because a supplier groups them with bovines. Rubber coverage is limited to the specified source rather than every natural gum or synthetic elastomer. Oil palm is not every palm species, and bamboo and rattan are not treated as covered wood merely because they look woody.
Those limits matter when product codes group similar materials. The product may match a broad customs description while its actual material falls outside the relevant commodity boundary. Ask for species or feedstock evidence when it resolves that uncertainty. The distinction should be visible in the assessment record so a future supplier substitution does not inherit an answer based on a different material.
Processing changes actor questions as well as products
A processor turning relevant inputs into a relevant output must examine its current legal role under the amended Regulation. The existence of a new product code does not alone establish that the processor must submit a new due diligence statement. The revised rules distinguish operators, downstream operators and traders, and their obligations depend on the actual facts and the current provisions.
Keep the product-scope decision separate from the actor decision. First establish whether the output is listed. Then identify how the business acquired the inputs, what earlier due diligence or simplified declaration applies and what its activity constitutes. This prevents an old assumption that every transformation necessarily creates a fresh first-operator filing from being embedded in the product master.
The commodity guides the evidence trail
For a relevant wood product, traceability concerns the wood and the harvesting context; wood also has the forest-degradation requirement. For cattle products, the geolocation framework concerns the establishments where the cattle were kept. For a listed cocoa preparation, the cocoa supply must be connected to the production plots even when the final product is sold in an entirely different format.
A broad product origin statement is not necessarily the country-of-production evidence needed for the commodity. The country where chocolate was manufactured can differ from the cocoa-growing country. Similarly, the factory producing a wooden article can differ from the forest location. Maintaining both the product identity and commodity origin avoids confusing the last processing location with the relevant production location.
Record both identities without duplicating them
A practical assessment has separate fields for the product SKU and classification, the relevant commodity, the commodity's production sources and the transaction. Add the Annex entry and the evidence linking the product to those sources. This structure is more useful than choosing one label and expecting it to answer every compliance question.
The definitions and schedule are available in Articles 1 and 2 and Annex I. For goods produced by refining, extracting or manufacturing from listed inputs, the derived-product assessment develops the next step. The key is to preserve the distinction between what was produced on the land and what is being supplied now, while retaining a traceable link between the two.
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.