Filed under EU Deforestation Regulation Explained: Scope, Requirements and Compliance
Plot record: legal status and review details
- Jurisdiction
- European Union
- Status
- In force; main obligations apply according to Article 38
- Application
- 30 December 2026 generally; 30 June 2027 only where Article 38(3) applies; specified Annex I additions from 30 December 2027
- Relevant provisions
- Articles 1, 2(1) to (2), 2(14), 2(24), 9; Annex I
Review this page when:
- EUDR amendments
- Commission guidance or FAQ revision
- Article 38 application dates
- Annex I amendments
The seven commodities in the legal definition
A relevant commodity under Article 2(1) of EUDR is cattle, cocoa, coffee, oil palm, rubber, soya or wood. This is a defined list. It identifies the raw-material categories around which the regulation is organised. A business cannot expand or narrow that list through its own sustainability policy, supplier classification or marketing terminology.
The commodity definition is only one part of the scope decision. Relevant products are the products listed in Annex I that contain, have been fed with or have been made using relevant commodities. To decide whether a specific item is covered, identify both the commodity relationship and the applicable Annex I product entry. Those questions are related but not identical.
Why a commodity is not the same as a product
A commodity can appear in different commercial forms as it moves through a supply chain. Coffee may be traded in different states, while wood may become a listed manufactured article. The law uses relevant-product classifications to define which forms are controlled. It does not treat every object associated commercially with coffee or wood as covered.
That distinction prevents two common mistakes. One is assuming that anything containing a relevant material automatically falls within scope. The other is assuming that processing removes a commodity from the regime. Read the relevant-product definition before applying either assumption to an actual item. Annex I descriptions and classification, including any qualified entry, must be checked.
Cattle concerns animals and covered derived goods
The cattle category extends beyond a simple purchasing label such as “beef”. Annex I determines which bovine products are relevant products. Businesses handling listed live cattle, meat or offal must assess the precise product entry. Cattle hides, skins and leather were removed from Annex I by the 2026 scope amendment, so an older list showing those goods should not be reused as the current scope test. Conversely, a supplier's involvement in a cattle supply chain does not bring every item it sells into scope.
Location evidence also follows the commodity's characteristics. For cattle, Article 9 refers to all establishments where the animals were kept. Recording only the address of a slaughterhouse or final processor can omit earlier locations. The commodity identification therefore influences the information required after the product has been confirmed as covered.
Agricultural commodities require production origins
Cocoa, coffee, oil palm, rubber and soya frequently pass through cooperatives, collectors, mills or export facilities. Those addresses identify businesses or processing stages, rather than necessarily identifying the land where the commodity was produced. EUDR distinguishes the country of production from the country of customs origin or the country from which the shipment departed.
For a coffee shipment consolidated in a trading country, begin with where the coffee was grown. A shipping document naming the trading country cannot by itself settle that question. Similarly, processing an agricultural commodity in another jurisdiction does not erase the need to identify the underlying production origins relevant to the product.
Wood carries an additional land-history question
Wood is one of the seven commodities, but its deforestation-free test includes the forest-degradation element in Article 2(13). Businesses therefore need to distinguish agricultural conversion from the specified structural changes to forest cover. Evidence suitable for a crop on agricultural land may not answer all the questions arising from timber harvesting.
Article 9 also requires the common and full scientific names of species for relevant products containing or made using wood. This helps identify what the goods actually are and evaluate the associated evidence. A commercial label such as “mixed hardwood” may be too imprecise for the required product description and a meaningful review.
How to map commodities in a procurement register
Record the product description, constituent materials, relevant commodity categories and the sources supporting those classifications. Then record the proposed Annex I entry separately. This allows a reviewer to see the difference between the material investigation and the legal conclusion about product coverage.
For a composite article, ask what relevant commodities are present or used and which are relevant to its Annex I entry. Avoid automatically applying every commodity data request to every ingredient. Equally, do not overlook an input simply because a supplier describes the output by a different commercial name. Product composition and the wording of the legal entry should drive the investigation.
Commodity knowledge does not establish compliance
Knowing that a shipment concerns rubber or soya identifies where to begin; it does not establish deforestation-free status or legality. The operator still needs the required information about production and must assess the actual risks. A commodity grown in a country classified as low risk is not automatically compliant, and a high-risk country classification is not itself a categorical ban.
Supply-chain structure matters alongside the commodity. A direct purchase from an identified producer raises different traceability questions from purchases through several collectors with changing sources. A useful assessment explains those differences rather than placing identical supplier declarations into separate commodity folders and treating the filing exercise as due diligence.
Check the legal version before relying on a list
The current baseline is the 18 September 2026 consolidated regulation. Product entries can change even where the seven-commodity definition remains stable. The September 2026 Annex I changes illustrate why a commodity-level summary should not be used as a permanent replacement for the product list.
The EUDR overview connects commodity identification to product scope, legal roles and the three market-access conditions. For the controlling definitions, consult Articles 1 and 2 and Annex I. Keep the commodity entry and the product-scope decision together so later amendments can be reviewed against an intelligible record.
Primary sources on the record
Articles 1, 2(1) to (2), 2(14), 2(24), 9; 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.