The Regulation
EUDR Annex I: Every Relevant Product and HS Code, as Amended in 2025 and 2026
EUDR Annex 1 under 2023/1115: all 89 HS and CN entries, 18 lines from 30 December 2027, leather and printed products removed, and the ex prefix.
EUDR Annex I lists 89 entries of HS and CN codes for seven relevant commodities, as consolidated in Regulation (EU) 2023/1115 on 18 September 2026.
Annex I sets the product scope of the EU Deforestation Regulation, for cattle, cocoa, coffee, oil palm, rubber, soya and wood.
Regulation (EU) 2025/2650 deleted printed products, and Delegated Regulation (EU) 2026/2102 deleted leather and added 18 lines. The key figures are listed below.
- Entries: 89 across seven commodities.
- Added lines: 18, applying from 30 December 2027.
- Main application date: 30 December 2026 (Article 38(2)).
- Removed: printed products (26 December 2025); leather (18 September 2026).
What Is EUDR Annex I?
EUDR Annex I is the table of "relevant commodities and relevant products as referred to in Article 1", listing goods as classified in the Combined Nomenclature of Annex I to Regulation (EEC) No 2658/87. It is the first of three annexes to the Regulation's 39 articles. Under Article 2(2), a relevant product is a product listed in Annex I that contains, has been fed with or has been made using a relevant commodity.
Seven Relevant Commodities, 89 Entries
The 89 entries split into cattle 8, cocoa 6, coffee 2, oil palm 28, rubber 10, soya 4 and wood 31, with 18 entries applying from 30 December 2027.
| Commodity | Entries | From 2027-12-30 | Species note |
|---|---|---|---|
| Cattle | 8 | 1 | Genus Bos only (note 1) |
| Cocoa | 6 | 0 | None |
| Coffee | 2 | 1 | None |
| Oil palm | 28 | 16 | Elaeis spp. only (note 2) |
| Rubber | 10 | 0 | Hevea brasiliensis only (note 3) |
| Soya | 4 | 0 | None |
| Wood | 31 | 0 | No bamboo, rattan or other woody materials (note 4) |
| Total | 89 | 18 |
Entries by commodity; the ex 9403 furniture entry counts once.
What Does "ex" Mean in an Annex I Code?
The prefix "ex" means that only part of the goods classified under the code is covered; the Commission reads it as "extract" (FAQ Version 5 (April 2026), 2.2). Since 18 September 2026, most wood, oil-palm and rubber entries carry "ex", because those codes also hold products of other materials (recital 7 of Delegated Regulation (EU) 2026/2102). Whole codes without "ex" are cocoa 1801 to 1806, coffee 0901 and 2101 11 00, and soya 1201 90 00, 1208 10, 1507 and 2304.
HS, CN or TARIC: Which Code Level Applies at Customs?
The Commission considers that three code levels apply at release for free circulation, and the 8-digit CN code at export (FAQ 2.9):
- HS: 6 digits, the World Customs Organization's Harmonised System.
- CN: 8 digits, the EU Combined Nomenclature.
- TARIC: 10 digits, declared at release for free circulation.
Yearly CN amendments apply directly; Annex I keeps the codes valid at adoption (FAQ 2.9). Document codes in the customs declaration are covered under EUDR at customs.
Products Not Listed in Annex I Are Not Covered
A product outside Annex I is not covered even if it contains a relevant commodity: the Commission cites margarine made with palm oil and cars fitted with natural-rubber tyres (FAQ 2.1). No de minimis threshold of volume or value exists (FAQ 2.3). Mixed natural and synthetic rubber products have no content threshold either, and due diligence covers the natural rubber only (FAQ 2.2, 2.3).
Composite Products: Which Commodity Does a Product Trigger?
A composite product triggers the commodity linked to its Annex I line. For chocolate under 1806, due diligence covers the cocoa inputs, such as cocoa powder (1805) and cocoa butter (1804), not the palm oil (1511) in the recipe (Guidance C/2026/3896, section 9; FAQ 1.3). Inputs not yet subject to due diligence must undergo it.
The Complete EUDR Annex I List of HS and CN Codes
The complete list prints all 89 entries of the consolidated text 02023R1115-20260918 in seven tables, with product wording shortened. Flags and the deferral column are explained in the table notes below.
Cattle: 8 Entries, Frozen Tongues From 2027
Cattle has 8 entries, from live cattle (ex 0102) to prepared meat (ex 1602 50), and frozen tongues (ex 0206 21 00) apply only from 30 December 2027. Chain detail sits under EUDR and cattle.
| Code | Product | Applies from | Deferral | Exclusions | Change since 2023 |
|---|---|---|---|---|---|
| ex 0102 | Live cattle | 2026-12-30 | yes | none | Rewording of "0102 21, 0102 29" (2026-09-18) |
| ex 0201 | Meat of cattle, fresh or chilled | 2026-12-30 | yes | none | Unchanged |
| ex 0202 | Meat of cattle, frozen | 2026-12-30 | yes | none | Unchanged |
| ex 0206 10 | Edible offal of cattle, fresh or chilled | 2026-12-30 | yes | none | Unchanged |
| ex 0206 21 00 | Frozen cattle tongues | 2027-12-30 | n/a | none | Added (2026-09-18) |
| ex 0206 22 | Edible cattle livers, frozen | 2026-12-30 | yes | none | Unchanged |
| ex 0206 29 | Edible cattle offal (excluding tongues and livers), frozen | 2026-12-30 | yes | none | Unchanged |
| ex 1602 50 | Other prepared or preserved meat, meat offal, blood, of cattle | 2026-12-30 | yes | none | Unchanged |
Cattle lines, consolidated text.
Cocoa: 6 Entries, Headings 1801 to 1806
Cocoa has 6 whole headings without "ex", from cocoa beans (1801) to chocolate (1806). Each heading is explained under EUDR and cocoa; since 18 September 2026, heading 1802 excludes waste under Article 3(1) of Directive 2008/98/EC.
| Code | Product | Applies from | Deferral | Exclusions | Change since 2023 |
|---|---|---|---|---|---|
| 1801 | Cocoa beans, whole or broken, raw or roasted | 2026-12-30 | yes | none | Unchanged |
| 1802 | Cocoa shells, husks, skins and other cocoa waste | 2026-12-30 | yes | W | Waste exclusion added (2026-09-18) |
| 1803 | Cocoa paste, whether or not defatted | 2026-12-30 | yes | none | Unchanged |
| 1804 | Cocoa butter, fat and oil | 2026-12-30 | yes | none | Unchanged |
| 1805 | Cocoa powder, not containing added sugar or other sweetening matter | 2026-12-30 | yes | none | Unchanged |
| 1806 | Chocolate and other food preparations containing cocoa | 2026-12-30 | yes | none | Unchanged |
Cocoa lines, consolidated text.
Coffee: Heading 0901 and Soluble Coffee 2101 11 00 From 2027
Coffee heading 0901 applies from 30 December 2026, and soluble coffee under 2101 11 00 from 30 December 2027. Roasting and import roles are covered under EUDR and coffee.
| Code | Product | Applies from | Deferral | Exclusions | Change since 2023 |
|---|---|---|---|---|---|
| 0901 | Coffee, whether or not roasted or decaffeinated; husks and skins; substitutes containing coffee | 2026-12-30 | yes | none | Unchanged |
| 2101 11 00 | Extracts, essences and concentrates of coffee | 2027-12-30 | n/a | none | Added (2026-09-18) |
Coffee lines, consolidated text.
Oil Palm: 28 Entries, 16 of Them From 2027
Oil palm has 28 entries: 12 apply from 30 December 2026 and 16 added lines from 30 December 2027. Note (2) limits them to Elaeis spp., so babassu oil (Attalea spp.) is out.
Liquid skin-washing products (3401 30) and surfactants (3402) are not listed. Mill-to-refinery chains are covered under EUDR and oil palm.
| Code | Product | Applies from | Deferral | Exclusions | Change since 2023 |
|---|---|---|---|---|---|
| ex 1207 10 00 | Palm nuts and kernels | 2026-12-30 | yes | none | ex and 8 digits added |
| ex 1511 | Palm oil and its fractions, not chemically modified | 2026-12-30 | yes | W | ex and W added |
| ex 1513 21 | Crude palm kernel oil and fractions | 2026-12-30 | yes | W | ex and W added |
| ex 1513 29 | Palm kernel oil and fractions, other than crude | 2026-12-30 | yes | W | ex and W added |
| ex 2306 60 00 | Oilcake and other solid residues of palm nuts or kernels | 2026-12-30 | yes | none | ex and 8 digits added |
| ex 2905 45 | Glycerol, purity 95 % or more, synthesised using oil palm | 2026-12-30 | yes | M | Oil-palm qualifier and M added |
| ex 2915 70 | Palmitic acid, stearic acid, their salts and esters | 2026-12-30 | yes | M | ex, qualifier and M added |
| ex 2915 90 | Saturated acyclic monocarboxylic acids and derivatives | 2026-12-30 | yes | M | ex, qualifier and M added |
| ex 3823 11 00 | Stearic acid, industrial | 2026-12-30 | yes | M | ex, qualifier and M added |
| ex 3823 12 00 | Oleic acid, industrial | 2026-12-30 | yes | M | ex, qualifier and M added |
| ex 3823 19 | Industrial monocarboxylic fatty acids; acid oils from refining | 2026-12-30 | yes | W | ex, qualifier and W added |
| ex 3823 70 00 | Industrial fatty alcohols | 2026-12-30 | yes | none | ex and qualifier added |
| ex 1516 20 | Hydrogenated or inter-esterified palm and palm kernel oils | 2027-12-30 | n/a | M | Added |
| ex 1518 00 | Chemically modified palm oils; inedible fat mixtures | 2027-12-30 | n/a | W | Added |
| ex 1520 00 | Crude glycerol, glycerol waters and lyes produced using oil palm | 2027-12-30 | n/a | none | Added |
| ex 2905 16 | Octanol and isomers | 2027-12-30 | n/a | none | Added |
| ex 2905 17 00 | Lauryl, cetyl and stearyl alcohol | 2027-12-30 | n/a | M | Added |
| ex 2905 19 00 | Other saturated monohydric alcohols | 2027-12-30 | n/a | none | Added |
| ex 2915 39 | Esters of acetic acid (other than those named) | 2027-12-30 | n/a | none | Added |
| ex 2916 15 | Oleic, linoleic, linolenic acids, salts and esters | 2027-12-30 | n/a | none | Added |
| ex 2916 19 10 | Undecenoic acids, salts and esters | 2027-12-30 | n/a | none | Added |
| ex 2921 19 | Acyclic monoamines and derivatives | 2027-12-30 | n/a | M | Added |
| ex 2923 90 00 | Quaternary ammonium salts and hydroxides | 2027-12-30 | n/a | M | Added |
| ex 2924 19 00 | Acyclic amides, carbamates and salts | 2027-12-30 | n/a | M | Added |
| ex 3401 11 00 | Toilet soap in bars, cakes or shapes | 2027-12-30 | n/a | M | Added |
| ex 3401 20 | Soap in other forms | 2027-12-30 | n/a | none | Added |
| ex 3824 99 | Other chemical products and preparations | 2027-12-30 | n/a | M | Added |
| ex 3907 29 | Other polyethers in primary forms | 2027-12-30 | n/a | M | Added |
Oil-palm lines; chemical lines cover only products made using or containing oil palm. Changes date from 2026-09-18.
Rubber: 10 Entries After the 2026 Narrowing
Rubber has 10 entries, from natural rubber (ex 4001) to hard rubber (ex 4017), all applying from 30 December 2026; tyres count only as new tyres, treads and inner tubes.
Note (3) limits the lines to Hevea brasiliensis, so synthetic rubber is out. Gloves and compounds are covered under EUDR and rubber.
| Code | Product | Applies from | Deferral | Exclusions | Change since 2023 |
|---|---|---|---|---|---|
| ex 4001 | Natural rubber and similar natural gums, in primary forms | 2026-12-30 | yes | none | ex added |
| ex 4005 | Compounded rubber, unvulcanised | 2026-12-30 | yes | none | Unchanged |
| ex 4006 | Unvulcanised rubber in other forms and articles | 2026-12-30 | yes | none | Unchanged |
| ex 4007 | Vulcanised rubber thread and cord | 2026-12-30 | yes | none | Unchanged |
| ex 4008 | Plates, sheets, strips, rods and profiles of vulcanised rubber | 2026-12-30 | yes | U | U added |
| ex 4011 | New pneumatic tyres, of rubber | 2026-12-30 | yes | none | Unchanged |
| ex 4012 90 30 | Tyre treads | 2026-12-30 | yes | none | Replaced ex 4012 |
| ex 4013 | Inner tubes, of rubber | 2026-12-30 | yes | none | Unchanged |
| ex 4015 | Apparel and accessories, including gloves, of vulcanised rubber | 2026-12-30 | yes | U | U added |
| ex 4017 | Hard rubber in all forms; articles of hard rubber | 2026-12-30 | yes | W, U | W and U added |
Rubber lines; changes date from 2026-09-18.
Soya: 4 Entries, 1201 90 00 Since 18 September 2026
Soya has 4 entries: soya beans other than for sowing (1201 90 00, since 18 September 2026), flour and meal (1208 10), oil (1507) and oilcake (2304). Crushing and storage chains are covered under EUDR and soya.
| Code | Product | Applies from | Deferral | Exclusions | Change since 2023 |
|---|---|---|---|---|---|
| 1201 90 00 | Soya beans, whether or not broken: other | 2026-12-30 | yes | none | Replaced 1201 (2026-09-18) |
| 1208 10 | Soya bean flour and meal | 2026-12-30 | yes | none | Unchanged |
| 1507 | Soya-bean oil and its fractions, not chemically modified | 2026-12-30 | yes | none | Unchanged |
| 2304 | Oilcake and other solid residues from soya-bean oil extraction | 2026-12-30 | yes | none | Unchanged |
Soya lines, consolidated text.
Wood: 31 Entries From Fuel Wood to Prefabricated Buildings
Wood has 31 entries: the 21 headings ex 4401 to ex 4421, pulp (ex 47), paper (ex 48), six seat lines, one furniture entry and prefabricated buildings. Sawn wood thicker than 6 mm falls under ex 4407, thinner veneer under ex 4408.
Note (4) excludes bamboo and rattan. Species names are covered under EUDR and wood.
| Code | Product | Applies from | Deferral | Exclusions | Change since 2023 |
|---|---|---|---|---|---|
| ex 4401 | Fuel wood, chips, sawdust, wood waste and pellets | 2026-12-30 | no | W, P1 | ex, W and P1 added |
| ex 4402 | Wood charcoal | 2026-12-30 | yes | none | ex added |
| ex 4403 | Wood in the rough | 2026-12-30 | no | U | ex and U added |
| ex 4404 | Hoopwood, split poles, stakes, chipwood | 2026-12-30 | yes | U | ex and U added |
| ex 4405 | Wood wool; wood flour | 2026-12-30 | yes | P1 | ex and P1 added |
| ex 4406 | Railway or tramway sleepers of wood | 2026-12-30 | no | U | ex and U added |
| ex 4407 | Wood sawn or chipped lengthwise, thicker than 6 mm | 2026-12-30 | no | U | ex and U added |
| ex 4408 | Veneer sheets and wood not thicker than 6 mm | 2026-12-30 | no | none | ex added |
| ex 4409 | Wood continuously shaped, including parquet strips | 2026-12-30 | no | U | ex and U added |
| ex 4410 | Particle board, OSB and similar board | 2026-12-30 | no | U | ex and U added |
| ex 4411 | Fibreboard | 2026-12-30 | no | U | ex and U added |
| ex 4412 | Plywood, veneered panels and similar laminated wood | 2026-12-30 | no | U | ex and U added |
| ex 4413 | Densified wood | 2026-12-30 | no | U | ex and U added |
| ex 4414 | Wooden frames for paintings, photographs, mirrors | 2026-12-30 | no | U | ex and U added |
| ex 4415 | Packing cases, crates, drums, pallets, pallet collars | 2026-12-30 | no | U, P1, P2 | ex, U, P1 and P2 added |
| ex 4416 | Casks, barrels, vats and other coopers' products | 2026-12-30 | no | U, P1, P2 | ex, U, P1 and P2 added |
| ex 4417 | Tools, tool handles, brush bodies, shoe lasts | 2026-12-30 | yes | U | ex and U added |
| ex 4418 | Builders' joinery and carpentry of wood | 2026-12-30 | no | U | ex and U added |
| ex 4419 | Tableware and kitchenware, of wood | 2026-12-30 | yes | U | ex and U added |
| ex 4420 | Marquetry, caskets, statuettes, small wooden furniture | 2026-12-30 | yes | U | ex and U added |
| ex 4421 | Other articles of wood | 2026-12-30 | yes | U | ex and U added |
| ex 47 | Pulp of wood | 2026-12-30 | no | U, R | Split from the 2023 pulp and paper entry |
| ex 48 | Paper and paperboard; articles of paper pulp, paper or paperboard | 2026-12-30 | no | W, U, R, P1, P2, C | Split from the 2023 pulp and paper entry |
| ex 9401 31 00 | Swivel seats with variable height adjustment, of wood | 2026-12-30 | yes | U | Replaced ex 9401 |
| ex 9401 41 00 | Seats convertible into beds, of wood | 2026-12-30 | yes | U | Replaced ex 9401 |
| ex 9401 61 00 | Other seats with wooden frames, upholstered | 2026-12-30 | yes | U | Replaced ex 9401 |
| ex 9401 69 00 | Other seats with wooden frames, not upholstered | 2026-12-30 | yes | U | Replaced ex 9401 |
| ex 9401 80 00 | Other seats, of wood | 2026-12-30 | yes | U | Replaced ex 9401 |
| ex 9401 91 90 | Other parts of seats, of wood | 2026-12-30 | yes | U | Replaced ex 9401 |
| ex 9403 30, ex 9403 40, ex 9403 50, ex 9403 60 and ex 9403 91 | Wooden furniture, and parts thereof | 2026-12-30 | no for ex 9403 30 to ex 9403 60; ex 9403 91: Article 38(3) test | U | ex and U added |
| ex 9406 10 00 | Prefabricated buildings of wood | 2026-12-30 | Article 38(3) test | U | Replaced 9406 10; U added |
Wood lines; changes date from 2026-09-18.
Table Notes, Line Exclusions and Exemptions
Annex I carries five table notes, plus line exclusions that apply only where a line states them. Note (5), in force since 18 September 2026, excludes samples of negligible value and quantity and products used up in testing. The introduction excludes goods made entirely from end-of-life material that would otherwise be waste, except by-products. The seven flags mean:
- W: waste under Article 3(1) of Directive 2008/98/EC (9 lines).
- U: used and second-hand products.
- R: recovered (waste and scrap) products.
- P1: single-use packing presented with another product.
- P2: reusable packing, from its first use as packing.
- C: correspondence and marketing materials.
- M: to the extent used for medicinal products (13 oil-palm lines).
"Deferral: yes" marks lines that operators that are natural persons or micro or small undertakings established as such by 31 December 2024 apply from 30 June 2027 (Art. 38(3)); products in the Annex to Regulation (EU) No 995/2010, marked "no", apply from 30 December 2026. "n/a" marks the 2027 additions. The scope of each exclusion is set out under EUDR exemptions.
Annex I Timeline: When Does Each Line Apply?
Each Annex I line applies on one of three dates: 30 December 2026; 30 June 2027 for operators that are natural persons or micro or small undertakings established as such by 31 December 2024 (products in the Annex to Regulation (EU) No 995/2010 from 30 December 2026); or 30 December 2027 for the added lines. Every date is listed on the EUDR timeline.
| Date | Who | Lines | Basis |
|---|---|---|---|
| 2026-12-30 | All operators, downstream operators and traders | 71 lines | Art. 38(2) |
| 2027-06-30 | Operators that are natural persons or micro or small undertakings established as such by 31 December 2024; products in the Annex to Regulation (EU) No 995/2010 from 30 December 2026 | Lines marked "Deferral: yes" | Art. 38(3) |
| 2027-12-30 | All operators | 18 added lines | Annex I as amended by Delegated Regulation (EU) 2026/2102 |
Application dates per line.
The 18 Lines That Apply From 30 December 2027
The 18 lines added by Delegated Regulation (EU) 2026/2102 each carry the words "This provision shall apply from 30 December 2027". They are frozen tongues (ex 0206 21 00), soluble coffee (2101 11 00) and 16 oil-palm lines, from hydrogenated palm oils (ex 1516 20) to palm soap (ex 3401 11 00, ex 3401 20). No wood or rubber line is among them.
EUTR-Annex Products: No Micro or Small Deferral
Operators that are natural persons or micro or small undertakings established as such by 31 December 2024 apply the Regulation from 30 June 2027; products in the Annex to Regulation (EU) No 995/2010 apply from 30 December 2026 (Article 38(3)). The Annex of the EU Timber Regulation (EUTR) decides which wood lines keep the earlier date.
Without deferral: ex 4401, ex 4403, ex 4406 to ex 4416, ex 4418, ex 47, ex 48 and ex 9403 30 to ex 9403 60. With deferral: ex 4402, ex 4404, ex 4405, ex 4417, ex 4419 to ex 4421 and the six seat lines. For ex 9403 91 and ex 9406 10 00, the outcome is not established as of 24 October 2026.
What Changed in Annex I in 2025 and 2026?
Annex I changed twice: Regulation (EU) 2025/2650 deleted printed products from 26 December 2025, and Delegated Regulation (EU) 2026/2102 rewrote the list from 18 September 2026.
| Date in force | Instrument | Line | Change | Reason |
|---|---|---|---|---|
| 2025-12-26 | Regulation (EU) 2025/2650 | ex 49 | Printed products deleted | Art. 1 of 2025/2650 |
| 2026-09-18 | Delegated Regulation (EU) 2026/2102 | ex 4101, ex 4104, ex 4107 | Hides, skins and leather deleted | Recital 5 |
| 2026-09-18 | Delegated Regulation (EU) 2026/2102 | ex 4010, ex 4016 | Belts and other vulcanised articles deleted | Recital 11 |
| 2026-09-18 | Delegated Regulation (EU) 2026/2102 | ex 4012 | Narrowed to ex 4012 90 30 tyre treads; see EUDR and tyres | Recital 10 |
| 2026-09-18 | Delegated Regulation (EU) 2026/2102 | 1201 | Narrowed to 1201 90 00; sowing seed out | Recital 12 |
| 2026-09-18 | Delegated Regulation (EU) 2026/2102 | ex 9401 | Six wooden-seat lines; aircraft and motor-vehicle seats out | Recital 13 |
| 2026-09-18 | Delegated Regulation (EU) 2026/2102 | 0102 21, 0102 29 | Reworded as ex 0102, scope unchanged | Recital 3 |
| 2026-09-18 | Delegated Regulation (EU) 2026/2102 | 18 lines | Added, applying from 2027-12-30 | Recitals 4, 6, 8 |
Annex I changes since 2023.
Regulation (EU) 2025/2650: Printed Products Out Since 26 December 2025
Printed products under ex 49 left Annex I on 26 December 2025, deleted by Article 1 of Regulation (EU) 2025/2650. Its other changes are covered under Regulation (EU) 2025/2650.
Published in OJ L, 2025/2650 on 23 December 2025, the Regulation entered into force three days later. The deleted line, covering books, newspapers and other printed products, never applied to operators.
Chapter 48 paper goods, such as labels and stationery, stay in scope under ex 48. The boundary is explained under EUDR and printed products.
Delegated Regulation (EU) 2026/2102: The EUDR Delegated Act on Product Scope
The EUDR delegated act on product scope is Commission Delegated Regulation (EU) 2026/2102 of 13 July 2026 "as regards the list of relevant commodities and relevant products" (C(2026) 4920), published in OJ L, 2026/2102 on 17 September 2026 and in force since 18 September 2026 (Article 2). Its first footnote cites the EUDR at page 35 of OJ L 150; the correct page is 206.
Its basis is Article 34(1), "to amend Annex I with regard to the relevant CN codes of relevant products", a power conferred for five years from 29 June 2023 and tacitly extended (Article 35(2)). Under Article 35(6), it could enter into force only without objection from Parliament or Council within two months, extendable by two; its entry into force shows that condition was met. A first draft drew 291 responses in April to May 2025; a second followed with COM(2026) 191 on 4 May 2026 for four weeks of feedback. The methodology is set out in SWD(2026) 194 of 13 July 2026.
What Did 2026/2102 Remove: Leather, Belts, Tyres, Seed Soya and Vehicle Seats?
Delegated Regulation (EU) 2026/2102 removed five product groups on 18 September 2026. Hides, skins and leather (ex 4101, ex 4104, ex 4107) went because the leather chain is separate, hides are worth little against meat and EU operators have limited leverage (recital 5); what remains is explained under EUDR and leather.
Belts (ex 4010) and other vulcanised articles (ex 4016) hold little natural rubber (recital 11). Retreaded and used tyres left when ex 4012 was narrowed to tyre treads (recital 10). Soya beans for sowing (1201 10 00) "represent negligible trade volumes" (recital 12). Aircraft (9401 10 00) and motor-vehicle seats (9401 20 00) left too (recital 13).
What Did 2026/2102 Add: Soluble Coffee, Frozen Tongues and Palm Derivatives?
Delegated Regulation (EU) 2026/2102 added 18 lines: 1 cattle, 1 coffee and 16 oil-palm lines. Frozen tongues joined fresh tongues, already under ex 0206 10 (recital 4). Excluding soluble coffee "may result in the relocation rather than the elimination of the deforestation risk" (recital 6), and the same relocation risk brought in oleochemicals (recital 8). The medicinal carve-out of recital 9 is use-based. The 16 lines are explained under palm oil derivatives.
What Else Did 2026/2102 Change in the Wording?
Delegated Regulation (EU) 2026/2102 also reworded lines without changing the products covered. "0102 21, 0102 29" became "ex 0102" (recital 3), and notes (1) to (5) were inserted. The 2023 entry "Pulp and paper of Chapters 47 and 48" was split into ex 47 and ex 48, and waste and used-goods wording avoids "discouraging circular and resource efficient practices" (recital 14).
How to Run an Annex I Scope Check
This guide orders the Annex I check in four questions; the Regulation prescribes no checklist. The four questions are listed below.
- Is the code listed? Match the CN code against the 89 entries.
- Is the species covered? Notes (1) to (4) exclude buffalo, bison, babassu, synthetic rubber, bamboo and rattan.
- Does an exclusion apply? Only that line's flags and note (5) count.
- From when? The line's date applies, and products produced before 29 June 2023 are out (Article 1(2)), except EUTR timber under Article 37(3).
The same questions run in the EUDR Scope Checker.
Every code on this page is checked against the consolidated text of Regulation (EU) 2023/1115 of 18 September 2026; see our methodology and fact-checking.
This guide explains the rules; it is not legal advice for an individual case.
How Does Annex I Connect to Regulation (EU) 2023/1115, the Commodities and Due Diligence?
Annex I decides which products the articles of the Regulation apply to. Every article is mapped under Regulation (EU) 2023/1115.
Each line belongs to one of the seven EUDR commodities.
Once a line is listed and its date reached, starting with 30 December 2026, EUDR due diligence applies.
Annex I Codes in the Due Diligence Statement
Annex II, point 2 asks for the "Harmonised System code, free-text description" and quantity of each relevant product. That code comes from the Annex I line, as point 2 of the due diligence statement shows.
Is the EUDR Delayed Again?
No: no further delay is proposed as of 24 October 2026, and the 18 added lines keep 30 December 2027. Earlier postponements are recorded under EUDR delay.
EUDR Annex I FAQ
Six further questions follow. More answers are in the EUDR FAQ.
Where Is the Official Text of Annex I Published?
Annex I is published in the consolidated text of Regulation (EU) 2023/1115 dated 18 September 2026 (02023R1115-20260918) on EUR-Lex. The consolidated text marks the amending acts as M1 (2024/3234), M2 (2025/2650) and M3 (2026/2102).
Can a Delegated Act Add a New Commodity to Annex I?
No: Article 34(1) empowers the Commission to amend Annex I only "with regard to the relevant CN codes of relevant products"; the seven commodities are defined in Article 2(1). Products of those commodities can be added or deleted, as 2026/2102 did.
Will Leather Return to Annex I?
Not without a review: recital 2 of Delegated Regulation (EU) 2026/2102 places hides, skins and leather in the general review due by 30 June 2030 (Article 34(2)). The Commission continues to monitor the leather chain meanwhile.
Does the Commission FAQ Still Call 2026/2102 a Draft?
Yes: FAQ Version 5 (April 2026) still describes the samples, used-goods and correspondence exclusions as a draft delegated act; they are law since 18 September 2026. Current versions are indexed under Commission guidance and FAQ.
Do I Need Software or a Consultant to Classify Products?
No: the only mandatory IT is the free EUDR Information System (Implementing Regulation (EU) 2024/3084, Article 18(1)), and responsibility stays with the operator. No approved EUDR software or provider exists.
Does Certification Replace the Annex I Check?
No: no EUDR certificate exists, and a scheme certificate is only complementary information under Article 10(2)(n). What schemes prove is set out under certification and the EUDR.
Sources
- EUR-Lex: CELEX 02023R1115
- EUR-Lex: CELEX 32023R1115
- EUR-Lex: Delegated Regulation (EU) 2026/2102
- EUR-Lex: Regulation (EU) 2025/2650
- European Commission, Environment: environment.ec.europa.eu/publications/faq-eudr-implementation_en
- EUR-Lex: eur-lex.europa.eu/eli/C/2026/3896/oj/eng
- EUR-Lex: CELEX 52026DC0191
- EUR-Lex: CELEX 52026SC0194
- EUR-Lex: Implementing Regulation (EU) 2024/3084