EUDR Product Scope Updated: Products Added, Removed and Exempted

The EU has changed the list of products covered by the EU Deforestation Regulation (EUDR). Commission Delegated Regulation (EU) 2026/2102 was published on 17 September 2026 and entered into force the following day.

The amendment matters because EUDR coverage depends on the product entries in Annex I, not simply on whether a product contains wood, rubber, palm oil or another relevant commodity. The revised Annex removes several product groups, adds others and clarifies exclusions for specific uses.

Products removed from the scope

The amendment removes the following entries or product categories:

• Cattle hides, skins and leather covered by the specified entries.
• Retreaded tyres, while new rubber treads remain covered.
• Conveyor and transmission belts of vulcanised rubber under the former entry ex 4010.
• Other articles of vulcanised rubber covered by the former entry ex 4016.
• Soya beans for sowing.
• Aircraft and motor vehicle seats.

These are changes to specific product entries, not exemptions for the entire cattle, rubber, soya or wood supply chains. Other products made from those commodities remain covered where they are listed in Annex I.

Products added from December 2027

The revised Annex adds coffee extracts, essences and concentrates, including soluble coffee, as well as frozen cattle tongues and a range of additional palm oil derivatives.

The palm oil additions extend beyond food products. They include specified fatty alcohols, acids and derivatives, soaps and certain chemical preparations and polyethers. Coverage depends on both the relevant tariff entry and whether the product contains, or has been made using, oil palm.

The newly added product entries apply from 30 December 2027. This later date gives businesses time to prepare for the extension of the scope; it does not postpone the requirements for products already covered by the EUDR.

Exclusions and clarifications

The amendment also clarifies the treatment of waste, used and second-hand products under specified entries. These exclusions must be checked against the wording of the relevant entry rather than treated as a general exemption for all recovered or recycled materials.

Packing materials and containers used to support, protect or carry another product are distinguished from packaging placed on the market as a product in its own right. The latter can still fall within the EUDR. The amendment also addresses reusable packaging once it has been used to carry another product.

Further exclusions cover qualifying samples and products used for examination, analysis or testing, subject to conditions. Certain product entries also exclude use in the manufacture of human or veterinary medicinal products.

The revised wording clarifies the commodity origin of several products. For example, the rubber entries concern rubber from Hevea brasiliensis, not synthetic rubber, while specified palm-derived chemical entries apply only where oil palm has been used.

What companies should review

Companies that have already mapped their products against the original Annex I should revisit that assessment. The changes can remove products from an existing compliance programme or bring additional products into scope from December 2027.

For chemical suppliers in particular, a tariff code alone may not settle the question. Information about the feedstock used to manufacture a substance or preparation can also be needed to establish whether a palm-derived product falls within the revised entry.

The amendment is already in force. It is not a draft or a consultation proposal.

Source: Commission Delegated Regulation (EU) 2026/2102 amending the EUDR product list , published in the Official Journal on 17 September 2026.