Reading Annex I: is your product even in EUDR scope?

A chocolate bar is covered by the EU Deforestation Regulation (EUDR). The package of cocoa cookies on the same shelf is not. The bar is classified under customs heading 1806, which appears in Annex I of Regulation (EU) 2023/1115; the cookies fall under heading 1905, which does not. That is the whole mechanism: Annex I is a closed list of customs codes, and a product whose code is not on it sits outside the regulation, whatever its recipe.

For a retailer or wholesaler with thousands of references, answering "are we concerned?" means sorting the catalog line by line, and the sort is worth doing now. The regulation applies from December 30, 2026 for large and medium-sized companies, and from June 30, 2027 for micro and small enterprises, following the postponement adopted in December 2025.

Seven commodities, but a closed list of products

The EUDR targets cattle, cocoa, coffee, oil palm, rubber, soy ("soya" in the regulation's spelling), and wood, and the products that contain them, were fed with them, or were made using them. But only the products listed in Annex I, identified by their codes in the EU's Combined Nomenclature (CN), carry obligations.

For a distribution business, the in-scope column is longer than expected: coffee (0901, green or roasted), chocolate (1806), soybean oil (1507), wooden furniture (9403 subheadings) and wooden seats (ex 9401), charcoal (4402), wooden pallets and packing cases (4415), pulp, paper, and cardboard (Chapters 47 and 48), new tires (ex 4011), and, as the list stands today, cattle hides and leather (4101, 4104, 4107).

The out-of-scope column is just as instructive, because it contradicts intuition. Milk and cheese are out: dairy is not listed under cattle. Cocoa cookies (1905), coffee-based drinks (2202 99), and soluble coffee (2101) are out. Printed books, newspapers, and other products of the printing industry are out too: the December 2025 revision, Regulation (EU) 2025/2650, deleted them from Annex I, while paper and cardboard themselves stay in. Margarine made from palm oil is out, and so is soap, even though industrial fatty acids and glycerol of 95% purity or more, upstream of both, are in. Leather shoes and handbags are out, while the raw hide they came from is in. A car is out even though its tires, sold separately, would be in.

The regulation sets no floor either. There is no volume or value threshold: a single box of relevant product placed on the market triggers the obligations.

The customs code of the finished product settles the question

Two refinements matter when reading the list.

First, the "ex" prefix. It means only the extract of that heading made of the relevant commodity is covered. Heading 9401 includes seats of metal and plastic; only the wooden ones are in scope. Heading 0201 covers fresh bovine meat; the regulation reaches meat of cattle, not bison or buffalo. Bamboo is not wood under the regulation, so purely bamboo products are out, and the bamboo components of a mixed product carry no due diligence. Likewise, for a tire made from a blend, due diligence covers only the natural rubber share, not the synthetic.

Second, time. The regulation does not apply to relevant products produced before June 29, 2023, its date of entry into force, a useful boundary for slow-rotation stock.

Good to know: the CN code you need is already in your import declarations. Starting the sort from customs data, rather than from commercial product descriptions, saves a round of guesswork and gives every conclusion a defensible anchor.

Packaging follows its own rule

Annex I itself carves out the case that worries logistics teams most. Heading 4415 covers pallets, cases, and crates of wood, but explicitly excludes "packing material used exclusively as packing material to support, protect or carry another product."

The European Commission's FAQ (version 5, April 2026) draws the practical line. Packaging placed on the market as a product in its own right, an empty pallet sold by a pallet maker, boxes bought by the thousand from a converter, is in scope. The same pallet carrying your goods is not, and whether it appears on the invoice next to the merchandise is irrelevant: what counts is whether customs would classify it jointly with the product it carries. Once packaging has served, its resale or rental as used packaging is also outside the scope.

Recycled material has its own carve-out. A product made entirely from material that has completed its lifecycle and would otherwise have been discarded as waste is exempt. But most recycled cardboard contains a share of virgin fiber to strengthen it, and that share is enough to bring the product back into scope, with the virgin material to be traced.

An out-of-scope conclusion deserves a paper trail too

The Commission is explicit that no documentation is required for products outside Annex I. Your buyers will be less accommodating: expect the question "why is this reference not covered?" in the next round of supplier questionnaires, and expect it again from a control authority checking that your sort was done honestly.

A classification file answers it. For each product family: the CN code, taken from customs declarations; the Annex I line it matches or fails to match, "ex" reading included; the date of the check; and the version of the reference you used. For a genuinely doubtful classification, a Binding Tariff Information decision from customs settles the code for three years.

The file needs a review trigger, because the list is moving. A draft delegated act published on May 4, 2026, with feedback open until June 1, 2026, proposes adding soluble coffee and certain palm oil derivatives such as soap, removing cattle hides and leather, and formally excluding samples, items of correspondence, second-hand products, and retreaded tires. None of it is law until the act is adopted and published, so today's sort must apply today's annex, with a note of what may change.

Start with your customs data: extract the CN codes, mark each reference in or out against Annex I, and date the conclusion. Then put a watch on the delegated act, because some of these answers may change within the year, in both directions.

FAQ

Is a product containing palm oil automatically covered by the EUDR?

No. A product is covered only if its customs code appears in Annex I of Regulation (EU) 2023/1115. Palm oil itself, palm kernel oil, and industrial fatty acids are listed, but margarine and soap made from palm oil are not, so they carry no EUDR obligations as the list stands in May 2026.

Are wooden pallets and cardboard boxes in EUDR scope?

Only when they are placed on the market as products in their own right, for example empty pallets sold by a manufacturer. Packaging used exclusively to support, protect, or carry another product is excluded, and so is the resale of packaging that has already been used.

Is 100% recycled paper or cardboard covered?

No. Products made entirely from material that has completed its lifecycle and would otherwise have been discarded as waste are exempt. If the product contains any virgin fiber, it falls back into scope and the virgin share must be traced to its plot of origin.

When does the EUDR start to apply?

From December 30, 2026 for large and medium-sized companies, and from June 30, 2027 for micro and small enterprises, following the one-year postponement adopted in December 2025. Products produced before June 29, 2023 are outside the scope.