Does the EUDR apply to my product?
Your product is caught by the EU Deforestation Regulation if it contains, was fed with, or was made using one of seven commodities — cattle, cocoa, coffee, oil palm, rubber, soya or wood — and its customs code appears in Annex I of Regulation (EU) 2023/1115. [Reg. 2023/1115, Art. 1 & Annex I]
If neither the commodity nor the Annex I code matches, the product is out of scope. A few borderline products (leather, retreaded tyres, soluble coffee, certain palm derivatives) sit under a pending scope change — treat those as "in, but watch".
The seven commodities
The regulation applies to these seven "relevant commodities" and to the "relevant products" derived from them. [Reg. 2023/1115, Art. 2(1)] If your product has nothing to do with any of the seven, you can stop here — it is out of scope.
- Cattle — beef, live cattle, hides and leather.
- Cocoa — beans, paste, butter, powder and chocolate.
- Coffee — green and roasted beans.
- Oil palm — palm oil and palm-kernel derivatives.
- Rubber — natural rubber, tyres and rubber products.
- Soya — soybeans, meal and oil.
- Wood — timber, paper, pulp, charcoal and furniture.
The Annex I test: it's the HS/CN code that decides
Being made from a listed commodity is necessary but not sufficient. The precise list of products in scope is defined by Harmonised System / Combined Nomenclature codes in Annex I of the regulation. [Reg. 2023/1115, Annex I] A product is only caught if its customs code is on that list.
To check: find your product's HS/CN code (the same code your freight forwarder or customs broker uses on the import declaration), then look it up in Annex I. Examples of codes that are listed:
| Product | Commodity | Typical HS heading | Scope |
|---|---|---|---|
| Roasted coffee | Coffee | 0901 | In scope |
| Chocolate bar | Cocoa | 1806 | In scope |
| Wooden furniture | Wood | 9403 | In scope |
| Paper & paperboard | Wood | 4801–4823 | In scope |
| Natural-rubber tyres | Rubber | 4011 | In scope |
| Cotton tote bag | — | — | Out of scope |
Cotton, cut flowers, cane sugar and countless other agricultural goods are simply not among the seven commodities — they are out of scope no matter how they were grown.
Products "in scope, under revision"
The Annex I list is not frozen. A draft delegated act on Annex I scope was pending as at 9 July 2026: it proposes adding soluble/instant coffee and certain palm-oil derivatives (such as some soaps), and removing leather and retreaded tyres. [Commission EUDR implementation page] Printed products were already removed from Annex I by the December 2025 amendment. [Reg. 2025/2650, recitals]
What "in scope" actually obliges you to do
In scope does not automatically mean you must file paperwork. It means the product cannot be placed on or exported from the EU market unless it is deforestation-free (produced on land not deforested or degraded after 31 December 2020), produced legally, and covered by a Due Diligence Statement. [Reg. 2023/1115, Art. 3] Who files that statement depends on your role in the supply chain — see the operator-vs-trader guide below.
General information about Regulation (EU) 2023/1115, not legal advice — and not a deforestation assessment. This kind of screening determines your scope, role, deadline and documentary obligations; it does not verify that any plot of land is deforestation-free. Confirm your classification with counsel before relying on it for a market-access decision.
Find out where you actually stand
You don't need a traceability platform to start — you need to know your position and exactly what to ask your suppliers for. The EUDR position report screens your products against Regulation (EU) 2023/1115, names your role and deadline, tiers your origin countries, and hands you ready-to-send supplier data-request letters.
Check if my product is caught → get my EUDR position reportQuestions
Is cotton or sugar covered by the EUDR?
No. The EUDR covers only seven commodities — cattle, cocoa, coffee, oil palm, rubber, soya and wood — and products derived from them and listed in Annex I of Regulation (EU) 2023/1115. Cotton, sugar and cut flowers are not among them, so they are out of scope.
How do I find my product's HS code for the Annex I check?
Use the same Harmonised System / Combined Nomenclature code that appears on your customs import declaration — your freight forwarder or customs broker will know it. Then look that code up in Annex I of Regulation (EU) 2023/1115. If the code is listed and the product derives from one of the seven commodities, it is in scope.
Is leather still in scope?
As at 9 July 2026, yes — leather is a cattle-derived product covered by Annex I. However, a draft delegated act was pending that proposes removing leather (and retreaded tyres) from scope. Treat leather as in scope today but flagged for a possible change.
Does a small amount of a commodity in my product still trigger the rules?
If the product falls under an Annex I code and contains, was fed with, or was made using a relevant commodity, it is in scope regardless of the proportion. The Annex I code is the deciding test, not the percentage.
Sources
- Regulation (EU) 2023/1115 (EU Deforestation Regulation) — https://eur-lex.europa.eu/eli/reg/2023/1115/oj — Art. 1 (scope), Art. 2(1) (seven commodities), Art. 3 (prohibition), Annex I (product list by HS code).
- Regulation (EU) 2025/2650 (amending 2023/1115; dates of application and downstream obligations) — https://eur-lex.europa.eu/eli/reg/2025/2650/oj — removal of printed products; pending Annex I changes.
- European Commission — EUDR implementation, guidance & FAQ — https://green-business.ec.europa.eu/deforestation-regulation-implementation_en