EUDR HSN Codes: Is Your Product In Scope After the 2026 Delegated Act?

EUDR HSN codes are the Combined Nomenclature (CN/HS) customs codes listed in Annex I of the EU Deforestation Regulation (Regulation (EU) 2023/1115) that decide whether your product needs a Due Diligence Statement (DDS). If your code sits in Annex I and the product contains a regulated commodity, EUDR applies however finished the product looks. The Commission’s delegated act adopted on 13 July 2026 reshaped the list: cattle leather came out, while soluble coffee and a range of palm oil derivatives went in. Getting your EUDR HSN codes right is the trigger for geolocation, deforestation-free proof, and EU market access.

Key takeaways

• Your EUDR HSN codes not your product name decide whether the regulation applies and whether you must file a DDS.
• The 13 July 2026 delegated act amended Annex I: 17 codes added, 3 deleted (incl. cattle leather HS 4101/4104/4107), 1 clarified. Provisional until Official Journal publication.
• A mismatch between the code on your DDS and the code on your customs declaration is one of the most common rejection triggers.
• Deadlines: 30 December 2026 (large/medium) and 30 June 2027 (micro/small non-timber). Deforestation cut-off: 31 December 2020.

Why the wrong EUDR HSN code strands your container

• The code, not the product name, is what customs reads first.
• Scope is tied to the Annex I code a finished good can be just as in-scope as the raw commodity.
• If the DDS code and the customs-declaration code don’t match, the shipment gets held.

Picture a rubber processor shipping industrial rubber sheet under HS 4008, certain that only tyres mattered. Customs flags the container, the DDS on file covers a different code, and weeks of demurrage follow. That is what wrong EUDR HSN codes cost not a paperwork slap, but stranded inventory and a nervous buyer. The trap is assuming a finished good is safe: a chocolate bar (HS 1806) or a wooden chair can be as in-scope as a raw bean or log. If you cannot line up your EUDR HSN codes against Annex I with confidence, every shipment is a coin toss at the border.

Which Commodities Are Covered by EUDR?

Coffee, cocoa, rubber, palm oil, soy, cattle and wood are at the heart of the EUDR but knowing the commodity is only the first step. Product classification, Annex I and the relevant HSN/CN code determine whether a specific product falls within scope.

Read our complete guide to EUDR Commodities and understand what is and isn’t covered.

EUDR HSN codes by commodity (updated for the 2026 delegated act)

Here are the EUDR HSN codes that matter, commodity by commodity. HS is the 6-digit global base; the EU’s Combined Nomenclature (CN) and 10-digit TARIC extend it. Cross-check every code with your customs broker the table is a starting point, not legal advice.

What the 13 July 2026 delegated act changed

The Commission adopted this delegated act under Article 34(1), alongside Implementing Regulation (EU) 2026/1565. It rewrites Annex I without reopening the EUDR itself. Re-scope your EUDR HSN codes against the final text once it is published in the Official Journal until then, treat the changes below as adopted-but-provisional.

How correct EUDR HSN codes map to your DDS and customs declaration

Once your EUDR HSN codes are confirmed, compliance becomes a finite workflow instead of a border gamble: tag the batch to the right code, attach plot-level geolocation, file the DDS in EU TRACES, and carry the DDS reference onto the customs declaration. Every link keys off the code.

1. Classify: map each SKU to its Annex I code (and any “ex” subset) before you ship.
2. Link: attach GPS polygons and legality docs to the coded batch.
3. File & reference: submit the DDS, then quote its reference number on the customs declaration so the code, product and proof line up.

EUDR HSN codes and the 2026–2027 compliance timeline

Scope changes don’t move the clock. Your EUDR HSN codes decide obligations from these dates :

• 30 December 2026 — large and medium operators and traders.
• 30 June 2027 — natural persons and micro/small non-timber operators.
• 31 December 2020 — deforestation cut-off; land cleared after this date makes the product non-compliant.
• Penalties — fines up to 4% of EU-wide annual turnover, goods seizure, and loss of market access.

EUDR HSN codes are a data problem disguised as a customs problem. Annex I will keep moving through delegated acts, so a one-time spreadsheet of codes goes stale fast. Companies that stay audit-ready hold their code-to-commodity-to-geolocation mapping in one data layer that updates when the scope does not fifteen static files.

How TraceX Helps You Navigate EUDR HSN Codes

With the 2026 Delegated Act updating EUDR Annex I, determining whether a product is in scope requires more than simply identifying its commodity. The relevant CN/HS code and the specific product classification need to be assessed against the updated scope.

TraceX EUDR Solutions helps businesses operationalize this process by enabling teams to identify and classify products, map them against EUDR scope requirements, and connect applicable products to the relevant supplier, commodity and traceability data. From HSN/CN-code assessment and product-scope identification to supplier onboarding, geolocation, deforestation-risk assessment and DDS workflows, TraceX brings the compliance journey into one connected platform.

This is particularly valuable as the 2026 changes have both removed certain products from scope and added new derived products, making periodic scope reviews essential.

In short: know your code, know your scope, and know what evidence you need. TraceX helps you turn that assessment into an operational EUDR workflow.

How to pressure-test a solution against your EUDR HSN codes

Before you buy any EUDR tool, test it against your real EUDR HSN codes:

• Does it map every SKU to its Annex I code, including “ex” subsets, and re-scope automatically when a delegated act changes the list?
• Did it already reflect the 13 July 2026 changes (leather out; soluble coffee, palm oil derivatives, frozen tongues in)?
• Can it attach GPS polygon geolocation and legality docs to each coded batch (cut-off 31 Dec 2020)?
• Does it generate a TRACES-ready DDS and carry the reference onto the customs declaration for the same code?
• Does it flag a mismatch between declared code and DDS code before the shipment moves?
• Does it reuse one data layer across EUDR and adjacent regulations you face (e.g. CSDDD)?

Frequently Asked Questions