Latest EUDR Delegated Act: Is Your Product Still in Scope?

The latest EUDR delegated act, adopted by the European Commission on 13 July 2026, does not change the seven covered commodities or the 30 December 2026 start date. It rewrites Annex I the product-by-product list of HS/CN codes that decides scope. Soluble coffee and a wide set of palm oil derivatives are added; cattle leather, most of a retreaded tyre, and several rubber and vehicle products are removed; and waste, samples, and packaging exemptions are confirmed. Newly added products get until 30 December 2027. The act is adopted but not yet final it is still in Parliament/Council scrutiny and not yet published in the Official Journal.

Key takeaways

• The latest EUDR delegated act reshapes Annex I only the seven commodities (cattle, cocoa, coffee, palm oil, rubber, soya, wood) and the enforcement dates are unchanged.
• Added to scope: soluble coffee (CN 2101 11 00), frozen cattle tongues (CN ex 0206 21 00), and palm oil oleochemicals plus soap made using oil palm.
• Removed from scope: cattle hides, skins and leather (CN 4101, 4104, 4107), retreaded tyres beyond the new tread (CN ex 4012 90 30), soybeans for sowing, articles of vulcanised rubber, conveyor and transmission belts, and aircraft and vehicle seats.
• Two clocks now run: existing in-scope products apply from 30 December 2026; newly added products apply from 30 December 2027.
• Scope now depends on the commodity actually used (the “ex” prefix) and on species (Bos, Elaeis, Hevea) it is a data-lineage question, not a product-name lookup.
• The act is adopted but not yet in force treat the new scope as provisional until it appears in the Official Journal.

The latest EUDR delegated act, adopted on 13 July 2026, has quietly changed which of your products the EU Deforestation Regulation actually covers without touching the regulation itself. The EUDR (Regulation (EU) 2023/1115) is the law that requires companies to prove goods are deforestation-free before placing them on, or exporting them from, the EU market. What the delegated act does is amend Annex I the list that spells out, HS code by HS code, exactly which goods fall under the rules. Change that list and you change real obligations, even though the headline regulation is untouched. For most compliance teams it reduces to a single question: is your product still on the list?

What the latest EUDR delegated act actually changes

The latest EUDR delegated act keeps the seven relevant commodities exactly as they were: cattle, cocoa, coffee, oil palm, rubber, soya and wood. It does not reopen the regulation and it does not move any deadline. Instead it rewrites the product list underneath those commodities. Because Annex I is expressed in Combined Nomenclature (CN) customs codes, a single code moving on or off the list can pull an entire category of goods into or out of due diligence regardless of what the product is called on your invoice.

The change is the final piece of the Commission’s EUDR simplification package first published on 4 May 2026. The draft was open for public feedback until 1 June 2026; the version adopted on 13 July 2026 keeps the draft’s additions and removes more products than the draft did, following that feedback. It was adopted together with an implementing act updating the EUDR Information System. Crucially, the act still has to clear a Parliament and Council scrutiny period before it can be published in the Official Journal and take effect.

The Commission estimates the wider simplification package could cut affected companies’ annual compliance costs by roughly ~75% against the original design, with environmental benefits of around ~€7bn per year figures worth watching, because they frame every removal as relief and every addition as a manageable exception.

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Which products the latest EUDR delegated act adds

The additions share one logic: each is made from a commodity already covered, but sat outside the list leaving a gap where deforestation risk could quietly relocate downstream. The latest EUDR delegated act closes those gaps.

• Soluble coffee (CN 2101 11 00) — extracts, essences and concentrates of coffee now join green and roasted beans. Same plant, same risk, previously outside scope.
• Frozen cattle tongues (CN ex 0206 21 00) — added to match the fresh tongues already covered, removing an odd fresh-in / frozen-out split.
• Palm oil oleochemicals and soap — the largest block of additions: fatty acids, fatty alcohols, glycerol and related derivatives made using oil palm, plus soap containing palm oil. This lands hardest on chemicals, cosmetics, detergent and food-ingredient firms, where the finished product name says nothing about the palm-oil feedstock inside it.
• A carve-out matters here: palm oil derivatives used to manufacture medicinal products for human or veterinary use are excluded, as are certain palm oil derivatives used as feedstock for biofuels.

Which products the latest EUDR delegated act removes

The removals run the other way products where the compliance effort was judged disproportionate to the deforestation benefit. Under the latest EUDR delegated act, the notable exits are:

• Cattle leather — raw, tanned and further-prepared hides and skins (CN 4101, 4104, 4107) are deleted. Leather is a low-value by-product of the meat trade, and finished-leather buyers have little leverage to extract reliable origin data from suppliers far up the chain. The Commission has flagged it will revisit leather in the 2030 general review.
• Retreaded tyres — only the new rubber tread stays in scope (CN ex 4012 90 30); the used casing does not, rewarding circular reuse.
• Vulcanised rubber goods — conveyor and transmission belts and other articles of vulcanised rubber (CN 4010, 4016) leave, on the basis of low natural-rubber content.
• Soybeans for sowing (CN moved to 1201 90 00) and aircraft / motor-vehicle seats (carved out of CN ex 9401) also come out.
• A word of caution the celebratory coverage skips: a removal is not a delete-and-forget. Removed categories still need a documented rationale for standing controls down and, until the act is published in the Official Journal, they are not legally out yet.

Latest EUDR delegated act: what is exempt and clarified

Beyond adds and removes, the latest EUDR delegated act settles several grey areas that have caused real confusion for operators:

• Waste, used and second-hand goods — anything qualifying as waste under the EU Waste Framework Directive, plus used and second-hand products, is confirmed outside scope, so repair, reuse and recycling are not penalised.
• Samples and testing products — goods used up or destroyed in analysis, examination or testing are exempt.
• Packaging — single-use and reusable packaging that merely carries another product is out; packaging sold as a product in its own right stays in.
• Marketing materials and correspondence — labels and information materials accompanying a product, and items of correspondence, are excluded.
• Species and the “ex” prefix — cattle means the Bos genus; oil palm means Elaeis; rubber means Hevea. Bamboo, rattan, reeds and lime bark sit outside wood. Where an entry carries “ex”, it applies only when a covered commodity was actually used.

Our take: the latest EUDR delegated act turns scope into a versioned dataset

Here is the part most “what changed” summaries miss. The latest EUDR delegated act is being read as relief a shorter list, a lighter load. But look at the mechanics and a different story appears: scope is no longer a one-time checklist. It is a living, version-controlled dataset.

Consider the evidence. Annex I has now moved twice in eight months, while the 30 December 2026 deadline has not moved once. The act is adopted but not final, so the “answer” to whether a product is in scope is provisional. And the two-clock structure existing products from 30 December 2026, newly added products from 30 December 2027 means the same supplier programme now carries two live compliance dates at the same time. Relief on paper; more state to track in practice.

The deeper shift is that the “ex” prefix and the species definitions turn scope into a data-lineage question. Whether CN ex 0206 21 00 or a palm oil derivative is in scope no longer depends on the product name on the label, it depends on which commodity, and which species, was actually used to make it. You cannot answer that from a spreadsheet of finished-good descriptions. You answer it from traceable origin data linked to each SKU and its HS code.

That is why the winners will not treat the latest EUDR delegated act as a memo to read once. They will treat product-to-HS-code mapping as governed data: versioned, timestamped, and auditable, so that when Annex I moves a third time and it will, with a general review due in 2030 they can show exactly what they concluded, when, and why. And because the same origin and supplier data also feeds CSDDD, CSRD and packaging rules, the smart move is to build it once, in one data layer, rather than rebuild it every time a delegated act lands.

How TraceX Helps

As EUDR product scope evolves, businesses need more than a one-time HS/CN code check. TraceX EUDR solutions help enterprises connect product classification with supplier and farm traceability, validated GeoJSON data, satellite-backed deforestation risk assessments, legality documentation, and automated DDS workflows with EU TRACES integration. This enables businesses to identify in-scope supply chains, maintain audit-ready evidence, and adapt their compliance processes as regulatory requirements change.

Latest EUDR delegated act: manual scope tracking vs. TraceX

Latest EUDR delegated act: a buyer readiness checklist

Use this to decide whether the latest EUDR delegated act changes anything for you before your next filing cycle:

• Re-run product scoping against the amended Annex I focus on derived products and feedstocks, not finished-product names.
• Flag anything newly in scope (soluble coffee, palm oil oleochemicals, soap, frozen cattle tongues) and start supplier engagement now against the 30 December 2027 date.
• For removed categories (leather, retreaded tyres, vulcanised rubber, sowing soybeans, vehicle seats), document the stand-down rationale but keep collecting data until Official Journal publication.
• Confirm species and “ex” logic for borderline products is the feedstock actually Bos, Elaeis or Hevea?
• Record the scope decision with a date and source, so you can show your reasoning when Annex I moves again.
• Connect the same origin/supplier data to your CSDDD, CSRD and packaging obligations to avoid rebuilding it per regulation.

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