Which Products and Commodities Are Covered by EUDR?

How the EUDR defines scope

The EUDR applies to seven commodity groups and a detailed list of derived products set out in Annex I of Regulation (EU) 2023/1115. The regulation uses the EU's Combined Nomenclature (CN) codes — the same classification system used for customs declarations — to define precisely which products are covered.

The scope is deliberately broad. The regulation covers not just raw commodities but also products that contain, were fed with, or were made using the regulated commodities. This "contains, fed with, or made using" test is the key principle for determining whether a product falls within scope. If any regulated commodity was used at any stage of the product's production — as an ingredient, a raw material, or an input to the production process — the final product may be covered.

It is important to note that the EUDR covers products regardless of their country of origin. Whether the commodity was produced in Brazil, Indonesia, the Democratic Republic of Congo, or within the EU itself, the same rules apply.

The seven commodity groups

Below is a detailed breakdown of each commodity group, including the types of derived products covered and examples of CN codes referenced in Annex I.

1. Cattle (bovine animals)

The cattle commodity group covers live bovine animals and a wide range of products derived from them. This is one of the most expansive categories in terms of derived products, because cattle supply chains produce both food and non-food outputs.

What is covered:

• Live bovine animals (CN 0102)
• Beef and veal — fresh, chilled, or frozen (CN 0201, 0202)
• Edible offal (CN 0206)
• Processed and preserved meat (CN 1602)
• Leather and hides — raw hides and skins (CN 4101), tanned or crust hides (CN 4104), and finished leather products
• Leather goods including handbags, suitcases, belts, and footwear uppers
• Tallow and other rendered animal fats used in industrial applications

Surprising inclusions: Many fashion and luxury goods companies do not immediately associate their products with deforestation regulation. However, if your leather goods use bovine leather, the EUDR applies. This includes high-end handbags, shoes, car interiors, and furniture upholstery. The connection between cattle ranching and deforestation — particularly in the Amazon and Cerrado biomes — is one of the primary drivers behind the regulation.

2. Cocoa

The cocoa commodity group covers cocoa beans and the extensive range of products manufactured from them. Cocoa supply chains are particularly complex because cocoa beans undergo multiple processing stages before reaching the consumer.

What is covered:

• Cocoa beans, whole or broken, raw or roasted (CN 1801)
• Cocoa shells, husks, skins, and waste (CN 1802)
• Cocoa paste, whether or not defatted (CN 1803)
• Cocoa butter, fat, and oil (CN 1804)
• Cocoa powder, not containing added sugar (CN 1805)
• Chocolate and chocolate products — including chocolate bars, pralines, chocolate coatings, drinking chocolate, and chocolate-flavoured confectionery (CN 1806)

Surprising inclusions: The scope extends well beyond what most people think of as "cocoa products." If your food product contains cocoa butter as an ingredient — even in small quantities — it may be in scope. This affects biscuit manufacturers, ice cream producers, bakeries, and cosmetics companies that use cocoa butter in their formulations.

3. Coffee

The coffee commodity group covers coffee in all its forms, from green beans to roasted and processed products.

What is covered:

• Coffee beans — not roasted, not decaffeinated (CN 0901 11)
• Coffee beans — not roasted, decaffeinated (CN 0901 12)
• Roasted coffee — not decaffeinated (CN 0901 21)
• Roasted coffee — decaffeinated (CN 0901 22)
• Coffee husks and skins (CN 0901 90)
• Coffee substitutes containing coffee (CN 0901 90)
• Extracts, essences, and concentrates of coffee (CN 2101 11)
• Preparations with a basis of coffee extracts (CN 2101 12)

Surprising inclusions: Instant coffee, coffee capsules, coffee-flavoured syrups, and ready-to-drink coffee beverages all fall within scope. If your product contains coffee extract as an ingredient — for example, a coffee-flavoured dessert or energy drink — you should check whether it is covered under Annex I.

4. Oil palm

The oil palm commodity group is one of the most far-reaching in terms of derived products, because palm oil and its derivatives are used as ingredients in an enormous range of consumer and industrial products.

What is covered:

• Oil palm fruit (CN 1207 10)
• Palm oil — crude (CN 1511 10)
• Palm oil — refined (CN 1511 90)
• Palm kernel oil (CN 1513 21, 1513 29)
• Palm stearin and palm olein
• Glycerol derived from palm oil (CN 1520, 2905 45)
• Fatty acids and fatty alcohols derived from palm oil — used in soaps, detergents, and cosmetics
• Biodiesel produced from palm oil (CN 3826)

Surprising inclusions: Palm oil derivatives are ubiquitous in modern manufacturing. They appear in margarine, baked goods, instant noodles, ice cream, soap, shampoo, lipstick, candles, cleaning products, and biofuels. Many companies that do not consider themselves "palm oil users" may find that their products contain palm-derived ingredients such as sodium lauryl sulphate, stearic acid, or glycerine. The EUDR requires traceability back to the plantation level for all of these.

5. Rubber

The rubber commodity group covers natural rubber and products made from it. Synthetic rubber is not covered — only natural rubber derived from the rubber tree (Hevea brasiliensis).

What is covered:

• Natural rubber in primary forms — latex, smoked sheets, technically specified rubber (CN 4001)
• Compounded rubber, unvulcanised (CN 4005)
• Vulcanised rubber in various forms (CN 4006, 4007, 4008)
• Tyres — new pneumatic tyres of rubber for cars, trucks, buses, aircraft, bicycles, and motorcycles (CN 4011)
• Retreaded or used pneumatic tyres (CN 4012)
• Inner tubes (CN 4013)
• Articles of vulcanised rubber — gaskets, seals, floor coverings, erasers (CN 4016)
• Rubber gloves (CN 4015)
• Rubber clothing and accessories (CN 4015)

Surprising inclusions: The tyre industry is the largest consumer of natural rubber globally, and all tyre manufacturers selling into the EU market will need to demonstrate EUDR compliance for their natural rubber inputs. Beyond tyres, rubber is used in medical gloves, industrial seals, conveyor belts, footwear soles, and sports equipment. If your product contains natural rubber, it is likely in scope.

6. Soya

The soya commodity group covers soya beans and the wide range of products derived from them, including both food and animal feed applications.

What is covered:

• Soya beans, whether or not broken (CN 1201)
• Soya bean flour and meal (CN 1208 10)
• Soya bean oil — crude (CN 1507 10)
• Soya bean oil — refined (CN 1507 90)
• Soya sauce (CN 2103 10)
• Soya bean oilcake and other solid residues — the primary ingredient in animal feed (CN 2304)
• Lecithin derived from soya (CN 2923 20)

Surprising inclusions: Soya lecithin is one of the most widely used food additives in the world, appearing in chocolate, baked goods, margarine, infant formula, and dietary supplements. Soya bean meal is the dominant protein source in animal feed for poultry, pigs, and farmed fish across Europe. If your business is in the animal feed industry, the food manufacturing sector, or the biofuels industry, soya is almost certainly part of your supply chain — and therefore within EUDR scope.

7. Wood

The wood commodity group is the most direct successor to the EUTR's scope, but the EUDR covers a broader range of wood-derived products than the EUTR did.

What is covered:

• Fuel wood, wood chips, sawdust, and wood waste (CN 4401)
• Wood charcoal (CN 4402)
• Wood in the rough (CN 4403)
• Railway or tramway sleepers (CN 4406)
• Sawn or chipped wood (CN 4407)
• Veneer sheets and plywood (CN 4408, 4412)
• Particle board and fibreboard (CN 4410, 4411)
• Wooden furniture — office, kitchen, bedroom, and other furniture (CN 9403 30, 9403 40, 9403 50, 9403 60)
• Prefabricated buildings of wood (CN 9406 10)
• Printed paper — books, newspapers, brochures, catalogues (CN 4901, 4902, 4903, 4904, 4905, 4911)
• Pulp of wood (CN 4701–4706)
• Paper and paperboard (CN 4801–4823)

Surprising inclusions: The inclusion of printed paper products means that publishers, printers, and packaging companies are within scope. Wooden furniture — including flat-pack furniture, garden furniture, and wooden toys — is also covered. Companies in the construction sector using timber framing, wooden cladding, or engineered wood products should verify their compliance obligations.

The "contains, was fed with, or was made using" test

The EUDR's scope is not limited to products that are obviously made from one of the seven commodities. The regulation applies to any product that contains a regulated commodity, was produced from animals that were fed with a regulated commodity, or was made using a regulated commodity as an input to the production process.

This test has significant implications:

• "Contains": A chocolate bar contains cocoa. A margarine contains palm oil. A leather jacket contains cattle hide. These are straightforward cases.
• "Fed with": This is particularly relevant for the cattle and soya commodity groups. If cattle were fed with soya-based feed, the resulting beef and leather products are linked to the soya supply chain. However, it is important to note that the EUDR's current Annex I does not extend the "fed with" test to all animal products — it applies specifically to the commodities and products listed.
• "Made using": This covers cases where a regulated commodity is used as a processing input. For example, palm oil derivatives used in the manufacture of soap or cosmetics, or wood pulp used in the production of paper.

The practical challenge for businesses is that many products contain regulated commodities in forms that are not immediately obvious. A food product may contain soya lecithin as an emulsifier. A cosmetic may contain palm-derived glycerine. A piece of furniture may use wood from multiple species and origins. Identifying all regulated inputs requires a thorough review of your product formulations, bills of materials, and supplier specifications.

Combined Nomenclature codes: how to check

The definitive way to determine whether your product is covered by the EUDR is to check its Combined Nomenclature (CN) code against the list in Annex I of the regulation. CN codes are the classification system used by EU customs for all goods entering or leaving the EU. Every product that crosses an EU border is assigned a CN code on its customs declaration.

To check whether your product is in scope:

1. Identify the CN code of your product. This should be available on your customs declarations, import/export documentation, or from your customs broker. You can also look up CN codes using the European Commission's TARIC database.
2. Cross-reference with Annex I of Regulation (EU) 2023/1115. The annex lists all covered CN codes, organised by commodity group. The consolidated version of the regulation, available on EUR-Lex, includes the most up-to-date version of Annex I.
3. Check for derived products that may not be immediately obvious. If your product contains ingredients or components derived from any of the seven commodities, the CN code of the final product may be covered even if the commodity itself is not the primary component.

If you are unsure about the classification of your product, consult your customs broker or seek a Binding Tariff Information (BTI) ruling from your national customs authority. Incorrect classification can lead to both customs and EUDR compliance issues.

Products that are not covered

While the EUDR's scope is broad, there are notable exclusions:

• Synthetic alternatives: Synthetic rubber, synthetic leather (e.g., PU leather), and synthetic palm oil substitutes are not covered, as they are not derived from the regulated commodities.
• Commodities not listed: Agricultural commodities such as cotton, sugar, rice, maize, and tobacco are not covered by the EUDR, even though some of them are associated with deforestation in certain regions.
• Recycled materials: Products made entirely from recycled materials (e.g., recycled paper, recycled rubber) may fall outside scope, depending on the specific CN code and the interpretation of "relevant product" under the regulation. However, this is an area where guidance from the European Commission is still evolving.
• Products in transit: Products that pass through the EU in transit (i.e., they are not placed on the EU market or consumed within the EU) are generally not covered, provided they remain under customs transit procedures.

What to do if your product is in scope

If you have determined that your product falls within the EUDR's scope, the next steps depend on your role in the supply chain:

1. If you are an operator (first placing the product on the EU market): you must conduct full due diligence, collect geolocation data, and submit a DDS before the product can be placed on the market.
2. If you are a trader: you must collect and retain DDS reference numbers from your suppliers and be prepared to provide them to competent authorities on request.
3. If you are a manufacturer using regulated inputs: verify that your suppliers can provide valid DDS reference numbers for all regulated ingredients and components.

In all cases, the starting point is a thorough product and supply chain review to identify all regulated commodities and derived products in your portfolio.

Sources: This article draws on Regulation (EU) 2023/1115 (EUDR) and the consolidated version of the EUDR including Annex I.