EUDR Annex I amendment: is your product affected?

Check your product's CN (Combined Nomenclature) code against the two Annex I lists Delegated Regulation (EU) 2026/2102 changed: the removals, which took effect from 18 September 2026, and the additions, which apply from 30 December 2027. If your code sits on neither list, nothing changed and your existing deadline — 30 December 2026 or 30 June 2027 — still applies.

Why this check is worth doing now

Commission Delegated Regulation (EU) 2026/2102 was adopted on 13 July 2026 and published in the Official Journal on 17 September 2026, amending Annex I of Regulation (EU) 2023/1115 without reopening the regulation's main text. It did two things at once: it took a handful of product lines out of scope entirely, and it put three new ones in, effective a year after the general application date. Neither change touches the seven covered commodities themselves — cattle, cocoa, coffee, oil palm, rubber, soy and wood are exactly as broad as before. What moved is the list of derived products made from them, in Annex I.

That matters because a lot of businesses built their compliance plan around a CN code they looked up months or years ago. If that code was removed, you may be doing due diligence work the regulation no longer asks for. If it was added, you have a new obligation with a 2027 start date you may not have on your calendar yet. Either way, the only way to know is to check the code, not to assume the amendment did or didn't touch you.

Step 1: find the CN code your product actually ships under

Your customs declarations already carry this. Check the CN (Combined Nomenclature) or HS code used on your import or export paperwork — not a general description of the product, but the actual heading and subheading. Annex I is built around these codes, and the amendment changes specific subheadings, not product categories in the abstract. If you sell several variants under different codes, check each one separately; the amendment does not move in a single direction across a product family.

If you don't handle customs declarations yourself, ask whoever does (a freight forwarder, customs broker, or your own trade compliance team) for the exact code on file. Guessing from a product description is how businesses miss a removal or an addition.

Step 2: check whether your code was removed

The following left Annex I, with effect from 18 September 2026:

Product	CN/HS reference	Effect
Cattle hides, skins and leather	ex 4101, ex 4104, ex 4107	Out of EUDR scope entirely
Retreaded tyres (most lines)	ex 4012, narrowed to ex 4012 90 30 (new tread only)	Narrowed; most retreaded-tyre codes removed
Conveyor and transmission belts, other vulcanised rubber articles	ex 4010, ex 4016	Out of EUDR scope
Soybean seeds for sowing	relevant soy seed codes	Out of EUDR scope
Aircraft and motor vehicle seats	ex 9401	Out of EUDR scope

If your product's code is on this list, you no longer have an EUDR due diligence obligation for it from 18 September 2026 onward. That is a change in scope, not a change in deadline — there is no transition period for a removal, because there is no longer anything to transition into. If you built a due diligence system around one of these codes, you can stand it down for that product line; keep your existing due diligence statements and records for any consignments placed on the market before 18 September 2026, since those obligations applied at the time.

See what changed for leather, hides and footwear businesses and what stays in scope for rubber and tyre distributors if either applies to you — both guides cover the practical fallout of this removal in more detail than fits here.

Step 3: check whether your code was newly added

The amendment added three product groups to Annex I, applicable from 30 December 2027 — a year after the general 2026 application date, giving affected businesses a run-in period rather than dropping the obligation on them overnight:

Product	CN/HS reference	Applies from
Soluble (instant) coffee, extracts and concentrates	2101 11 00	30 December 2027
Frozen cattle tongues	ex 0206 21 00	30 December 2027
Palm oil oleochemical derivatives (fatty alcohols, glycerol, certain fatty acids and amines, some soap forms)	across CN chapters 15, 29, 34 and 38	30 December 2027

If you manufacture, import or trade any of these, you have until 30 December 2027 to put due diligence in place — geolocation of plots of production, supplier declarations, a risk assessment and a due diligence statement submitted through the EU's Information System, exactly as for any other Annex I product. That date is fixed in the delegated regulation itself; it is not a general grace period you can rely on for other newly regulated products in future.

If this is you, two guides go further than this page can: soluble and instant coffee manufacturers facing the 2027 deadline, and what the newly added products mean for coffee, palm and cattle-tongue supply chains generally. If your business already handles palm derivatives for cosmetics or personal care, this guide on palm oil derivatives in cosmetics sets out what counts as a derivative versus what sits outside Annex I altogether.

Step 4: if your code is on neither list

Most products are unaffected. If your CN code does not appear in either table above, this amendment made no difference to you. Your obligations and deadlines are exactly what they were before 17 September 2026:

• 30 December 2026 for large and medium operators and traders, and for micro and small operators whose products were already covered by the EU Timber Regulation.
• 30 June 2027 for micro and small operators on everything else.

For a full breakdown of which of those two dates applies to your business by size and product, see which deadline applies to you. For the amendment itself in full — the Commission's own reasoning, the complete product lists and how it interacts with the earlier 2025 postponement — see EUDR Annex I changes 2026: what's in and out.

A note on the exact effective date for removals

Most primary and secondary sources give 18 September 2026 — the day after Official Journal publication — as the date the removals and narrowings took effect, consistent with the Commission's own announcement. One piece of legal commentary instead reads the regulation's standard twenty-day entry-into-force clause as landing on 7 October 2026. If the precise day matters to you — for example, you shipped a consignment of a now-removed product in the narrow window between those two dates and need to know whether a due diligence statement was still required — check the entry-into-force article of the Official Journal text itself (EUR-Lex, OJ L series, 2026/2102) rather than relying on secondary summaries, including this one.

What this amendment does not do

It does not change the 30 December 2026 or 30 June 2027 application dates for anything already in scope. It does not reopen simplified due diligence for micro and small operators, which is a separate mechanism under Article 13. And it does not touch the cut-off date of 31 December 2020, after which production must be deforestation-free — that date is set in the regulation's main text, not in Annex I, and no amendment to date has moved it.

Next step

If you've worked out that your product is still in scope — whether it always was, or because this amendment newly added it — the fastest way to see what your business specifically has to do is to run the free compliance check. It asks about your product and role and gives you the deadline, the obligations and the documents you'll need, rather than a generic answer.

Frequently asked questions

Does this amendment apply retroactively to consignments already placed on the market? No. Removals take effect from 18 September 2026 onward; due diligence statements submitted for consignments placed on the market before that date remain valid obligations and should be kept on file. Additions apply only from 30 December 2027 forward.

My product isn't on either list — do I need to do anything? No. If your CN code doesn't appear in the removed or added tables above, this amendment changed nothing for you. Your deadline is still 30 December 2026 or 30 June 2027, depending on your size and product.

I make leather goods that also use wooden components, like shoe heels or handbag frames. Am I fully out of scope now? No. The removal only applies to the hide, skin and leather material itself. If your product also contains a wood-derived component covered by Annex I, that component keeps you in scope for that part of the product.

Is soluble coffee treated the same as roasted coffee under EUDR? No, not yet. Roasted and green coffee have been in scope since the regulation's original Annex I. Soluble coffee is newly added by this amendment and only becomes subject to the regulation from 30 December 2027.

Who decides whether my specific CN code is covered — the Commission or my competent authority? Annex I, as now amended, is the legal text that defines scope — it binds every competent authority uniformly across the EU. If you're unsure how your product is classified, your customs broker or your national competent authority's EUDR helpdesk can confirm the applicable code; neither can override what Annex I says once the code is settled.

Does this amendment add any new CN codes beyond the three named here? The regulation also recodes some existing entries — for example, live-cattle tariff lines — for classification consistency. That's a coding correction, not a scope change, and it doesn't add or remove products. If you're checking your own code and it falls in a recoded range, confirm with your broker that the product itself is unaffected.

What if the Commission removes or adds more products again before December 2026? The Commission has indicated it does not intend to reopen the regulation's main text again before the application date, but Annex I itself can still be amended by delegated act, as this one was. Recheck your CN code against the current Annex I text periodically rather than assuming today's list is final.

I'm a trader, not the original importer — does the removal still apply to me? Yes. Scope is defined by the product's CN code under Annex I, not by your role in the supply chain. If the product you trade was removed, neither operators nor traders handling it have an EUDR obligation for it from 18 September 2026.