EUDR Annex I changes 2026: what's in and out under Delegated Regulation (EU) 2026/2102

Commission Delegated Regulation (EU) 2026/2102 rewrote Annex I of the EUDR and took effect in September 2026. Cattle hides, skins and leather, re-treaded tyres, soya beans for sowing, and vehicle and aircraft seats are now out of scope. Soluble coffee, frozen cattle tongues and further palm oil derivatives are newly in scope — but not until 30 December 2027.

This is a separate, later change from the postponement made by Regulation (EU) 2025/2650, and it moves in the opposite direction. That regulation only ever added time and removed paperwork; this one removes some products from the regulation altogether while adding others for the first time. If you have not looked at Annex I since last year, both changes have happened, and confusing one for the other is an easy mistake to make.

The timeline, confirmed

The Commission adopted the delegated act on 13 July 2026 under Article 34(1) of Regulation (EU) 2023/1115, which lets it adjust Annex I without a full legislative process. That triggered the standard scrutiny period: the European Parliament and the Council each had two months, extendable by a further two, to object. Neither did. The scrutiny period closed on 14 September 2026, the Commission published the act in the Official Journal as Delegated Regulation (EU) 2026/2102 on 17 September 2026, and it entered into force the following day.

What is genuinely unsettled is the operative date for the removals specifically. Some secondary reporting on the act puts it at the day after publication — 18 September 2026 — in line with how the act is generally described as now in force; other reporting cites the more conventional twenty-day rule, which would put it at 7 October 2026. We have not been able to confirm which applies to the removal provisions from the regulation's own text this run. If a removed product is what takes you out of scope and the date matters to something you are about to do — a due diligence statement you are on the point of not filing, for instance — check the commencement article in the regulation itself before you rely on it. The addition date is not in the same doubt: 30 December 2027 for newly listed products is stated directly and repeated consistently across every source we checked, including the Commission's own account of the act.

What came out of Annex I

Removed	Detail
Cattle hides, skins and leather	HS 4101, 4104, 4107
Re-treaded tyres	—
Soya beans for sowing	Seed use only, not soya for crushing or feed
Vulcanised-rubber articles, conveyor and transmission belts	HS 4010, 4016
Vehicle and aircraft seats	—

Reporting on the act also describes it as putting samples used for testing, waste, and used or second-hand goods outside the product perimeter, alongside some packing materials. Treat that as a clarification of edge cases rather than a headline change — it narrows what counts as a "relevant product" at the margins, it does not remove a commodity.

None of the seven regulated commodities has been dropped. Cattle is still in scope — beef, live cattle and the newly added frozen tongues remain caught. It is specific downstream products, mostly in the leather and rubber chains, that came out. The regulation's own recitals reportedly flag that the 2030 review due under Article 34(2) may revisit some of these exclusions, so a business that restructured sourcing around this removal should not treat it as closed permanently.

What went into Annex I, and why the date is different

Added	Detail	Applies from
Soluble coffee, and coffee extracts, essences and concentrates	HS 2101 11	30 December 2027
Frozen cattle tongues	—	30 December 2027
Further palm oil derivatives	Certain fatty alcohols, glycerol, specified acids, amines and soap forms	30 December 2027

The later date exists because these products were never assessed for deforestation risk under the original 2023 regulation — the Commission had to bring them into scope before it could set a compliance date for them, and it gave a year's run-in rather than making them due alongside everyone else. That mirrors the logic behind the two-tier main application dates: a later date for the part of the market that needs longer to get ready, not a lighter obligation once it lands.

If you deal in both an established product and a newly added one — an importer bringing in both roasted and soluble coffee is the obvious case — you are now running two dates on the same due diligence relationship with the same supplier. The roasted coffee needs a statement by your main date; the soluble line has until 30 December 2027. Keep the distinction in your own records, because a competent authority checking your file will expect you to know which line is which.

Does this move your main deadline?

No. 30 December 2026 for large and medium operators and traders, and for micro and small operators whose products were already under the EU Timber Regulation, is unchanged. 30 June 2027 for other micro and small operators is unchanged. This delegated act only edits which products Annex I covers — it does not touch Article 38, which is where the application dates themselves sit. Anyone reporting that this act delayed the EUDR again has conflated it with 2025/2650, which is a different instrument from six months earlier. What changed under the December 2025 amendment covers that one on its own terms.

If a removed product was your only reason to be in scope

Check this properly rather than assuming it. If leather, re-treaded tyres, or the specific rubber and belting HS codes above were the entire basis for your EUDR obligations — nothing else you place on the EU market falls under cattle, cocoa, coffee, oil palm, rubber, soya or wood — you may now be out of scope entirely. That is worth confirming in writing, because the obligations you are walking away from include the due diligence statement, geolocation, and five-year retention, not just an inconvenience.

Most businesses will not be so clean-cut. A tannery that also handles hides destined for other leather products, or a distributor whose warehouse holds both re-treaded and new tyres, needs to check each CN code it deals in separately rather than treating the whole product line as cleared.

If a newly added product brings you into scope for the first time

Soluble coffee manufacturers, instant coffee blenders, and importers of coffee extracts and concentrates who were not previously caught by the green and roasted coffee categories now have an EUDR obligation, from 30 December 2027. The same goes for buyers of the newly listed palm oil derivatives — largely a cosmetics, food and industrial chemicals audience that has historically bought fatty alcohols and glycerol without thinking about where the palm came from.

A year sounds like time to spare. It generally is not, for the same reason it was not for anyone else facing an EUDR date: the constraint is supplier data, not paperwork. A supplier who has never been asked for plot-level geolocation does not produce it quickly, and a supplier who cannot produce it needs replacing, which takes longer still. Starting the supplier conversation now, while the date feels distant, is the difference between a dry run and a scramble.

What this delegated act does not touch

• The 31 December 2020 cut-off date for deforestation-free production.
• The due diligence statement mechanics and the concentration of filing on the first EU placer, introduced by Regulation (EU) 2025/2650.
• Geolocation requirements — polygons above 4 hectares, points below, every establishment for cattle — for any product that remains in scope.
• The five-year record retention obligation.
• The penalty regime: fines with a maximum of at least 4% of annual EU-wide turnover, confiscation, and exclusion from public procurement for serious or repeated infringements.
• Country benchmarking under Implementing Regulation (EU) 2025/1093, which is unaffected by a change to which products are covered.

What to do about it

Re-run your CN code mapping against the current Annex I rather than the version you checked last year or the version you checked in July when the act was only proposed. Two changes have happened in the same twelve months, in opposite directions, and a mapping done at either point is now out of date in one direction or the other.

If your products moved out of scope, document the basis for that conclusion before you stop any compliance activity built around them. If a product moved in, you have until 30 December 2027, but the supplier data you will need does not arrive on that schedule by itself.

Check what the EUDR requires of your specific products against the current Annex I, not last year's list.