EUDR and gelatine, collagen or bone-derived ingredients

No. Gelatine and collagen, classified under CN 3503, have never had an entry in Annex I of Regulation (EU) 2023/1115, so making or importing them is not EUDR-regulated in itself, whatever species or by-product they come from. The cattle hides that were once a route into scope for some gelatine makers came out of Annex I on 18 September 2026 too. What is left to check is narrower than most businesses in this sector assume.

Why gelatine and collagen sit outside Annex I

The EUDR does not regulate materials in the abstract; it regulates specific Combined Nomenclature (CN) codes listed against each of the seven commodities in Annex I. Cattle is one of those seven, but the cattle entry has always been a short, specific list: live animals, fresh and frozen meat, certain edible offal, some prepared meat, and — until 18 September 2026 — raw hides, tanned hides and leather. Gelatine and collagen, whatever animal or tissue they are derived from, fall under CN heading 3503 (gelatine and gelatine derivatives) in a different chapter of the customs tariff, and that heading has never appeared against cattle, or against any of the other six commodities. A regulation built around named CN codes does not reach a product simply because of what it is biologically made from; it reaches the product if its own code is on the list, and 3503 is not.

The same applies to bone meal, bone char, hydrolysed collagen peptides, gelatine capsules, gummy sweets made with gelatine, collagen supplements and cosmetic collagen — all downstream of, or classified separately from, the cattle entry. None of this is a 2026 change. It has been true since the regulation was adopted in 2023.

What the cattle Annex I entry actually covers

This table sets out the full cattle entry as it stands after the Annex I recast, so you can check your own inputs against it rather than against the word "cattle" in general.

CN code	Covers	In scope now?
0102 21, 0102 29	Live cattle	Yes
ex 0201, ex 0202	Fresh, chilled or frozen beef	Yes
ex 0206 10, ex 0206 22, ex 0206 29	Edible offal, excluding tongues	Yes
ex 1602 50	Prepared or preserved meat, offal or blood of cattle	Yes
Frozen cattle tongues	Added by Delegated Regulation (EU) 2026/2102	Yes, from 30 December 2027
ex 4101, ex 4104, ex 4107	Raw hides, tanned hides, leather	No — removed 18 September 2026
0506 (bones, horn-cores, unworked or simply prepared)	Bone feedstock for gelatine or collagen	Never listed
3503	Gelatine and gelatine derivatives, including collagen preparations	Never listed

If your business handles cattle meat or live cattle anywhere in its supply chain, that side of it is genuinely in scope and needs the full operator due diligence the cattle commodity requires. That obligation does not extend to a separate product line making gelatine from bone, because bone itself was never an Annex I entry.

The one route that did exist, and is now closed

Some gelatine and collagen manufacturers buy raw or lightly processed cattle hide, rather than bone, as feedstock — hide collagen and bone collagen are both common in the industry. Before 18 September 2026, a business importing or placing on the market raw hides under CN ex 4101, or tanned hides under ex 4104, to use as its own input material was doing something Annex I did reach, even though the gelatine it made at the end of that process was not itself regulated. That obligation sat on the hide purchase, not on the gelatine sale.

Commission Delegated Regulation (EU) 2026/2102 removed CN ex 4101, ex 4104 and ex 4107 from Annex I with no transition period, so this route closed on 18 September 2026 along with everything else it affected. The full removal, and what it did and did not change, is covered here if hide sourcing is a meaningful part of your business. From that date, a gelatine or collagen manufacturer sourcing cattle hide has the same position as one sourcing bone: no Annex I code anywhere in the chain.

What has never been in scope, regardless of the 2026 changes

• Bone, bone meal and bone char bought as gelatine or collagen feedstock (CN 0506).
• Gelatine and gelatine derivatives in any form — sheet, powder, capsule shell, or dissolved into a food, drug or cosmetic formulation (CN 3503).
• Hydrolysed collagen peptides sold as a supplement or functional ingredient.
• Collagen used in cosmetics or personal care, which sits outside Annex I in the same way palm-derived cosmetic ingredients sit inside it for a different reason — cosmetic use does not itself create or remove scope; the CN code of the ingredient does.
• Gelatine-based confectionery, capsules and pharmaceutical excipients.

Why this gets confused anyway

Three things push gelatine and collagen businesses towards assuming they are regulated, none of which actually puts them in scope.

First, cattle is one of the seven commodities, and "we buy from cattle" reads as close enough to "we buy a cattle product" to seem safe to assume in scope. It is not the same question. The regulation lists specific codes against cattle, not the species in general, and the codes stop short of bone and gelatine.

Second, gelatine and collagen imports already carry EU paperwork, so a business handling that paperwork reasonably expects the EUDR to be more of the same. It is not. Bovine-derived gelatine and collagen entering the EU are governed by Regulation (EC) 853/2004's definitions and Commission Delegated Regulation (EU) 2022/2292's import conditions — animal and public health rules, covering things like which third countries may export and what veterinary certification travels with the consignment. Those rules run in parallel with the EUDR and are not affected by anything in this article; they also do not create an EUDR obligation, because they answer a different question (is this safe to import) rather than the EUDR's question (did producing this cause deforestation after 2020).

Third, a company that supplies a tannery or abattoir, or buys from one, picks up EUDR language from that counterparty's compliance work and assumes it is shared. It generally is not. A tannery's due diligence statement for raw hide it imports says nothing about the gelatine house that later buys processed bone from a renderer three steps downstream — different product, different code, different question.

Where this leaves a mixed business

A company that both trades cattle meat and manufactures gelatine from bone needs to treat these as separate questions, because they get different answers. The meat side is in scope on its own terms and has been since 2023; it carries the full due diligence statement, geolocation and risk assessment obligations, by whichever application date fits its size — 30 December 2026 for large and medium operators and traders, 30 June 2027 for micro and small operators. The gelatine side generates no obligation of its own, with or without that other business line, because the product it sells and the bone or hide it buys (since September 2026) both sit outside Annex I.

Do not assume that being in scope for one product line pulls a separate product line in with it. Scope attaches to the specific CN code moving across the specific transaction, not to the business as a whole.

A general due diligence law may still apply, separately

The EUDR is not the only EU law that can touch a gelatine or collagen business trading with suppliers outside the EU. The Corporate Sustainability Due Diligence Directive applies by company size and turnover, not by commodity, and works on a different basis from the EUDR entirely. Being out of EUDR scope says nothing about whether that separate obligation reaches you — check it on its own terms if your size and turnover put you anywhere near its thresholds.

What to check in your own supply chain

• Get the CN code your supplier declares for the bone, hide or gelatine you buy or sell — not a product description, the actual code on the customs paperwork or commercial invoice.
• If it is 0506 (bone) or 3503 (gelatine, collagen), you have no EUDR obligation on that transaction.
• If it is ex 4101, ex 4104 or ex 4107 (hide or leather) and the transaction happened before 18 September 2026, keep the records; the obligation that applied then does not disappear retroactively.
• If any part of your business also handles live cattle, fresh or frozen beef, or cattle offal, check that line separately against the full cattle entry.

Check your own business against the current rules if gelatine or collagen is one product line among several and you are not certain which of them, if any, is actually regulated.