EUDR newly added products: soluble coffee, palm oleochemicals and cattle tongue, explained

Soluble coffee, a defined group of palm oil oleochemicals and soap, and frozen cattle tongues were added to EUDR Annex I by Commission Delegated Regulation (EU) 2026/2102, adopted 13 July 2026 and in force since 18 September 2026. If you place any of these on the EU market, or trade in products made from them, you have until 30 December 2027 to comply — one date, whatever your company's size.

What was actually added

Delegated Regulation (EU) 2026/2102 rewrote Annex I to the EUDR in two directions at once. It took several products out — covered in a separate guide — and it put four new categories in. All four take their application date from the delegated regulation's own transitional provision, separate from the main 30 December 2026 / 30 June 2027 split set by Regulation (EU) 2025/2650.

Added to Annex I	CN code	What it covers
Soluble coffee	2101 11 00	Extracts, essences and concentrates of coffee — closes the gap where roasted and green beans were already in scope but their processed form was not
Frozen cattle tongues	ex 0206 21 00	Fresh cattle tongues were already caught; freezing them alone had been enough to fall outside the old wording
Palm oil oleochemicals	Spread across Chapters 15, 29, 34 and 38 of the Combined Nomenclature	Hydrogenated and inter-esterified palm and palm kernel oils, crude glycerol, fatty alcohols, and fatty acid salts and esters synthesised from palm oil, including oleic, linoleic and linolenic acids and their salts and esters under CN 2916 15
Soap containing or made using palm oil	Classified under the standard soap heading, CN 3401	Bars, cakes and other moulded shapes for toilet use, and soap in other forms

CN 2916 15 was added specifically in response to stakeholder submissions made during the Commission's 2026 review, rather than appearing in the original draft — a sign of how late in the process the oleochemical list was still being adjusted. Several of the palm derivative entries are "ex" headings, meaning only some of the goods classified under that code are caught, not the whole heading. If your product sits near the edge of one of these descriptions, check it against the current Combined Nomenclature text rather than against a secondary summary, including this one.

Why these four, and not others

The gaps were not random. Fresh cattle tongues, roasted coffee beans, and crude palm oil were already in scope from when the EUDR was first drafted. What the Commission's 2026 review found was that simple processing — freezing, solubilising, refining into oleochemicals — had been taking materially the same commodity out of scope purely on a technicality of product description. Soap made with palm oil is the clearest example: the oil itself was always caught, but once it had been saponified into a bar of soap, nothing in the original Annex I text caught the finished product. The delegated regulation closes that gap rather than widening the regulation's underlying commodity list, which is still cattle, cocoa, coffee, oil palm, rubber, soya and wood.

If you handle coffee more broadly, what a coffee importer must collect from every farm still applies once soluble coffee reaches its own deadline. The same is true for palm oil traders and refiners moving into oleochemicals, and for cattle and beef supply chains that now need to track tongue as a product line in its own right rather than assuming it falls outside the cattle entry because it is frozen.

One date for everyone — size does not move it

Regulation (EU) 2025/2650 split the main EUDR timetable by company size: 30 December 2026 for large and medium operators and traders, 30 June 2027 for micro and small operators dealing in products not already under the EU Timber Regulation. None of that split carries over to the four categories added by Delegated Regulation (EU) 2026/2102.

A micro soap manufacturer and a large one face the same 30 December 2027 date for palm-oil soap. The later date is already the concession: the Commission gave every newly captured product a full extra year beyond the main deadline, rather than layering a second size-based extension on top of it. There is no equivalent of the Timber Regulation trap here, because none of these four categories were ever within the EU Timber Regulation's scope — so there is no earlier date to be caught by on that basis either.

Category	Application date
Large and medium operators and traders — existing Annex I products	30 December 2026
Micro and small operators — existing Annex I products already under the EU Timber Regulation	30 December 2026
Micro and small operators — existing Annex I products, non-timber	30 June 2027
Any operator or trader, any size — soluble coffee, palm oleochemicals, soap, frozen cattle tongue	30 December 2027

See which deadline applies to your business for how the size test itself works, including the group-consolidation point that catches businesses expecting a later date.

What is excluded even if your CN code matches

The same delegated regulation narrows the product perimeter generally, and some of the narrowing bears directly on the new entries:

• Products used to manufacture human or veterinary medicinal products are excluded — relevant chiefly to the glycerol and fatty-acid derivatives, both common pharmaceutical inputs, which would otherwise be caught by the oleochemical entries.
• Samples of negligible value, and products consumed or destroyed during testing, analysis or trials, are out of scope.
• Waste, used or second-hand goods, and packing materials are excluded by the same general clarifications that apply across the whole of Annex I, not only to the four new categories.

None of these exclusions are self-certifying. They sit in the wording of the entry itself, so the burden is on you to show your specific goods fall within the exclusion — a pharmaceutical glycerol supplier needs to be able to demonstrate end use, not simply assert it if a competent authority asks.

What to do before 30 December 2027

A year sounds generous, and for a single product line it often is. Three things are worth starting now rather than in late 2027:

1. Confirm your own CN codes. Most businesses newly caught by this amendment do not think of themselves as dealing in a "relevant product" at all — a cosmetics formulator buying soap base, or a food manufacturer buying soluble coffee as an ingredient, may not have checked Annex I since before this round of changes. Re-run your product list against the current Annex I text, not against last year's.
2. Trace back to plot level. The due diligence obligation for a newly added product is identical to the obligation for a product that has been in scope since 2023 — geolocation of the plot of production, a legality and deforestation-free assessment, and a risk assessment. None of that is faster to assemble for a product you have never been asked about before. If your supplier has never provided this for soluble coffee or crude glycerol specifically, assume the same multi-month response time documented for established Annex I commodities.
3. Register in the EUDR Information System when the time comes, not before. You do not need a due diligence statement for a newly added product before its own 30 December 2027 date arrives, and registering early does not buy you anything. What is worth doing early is confirming which of your product lines will need one, and building the supplier relationship that produces the geolocation data, well ahead of the date itself.

The cut-off date does not change for any of this. Products must still be deforestation-free after 31 December 2020, regardless of when the specific product entered Annex I. A supply relationship that predates the 2026 amendment gets no grandfathering on that point.

How this fits with the rest of the EUDR timetable

If you already have an EUDR compliance process running for other products — a due diligence statement workflow in TRACES, a records system, a risk assessment template — extending it to a newly added product is largely a data-collection exercise, not a process one. The same filing steps and the same record-keeping obligations apply unchanged once your product's own date arrives; nothing about being newly added simplifies either.

What catches businesses out is assuming that because the main EUDR deadline has passed them by — they cleared 30 December 2026 or 30 June 2027 believing their product list was complete — nothing further is coming. A business that checked its CN codes against Annex I in 2024 or 2025 and has not checked again since September 2026 may now have a product in scope that it has not assessed at all.

Check what the EUDR actually requires of your business against the current Annex I, including these four categories, rather than against the list you last checked.