EUDR spice and vanilla importers: why most spices are exempt

Spices and herbs are not an EUDR commodity. Regulation (EU) 2023/1115 fixes a closed list in Annex I — cattle, cocoa, coffee, oil palm, rubber, soya and wood — and pepper, vanilla, cinnamon, nutmeg, cloves, ginger and every other spice or dried herb sit outside it. A business that imports, grinds, blends or sells spices on their own has no due diligence statement to file. Blends and gift products containing cocoa, coffee or palm derivatives, and wooden packaging, are where that changes.

Which commodities does the EUDR actually cover?

The regulation does not test products against deforestation risk in general. It tests them against a fixed list of seven commodities named in Annex I, and only products built from those seven, identified by CN code, carry an obligation.

Commodity	In Annex I	Spice-adjacent products covered
Coffee	Yes (CN 0901)	Green and roasted coffee, soluble coffee, coffee extracts and concentrates
Cocoa	Yes (CN 1801–1806)	Cocoa beans, butter, paste, powder, chocolate
Oil palm	Yes	Palm oil and a wide set of derivatives: glycerol, fatty alcohols, acids, soap forms
Cattle, rubber, soya, wood	Yes	Not spice-adjacent in practice
Pepper, vanilla, cinnamon, nutmeg, cloves, ginger, cardamom, chilli, turmeric, herbs	No	Nothing — these sit entirely outside Annex I

Coffee is the only entry from HS Chapter 9 of the customs tariff. The spice headings in that same chapter — pepper (0904), vanilla (0905), cinnamon (0906), cloves (0907), nutmeg, mace and cardamom (0908), seeds such as cumin and coriander (0909), and ginger, saffron, turmeric and other spices (0910) — were never brought into Annex I, by the original 2023 regulation or by any amendment since.

Why weren't spices included in the first place?

Annex I was not drawn up as a general deforestation-risk list. It reflects the European Commission's own impact assessment of which commodities drive the largest share of EU-linked deforestation and forest degradation, and the final list that made it into the regulation runs to seven: cattle ranching, cocoa and oil palm plantations, soy expansion, rubber, timber, and coffee growing in forest-frontier regions. Spice and herb cultivation did not meet that threshold, despite genuine land-use concerns in some origins — vanilla in Madagascar and pepper in parts of Southeast Asia both have documented links to forest conversion in the sustainability literature. That link exists, but the EUDR does not test for it directly; it tests whether the product is on the Annex I list, and spices are not.

This is the same mechanism, and the same outcome, as tea's exclusion from the EUDR: a plant can carry real deforestation exposure in its sourcing and still sit outside the regulation, because the regulation regulates a named list of commodities rather than an open-ended risk test.

Doesn't vanilla come from forest land, though?

Vanilla is the spice most often raised in this context, because a large share of the world's vanilla is grown in or near Madagascar's remaining rainforest, and vanilla cultivation has been linked to forest encroachment in several studies. None of that changes its EUDR status. Vanilla beans, vanilla extract and vanilla pods are classified under CN 0905, and CN 0905 does not appear anywhere in Annex I, before or after the amendments made by Commission Delegated Regulation (EU) 2026/2102. A vanilla importer has no EUDR due diligence statement to file for the vanilla itself, however it was grown or wherever it was sourced. Buyers who want assurance on vanilla's land-use footprint need to get it through commercial channels — supplier audits, satellite monitoring services, or certification — not through the EUDR, because the regulation gives them no lever here at all.

When a spice product still creates an EUDR obligation

The exemption is for the spice or herb itself. It does not extend to a finished product just because spice is the headline ingredient. Three situations pull a spice business back into scope, and all three turn on what else is in the product or its packaging, not on the spice content.

Scenario	In scope?	Why
Pure spice or herb, whole, ground or blended with other spices only	No	No Annex I ingredient present
Mulled wine spice kit, chai spice mix or similar blend containing cocoa solids	Depends on the specific CN code	The cocoa component can bring that product into scope even though the spices in it would not be, on their own
Curry paste, spice paste or seasoning containing palm oil or a palm derivative as an emulsifier or carrier	Depends on the specific CN code	Oil palm derivatives remain in scope across a wide range of uses, including in food manufacturing
Gift hamper or gift set combining spices with coffee, cocoa or chocolate	The coffee/cocoa line, not the spice line	Each product line in a mixed hamper is assessed on its own CN code
Wooden spice racks, crates, pallets or certain wood-pulp spice packaging	Possibly, for the packaging itself	Wood remains an Annex I commodity independently of what it contains or transports

The practical trap is a product range built around an out-of-scope ingredient that still contains individual lines which are in scope. The only way to know is to check the CN code of each line rather than extending the spice exemption across the whole catalogue. EUDR for cocoa and chocolate makers sets out how cocoa content triggers obligations inside a mixed product; the same check applies to any cocoa or palm-derived ingredient sitting inside a spice-led line.

What about essential oils and extracts made from spices?

Clove oil, cinnamon oil, nutmeg oil, black pepper oil and similar spice-derived essential oils follow the same rule as the raw spice: none of them are Annex I products, so none of them carry an EUDR obligation on their own. EUDR for essential oils and aromatherapy makers covers this in more depth for the wider essential oil category — the same distinction applies here: a spice-derived oil is out of scope, but a finished product blending it with a carrier oil or emulsifier derived from palm needs that other ingredient checked on its own terms. Coffee extracts and concentrates are a specific exception worth knowing about even though it does not touch spices directly: Commission Delegated Regulation (EU) 2026/2102 added soluble coffee and coffee extracts to Annex I from 30 December 2027, which is a reminder that the Commission does expand scope by delegated act when it chooses to — it simply has not done so for spices.

Could spices be added to the EUDR in future?

In principle, yes. Article 34(2) of Regulation (EU) 2023/1115 requires the Commission to review the regulation's scope and impact, with the next substantive review due by 30 June 2030, and the Commission can amend Annex I by delegated act outside that cycle too, as it did for coffee, cattle and palm oil products under Delegated Regulation (EU) 2026/2102, adopted 13 July 2026 and in force since 18 September 2026. That delegated act did not touch spices, and nothing in the public record of the Commission's scope work names any spice or herb as a candidate for addition. What changed and what didn't under Delegated Regulation (EU) 2026/2102 has the full list of what that amendment actually moved. If a spice were ever added, it would get its own application date set in the amending act — the Commission's practice so far, with soluble coffee, has been to give newly added products roughly a year's extra runway rather than applying the nearest existing deadline.

What spice and herb importers should still check

Three things are worth doing even though the spice exemption itself needs no ongoing monitoring:

• CN code every blended or mixed product, not just the headline spice line. A hamper, kit or seasoning blend containing cocoa, coffee or palm derivatives needs that specific line assessed, even where the rest of the range is clearly exempt.
• Treat wooden and wood-pulp packaging as a separate question. A spice rack, display crate or certain cartons are assessed on their own CN code and their own supply chain, independently of the spice inside them.
• Keep commercial due diligence and legal due diligence separate. Sustainability concerns around vanilla, pepper or other spice sourcing are real and worth managing through supplier audits or certification if that matters to your buyers — but that is a commercial choice, not something the EUDR requires, because spices are not in its scope.

If your range sits only partly in spices — a retailer or hamper business selling spice blends alongside coffee, cocoa, palm-derived ingredients or wood products, for instance — check what the EUDR actually requires for your specific product range rather than assuming a spice-led brand is exempt across the board.

Deadlines, if any part of your business is in scope

Spices themselves carry no EUDR deadline. This table only matters if another part of your business handles a commodity that is:

Business handles	Application date
Spices and herbs only, no Annex I commodity or derivative	No EUDR date applies
Coffee, cocoa, oil palm, cattle, rubber or soy alongside spices — large or medium operator/trader	30 December 2026
Same commodities, micro or small operator/trader, product not previously under the EU Timber Regulation	30 June 2027
Soluble coffee or coffee extracts specifically, any size	30 December 2027
Wooden spice packaging, any size	30 December 2026 (large/medium) or 30 June 2027 (micro/small, where the Timber Regulation carve-out does not apply)

See which application date applies to your business for how operator size is worked out.

The bottom line

Spices and herbs are excluded from the EUDR by the same mechanism that puts coffee inside it: a fixed, closed commodity list in Annex I, not a general test of deforestation risk in the growing region. That exclusion covers pepper, vanilla, cinnamon, nutmeg, cloves, ginger and every other spice or herb, whatever the land-use story behind it. It does not extend to a product that combines a spice with cocoa, coffee or a palm derivative, and it does not extend to wooden packaging. A pure spice or herb business has no EUDR due diligence statement to file; a business that sells spices alongside anything on the Annex I list needs to check that other part of its range on its own terms.