EUDR for tea importers: why tea isn't treated like coffee

Tea is not covered by the EUDR. The regulation applies to seven commodities — cattle, cocoa, coffee, oil palm, rubber, soy and wood — and their listed derivatives in Annex I, and tea has never been one of them, even as coffee has sat in scope since the regulation entered into force. A tea importer has no due diligence statement to file for the tea leaf itself, in almost every case.

Why coffee is in scope and tea is not

The EUDR's product scope is not open-ended. Article 1 and Annex I of Regulation (EU) 2023/1115 fix a closed list of commodities, chosen during the regulation's drafting for their documented role in global deforestation: cattle ranching, cocoa and oil palm plantations, soy expansion, rubber, timber, and coffee growing in forest-frontier regions. Tea cultivation was not included in that original list, and nothing in the amendments since — not Regulation (EU) 2025/2650, which postponed and simplified the regime, and not Commission Delegated Regulation (EU) 2026/2102, which rewrote parts of Annex I in both directions — has added it. See what's in and out under Delegated Regulation (EU) 2026/2102 for the full list of that change: it added soluble coffee, frozen cattle tongues and further palm oil derivatives, and removed cattle leather, re-treaded tyres and a handful of rubber and vehicle products. Tea featured in none of it.

This is a genuine policy choice, not an oversight the Commission is quietly correcting. Tea growing is associated with land-use change in some origins, and civil society groups have raised it in the same breath as coffee and cocoa. But the regulation was built around the commodities the European Commission's own impact assessment identified as driving the largest share of EU-linked deforestation, and tea did not clear that bar. A review of the regulation's scope is required by 30 April 2026 under Regulation (EU) 2025/2650, and the Commission has said that review will look at targeted adjustments to the product list rather than a wholesale rewrite — nothing public from that process points to tea being added. If that changes, it would need its own delegated or implementing act, with its own application date, in the same way soluble coffee was added on a date a full year after the rest of Annex I.

What this means if you import tea

For a business that imports, blends, packs or sells black, green, white, oolong or herbal tea with no coffee, cocoa or other Annex I ingredient in it, the EUDR imposes no due diligence statement, no geolocation requirement, and no deforestation-free declaration. You do not register in TRACES for that product line, and you do not need a country risk assessment for the countries you source tea from, because the country benchmarking under Commission Implementing Regulation (EU) 2025/1093 only matters for the commodities the regulation actually covers.

That is a narrower exemption than it first sounds, because three situations pull tea-adjacent businesses back into scope:

Situation	In scope?	Why
Pure tea leaf, loose or bagged, no other ingredients	No	Tea is not an Annex I commodity
Tea blended with cocoa, coffee or an Annex I derivative (e.g. a chai concentrate with cocoa solids, a coffee-and-tea gift hamper sold as one product)	Depends on the specific product and CN code	The cocoa or coffee component may bring that product within scope even where the tea itself would not be
Flavoured or herbal "tea" that is not Camellia sinensis but is grown on converted forest land (e.g. certain rooibos or herbal blends)	No, unless it is itself an Annex I product	Being grown on deforested land is an environmental and reputational issue, not an EUDR trigger, unless the plant is a listed commodity
Wooden tea chests, crates or certain paper-based packaging and point-of-sale materials	Possibly, for the packaging itself	Wood and some paper products remain in scope independently of what they contain — see the guides below

The practical trap is the second row. A retailer selling a "coffee and tea" hamper, or a drinks manufacturer blending a tea base with cocoa solids, needs to check the CN code of the finished product and each Annex I ingredient in it, not assume the whole line is exempt because tea is the headline ingredient. EUDR for cocoa and chocolate makers sets out how cocoa content triggers obligations even in a mixed product, and the same logic applies to any coffee content in a blended drink.

Packaging is the other real exposure

Tea businesses that conclude they have no EUDR exposure at all are usually overlooking packaging, not the tea. Wood products remain in Annex I regardless of what they are used to transport or display, so wooden tea chests, display crates, and certain wood-pulp-based packaging can themselves be in scope as a separate product line, assessed on their own CN code and their own supply chain — entirely independent of the tea inside them. Printed products such as tea packet inserts and promotional literature were excluded from scope by Regulation (EU) 2025/2650, which narrows this further, but a standalone wooden crate or wood-pulp carton does not get that exclusion automatically. If your tea import business also imports or commissions wooden packaging, treat that as its own due diligence question, not an extension of the tea question.

Does any certification or scheme cover tea for buyers who want reassurance?

Tea has its own long-standing certification landscape — Rainforest Alliance, Fairtrade and organic certification are all well established in tea — but none of it exists because of the EUDR, and none of it creates an EUDR obligation where none otherwise applies. FSC, RSPO and Rainforest Alliance certification do not satisfy EUDR due diligence even for products that are in scope; for tea, the point is simpler still, because there is no EUDR due diligence duty to satisfy in the first place. A buyer who wants assurance that their tea is not linked to deforestation can still ask for it commercially, through these schemes or through their own supplier audits — that is good practice, and plenty of serious tea buyers already do it — but it is not something the regulation requires or checks.

What tea importers should still watch

Three things are worth tracking even though they change nothing today:

• The April 2026 scope review. If the Commission's review of the regulation's administrative burden leads to a proposal to widen Annex I, tea could in principle be raised again. Nothing in the public record of that review names tea as a candidate.
• Blended and multi-ingredient products. Any new product line that combines tea with cocoa, coffee, or another Annex I ingredient needs its own CN code check, done at launch, not assumed from the rest of the range.
• Your own packaging supply chain. Wooden crates, wood-pulp cartons and similar packaging are assessed on their own terms, and a packaging supplier switch can change your exposure even if your tea sourcing does not change at all.

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

Where tea sits against the deadlines that do apply to you

Because tea itself carries no EUDR deadline, this table only matters if some part of your business handles a commodity that is in scope:

Business handles	Application date
Tea only, no Annex I commodity or derivative	No EUDR date applies
Coffee, cocoa, cattle, oil palm, rubber or soy alongside tea — 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
Wood packaging used for tea, any size	30 December 2026 (large/medium) or 30 June 2027 (micro/small, where the EU Timber Regulation carve-out does not apply)

See which application date applies to your business for how operator size is worked out, and why the Timber Regulation carve-out removes the later date for some micro and small businesses handling wood products specifically.

The bottom line

Tea is excluded from the EUDR by the same mechanism that puts coffee inside it: a fixed commodity list in Annex I, not a general test of deforestation risk. That exclusion is specific to the plant itself. It does not extend automatically to blended products containing an Annex I ingredient, and it does not extend to packaging, which is assessed separately. A pure tea business has no EUDR due diligence statement to file; a business that sells tea alongside anything on the Annex I list needs to check that other part of its range on its own terms.