With two new legal acts (here and here), the European Commission laid the groundwork on 13 July 2026 for the practical implementation of the EU Deforestation Regulation (EUDR). Shortly before the Regulation comes into force at the end of 2026, a number of key products will be removed from its scope.
The EUDR aims to ensure that certain goods and products placed on the EU market or exported from the EU do not contribute to deforestation. The commodities affected are cattle, cocoa, coffee, palm oil, rubber, soya and timber, as well as numerous products manufactured from them. In future, companies will have to demonstrate, through appropriate due diligence measures, that their products are deforestation-free and have been produced in accordance with the legislation of the country of origin. Following the postponement of the implementation deadlines agreed in December 2025, the Regulation will apply from 30 December 2026 to large and medium-sized enterprises and from 30 June 2027 to other micro and small enterprises.
The most significant changes relate to Annex I of the EUDR, i.e. the catalogue setting out which products fall within its scope.
Cowhides and leather, retreaded tyres, soya beans for sowing, certain vulcanised rubber products, conveyor and drive belts, and motor vehicle and aircraft seats are being removed. In doing so, the Commission is replacing the previous, broad HS code ex 9401 (wooden seats) with a specific list of subheadings for wooden seats, which no longer includes motor vehicle and aircraft seats due to their low wood content.
New additions, however, include soluble coffee, numerous palm oil derivatives from the oleochemical supply chain (including certain fatty alcohols, fatty acids and soaps), and frozen beef tongues. A transitional period until 30 December 2027 applies to the new products.
The Commission is also using this revision to clarify ambiguities. The Commission is also using this revision to clarify ambiguities. For the first time, it is being made clear which species fall under the individual raw material categories: For example, only cattle of the genus Bos are covered (not buffalo or bison); for rubber, only Hevea brasiliensis (not synthetic rubber); and for wood, no products made from bamboo, rattan or other wood-like materials. The following will be expressly excluded from the scope of application in future: samples and specimens for analysis and testing purposes, waste products, used and reused goods, certain packaging materials, as well as marketing and information materials (e.g. labels) that accompany another product or are provided free of charge for marketing purposes, and correspondence. In addition, certain palm oil derivatives are excluded from the scope of application insofar as they are used in the manufacture of medicinal products for human or veterinary use.
In parallel, the Commission has adopted an Implementing Regulation (Regulation (EU) 2026/1565), which comprehensively revises the existing rules governing the operation of the EUDR information system. This is primarily in response to the implementation of the amendments to the EUDR adopted at the end of 2025, which, amongst other things, exempt downstream market participants and traders from the obligation to submit due diligence statements and introduced the new category of ‘micro or small primary producers’.
Key changes to the information system include:
In its press release, the Commission also announces regular training sessions for businesses from the end of July 2026.
The two legal acts complete the Commission’s simplification package for the EUDR, which was presented in May 2026 (for further details, see our blog post from May 2026). Key components of the package include, in particular, the revised guidance on the application of the Regulation and the update to the Commission’s comprehensive FAQs.
Despite the exclusion of certain product groups and targeted clarifications, the EUDR remains a far-reaching regulatory measure in the field of sustainable supply chains.
Companies should – if they have not already done so – check as soon as possible whether their products fall within the scope of the Regulation, what supply chain information will need to be collected in future, and whether existing compliance systems need to be adapted. Whilst the clarifications now published offer greater legal certainty, they do not alter the extensive evidence and documentation requirements that market participants will face once the Regulation comes into force. Affected companies should also bear in mind that the exclusion of bovine hides and leather is not necessarily permanent: the Commission has announced that it will evaluate the possibility of re-including them – including downstream leather products – as part of the general review of the EUDR in 2030.
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