EUDR is still commonly associated primarily with timber. In reality, Annex I covers seven categories of commodities and a wide range of derived products, which means that the regulation may affect a much broader group of businesses.
EUDR covers seven categories of commodities
The legal basis is Regulation (EU) 2023/1115 of 31 May 2023, which entered into force on 29 June 2023.
The application dates were subsequently postponed by Regulation (EU) 2025/2650. The new obligations are due to apply from 30 December 2026 for large and medium-sized operators and from 30 June 2027 for micro and small operators.
EUDR covers cattle, cocoa, coffee, palm oil, rubber, soy and wood, together with derived products listed in Annex I by reference to specific Combined Nomenclature codes.
The scope also includes less obvious products
The regulation covers certain products that are not commonly associated with deforestation.
Examples include retreaded tyre products under CN code 4012, wooden furniture and parts thereof under CN code 9403, and crude palm kernel oil under CN code ex 1513 21.
In practice, this means that a business dealing in goods listed in Annex I may qualify as an operator, downstream operator or trader for EUDR purposes, regardless of its main industry.
EUDR may affect a wide range of sectors
The regulation directly affects, among others, the food sector, through cocoa, coffee and cattle-derived products, and the furniture sector, through timber and wood products.
The cosmetics sector is in a different position. A finished cosmetic product with its own CN code may fall outside Annex I. However, EUDR obligations may arise earlier in the supply chain, for example for producers or importers of palm oil where that commodity is itself being placed on the EU market.
This means that a company’s business profile alone does not determine whether EUDR applies. The decisive factor is the specific product and its CN classification.
Penalties may be significant
Depending on the type of infringement, the regulation provides for financial penalties and other sanctions.
In the case of repeated infringement, the fine may reach up to 10% of the operator’s annual turnover in the financial year preceding the year in which the infringement occurred.
For businesses, this means that correct product classification should be one of the first steps in preparing for EUDR compliance.
The key conclusion is straightforward: the scope of EUDR extends far beyond timber, and whether a product falls within the regulation depends primarily on whether it is listed in Annex I under the relevant CN code.
Please contact us if your organisation requires support in determining whether the goods it imports, supplies or trades fall within the scope of EUDR.
We support businesses in analysing CN classifications and determining whether specific products are included in Annex I to EUDR. We also help identify the entity’s role in the supply chain and the obligations resulting from that role.
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