EUDR product scope changes: are you now in scope?

Alba Selva Ortiz avatar Alba Selva Ortiz · · 3 min read
EUDR product scope changes: are you now in scope?

Photo by Trac Vu on Unsplash

If you import or sell instant coffee, palm-oil soap or oleochemical derivatives, read this. The Commission has just adjusted the list of products covered by the EU Deforestation Regulation, and some that were previously outside are now in. Others that were in are now out.

What hasn’t changed is the part that matters: the deadlines hold.

What moved

On 4 May 2026 the Commission published an EUDR simplification package: a review report, updated guidance and FAQs, and a draft delegated act touching Annex I, the list of covered products. The public consultation on that draft ran for four weeks and closed on 1 June. It runs in parallel with the revised ESRS consultation, part of the same Omnibus simplification drive.

The scope changes, specifically:

Added: soluble (instant) coffee and certain palm-oil derivatives, for example soap made with palm oil and oleochemical derivatives. Also frozen cattle tongues.

Removed: leather, and retreaded tyres are no longer covered in full, the obligation applies only to the new rubber tread. Also excluded: product samples, certain packing materials, used and second-hand products, and waste.

One key point: the text of the Regulation is not being reopened. The Commission has been clear on this. These are technical adjustments to scope, not a substantive reform.

The dates: unchanged, and that’s the news

This is where a lot of people take a deep breath hoping for another delay. There isn’t one.

Large and medium-sized companies: comply from 30 December 2026. Micro and small operators (outside the timber sector): from 30 June 2027. The EUDR has already been pushed back twice; this time the Commission is pressing ahead with the agreed timeline.

And watch a nuance that hits smaller firms: micro and small companies already covered by the old Timber Regulation (EUTR) must meet EUDR obligations for timber products by 30 December 2026, the same date as the large ones. The extended June 2027 deadline only applies to them for products made from other raw materials.

The real problem, again, is the data

The EUDR asks you to prove three things about each product: that it’s deforestation-free, that it was legally produced, and that it’s covered by a due diligence statement. For that, you need to know where everything comes from. Plot geolocation. Traceability back to origin. Supplier documentation.

If you’ve just entered scope through soluble coffee or palm derivatives, the clock is running and the challenge isn’t understanding the Regulation, it’s having your supply-chain data connected and traceable. Who sells you what, from where, with what evidence behind it.

And here’s the connection a lot of companies miss: this isn’t a “sustainability” problem living in a separate department. It’s a purchasing and supplier data problem. The same data you already handle to operate, what you buy, from whom, where, is what the EUDR requires you to have in order. If it lives scattered across emails and each supplier’s PDFs, every due diligence statement is manual work from scratch. If it’s connected to your operations, the statement comes out of data you already hold.

The format of the product list changes, you’ve just watched it change. The data on who’s in your chain doesn’t. If you’ve got it connected, it makes no difference whether they add or drop a category tomorrow: you already know what’s in and where it comes from.

Could you say today, for each supplier, whether what they sell you falls under the new scope and what traceability you hold? If the answer is “I’d have to email each one and ask”, there’s your work for the coming weeks. Book a demo and we’ll show you how to connect it once.

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