The seven EUDR commodities
The EU Deforestation Regulation covers seven commodities and the products derived from them. Here is an importer’s guide to each: what is in scope, what sits just outside it, what to collect, and when it applies.
Scope starts with Article 1(1): seven commodities, and any product that contains them, was made using them, or was fed with them. Which of those products are caught is decided by CN code in Annex I, not by how the product looks. There is no de minimis anywhere in the Regulation: a covered commodity is covered whatever its quantity or value, including inside a processed good.
- 01CoffeeGreen and roasted coffee sit squarely in scope, across long smallholder supply chains.
- 02CocoaCocoa beans and everything downstream, paste, butter, powder, and chocolate, are covered.
- 03CattleBeef, leather, and hides are in scope, with a geolocation rule that differs from crops.
- 04WoodTimber, pulp, paper, printed books, and furniture. The broadest derived-product list of the seven.
- 05RubberNatural rubber and the products made from it, including tyres, fall under the EUDR.
- 06SoyaSoybeans, soy meal, and soy oil are covered, a lot of it entering as animal feed.
- 07Oil palmPalm oil and its derivatives, common as an ingredient far from the visible label.
How to read Annex I
Annex I is a table of CN headings, and two of its conventions decide most borderline cases. A row prefixed ex is partial scope: only the subset described in the row is caught, which is why every rubber row means natural rubber and not synthetic, and why only the bovine lines under a meat heading count. And the Annex is versioned: Article 34 lets the Commission amend the codes by delegated act, so a classification is only true as of a date.
Packaging has its own rule. Packaging used exclusively to support, protect or carry another product is out, but packaging sold or rented in its own right is a product like any other and is in. The pattern to expect across all seven is that the boundary sits mid-chain: the commodity and its first transformations are listed, and the finished consumer article usually is not.
What every commodity needs
Whichever of the seven you handle, the substantive test is the same three cumulative conditions: the product must be deforestation-free after 31 December 2020, legally produced under the law of the country of production, and covered by a statement. In practice that means plot geolocation, legality and deforestation-free evidence, and a Due Diligence Statement filed before the goods move. The deadlines decide when that starts, and EUDR for SMEs decides which date is yours.
Sources
Collect the plots once. File every shipment after.
Bindu holds the geolocation, the legality evidence, and the audit trail in one record, and assembles the statement from it when a shipment moves.