Covered products and commodities
The 7 commodities (soy, beef, palm oil, wood, cocoa, coffee, rubber), Annex I derived products, and associated CN codes.
Related tool: - Try the tool →The seven commodities
Annex I of Regulation 1115/2023 defines the scope of the EUDR through seven relevant commodities and a comprehensive list of derived products identified by their CN (Combined Nomenclature) codes. The selection reflects the commodities most closely associated with global deforestation.
| Commodity | Share of global deforestation | Primary producing regions |
|---|---|---|
| Cattle (beef) | ~40% (grazing + feed crops) | Brazil, Argentina, Paraguay |
| Soy | ~20% (direct + indirect) | Brazil, Argentina, Paraguay, USA |
| Palm oil | ~12% | Indonesia, Malaysia, Papua New Guinea |
| Wood | ~10% (logging + expansion) | Brazil, DRC, Indonesia, Russia |
| Cocoa | ~7% | Cote d'Ivoire, Ghana, Cameroon |
| Coffee | ~5% | Brazil, Vietnam, Colombia, Ethiopia |
| Rubber | ~4% | Thailand, Indonesia, Cote d'Ivoire |
1. Soy (Glycine max)
Soy cultivation is one of the leading drivers of deforestation in South America, particularly in the Brazilian Cerrado and the Gran Chaco region spanning Argentina, Paraguay, and Bolivia.
Key CN codes (Annex I extract):
- 1201 -- Soya beans, whether or not broken
- 1208 10 -- Soya bean flour and meal
- 1507 -- Soya-bean oil and its fractions
- 2304 -- Oilcake and other solid residues from soya-bean oil extraction
- 3505 10 -- Dextrins and modified starches from soya
Derived products include: soy lecithin (widely used in food manufacturing), soy protein isolates, soy milk, tofu, animal feed containing soy meal, biodiesel from soy oil. The supply chain is extensive -- soy meal is the primary protein source in European livestock feed, meaning the EUDR affects the entire European meat and dairy industry indirectly.
EU import volumes: approximately 33 million tonnes of soy beans and soy meal per year, primarily from Brazil (~50%), the United States (~25%), and Argentina (~15%).
2. Cattle and beef
The cattle commodity covers both live animals and a wide range of derived products, reflecting the outsized role of cattle ranching in tropical deforestation.
Key CN codes (Annex I extract):
- 0102 -- Live bovine animals
- 0201, 0202 -- Meat of bovine animals (fresh, chilled, frozen)
- 0206 -- Edible offal of bovine animals
- 0210 -- Meat, salted, smoked, dried
- 4101 -- Raw hides and skins of bovine animals
- 4104 -- Tanned or crust hides and skins of bovine animals
- 4107 -- Leather further prepared after tanning
- Various -- Leather articles, canned meat, gelatin, tallow
Key point: the regulation covers the entire value chain from live cattle through to finished leather goods. A European fashion brand sourcing leather handbags must trace the material back to the farm level.
EU import volumes: approximately 300,000 tonnes of beef per year, with significant flows from Brazil, Argentina, Uruguay, and Australia. Leather imports add another layer of complexity.
3. Palm oil (Elaeis guineensis and Elaeis oleifera)
Palm oil is the world's most consumed vegetable oil and a major driver of deforestation in Southeast Asia and increasingly in West Africa and Central America.
Key CN codes (Annex I extract):
- 1511 -- Palm oil and its fractions
- 1513 11 -- Crude coconut (copra) oil (when derived from oil palm)
- 2915 70 -- Palmitic acid, stearic acid, salts and esters
- 3823 -- Industrial monocarboxylic fatty acids
- 3826 00 -- Biodiesel from palm oil
- Various -- Glycerol, soap, cosmetic preparations containing palm derivatives
Derived products are pervasive: palm oil and its derivatives are found in approximately 50% of packaged supermarket products -- from margarine, chocolate, and instant noodles to shampoo, lipstick, and industrial lubricants. The challenge of tracing palm oil through complex refining and blending processes is substantial.
EU import volumes: approximately 6 million tonnes per year, primarily from Indonesia (~55%) and Malaysia (~35%).
4. Wood
The wood commodity has the broadest product coverage, reflecting the EUDR's roots in the former EU Timber Regulation.
Key CN codes (Annex I extract):
- 4401 -- Fuel wood, wood chips, sawdust
- 4403 -- Wood in the rough
- 4407 -- Wood sawn or chipped lengthwise
- 4408 -- Veneer sheets
- 4409 -- Wood continuously shaped (mouldings)
- 4410, 4411 -- Particle board, fibreboard (MDF, HDF)
- 4412 -- Plywood
- 4418 -- Builders' joinery and carpentry of wood
- 4701 to 4707 -- Mechanical and chemical wood pulp
- 4801 to 4823 -- Paper and paperboard products
- 9401 61, 9403 30-60 -- Wooden furniture
- Various -- Printed books (4901), charcoal (4402)
Unique feature for wood: the EUDR also covers forest degradation, defined as structural changes to forest canopy cover reducing it to levels between 10-30% (Article 2(6)). For the other six commodities, only outright deforestation (conversion to agricultural use) is prohibited.
EU import volumes: the EU is the world's second-largest importer of tropical timber. Major sources include Brazil, Indonesia, Cameroon, Republic of Congo, and China (as a processing hub).
5. Cocoa (Theobroma cacao)
Cocoa farming is the primary driver of deforestation in West Africa, where approximately 70% of global cocoa is produced.
Key CN codes (Annex I extract):
- 1801 -- Cocoa beans, whole or broken
- 1802 -- Cocoa shells, husks, skins
- 1803 -- Cocoa paste, whether or not defatted
- 1804 -- Cocoa butter, fat, and oil
- 1805 -- Cocoa powder (unsweetened)
- 1806 -- Chocolate and other food preparations containing cocoa
Supply chain characteristics: cocoa is predominantly produced by smallholders (5-6 million farms globally, average size 2-5 hectares). This fragmentation makes traceability extremely challenging. A single chocolate bar may contain cocoa from hundreds of different farms, blended at multiple stages.
EU import volumes: approximately 3.5 million tonnes of cocoa beans and products per year. The EU is the world's largest cocoa importer and processor. Belgium, the Netherlands, and Germany are major processing hubs.
6. Coffee (Coffea spp.)
Coffee cultivation has historically driven deforestation in Central America, East Africa, and increasingly in Vietnam and Laos.
Key CN codes (Annex I extract):
- 0901 -- Coffee, whether or not roasted or decaffeinated; coffee husks and skins
- 2101 11 -- Extracts, essences, and concentrates of coffee
Supply chain characteristics: like cocoa, coffee is predominantly a smallholder crop (estimated 12.5 million producers globally). However, coffee supply chains are somewhat more structured, with direct trade and certification schemes (Fairtrade, Rainforest Alliance, UTZ) covering a significant share of trade.
EU import volumes: approximately 3 million tonnes of green coffee per year. The EU is the world's largest coffee market, consuming roughly 30% of global production.
7. Rubber (Hevea brasiliensis)
Natural rubber production is increasingly associated with deforestation in Southeast Asia, particularly in Laos, Cambodia, Myanmar, and southern China.
Key CN codes (Annex I extract):
- 4001 -- Natural rubber in primary forms or plates, sheets, strip
- 4005 -- Compounded rubber, unvulcanised
- 4006 -- Unvulcanised rubber in other forms
- 4007 -- Vulcanised rubber thread and cord
- 4010 -- Conveyor or transmission belts
- 4011 -- New pneumatic tyres of rubber
- 4012 -- Retreaded or used pneumatic tyres
- 4013 -- Inner tubes of rubber
- 4015 -- Rubber gloves
- 4016 -- Other articles of vulcanised rubber
Supply chain characteristics: natural rubber is a critical industrial input. Approximately 70% is used in tyre manufacturing. The EUDR therefore affects the entire automotive and transport sector's supply chain.
EU import volumes: approximately 1.2 million tonnes per year, primarily from Thailand (~35%), Indonesia (~25%), and Cote d'Ivoire (~15%).
How to determine if a product is covered
Step 1: Identify the CN code
Use the TARIC nomenclature or the automated classification tool to determine the exact 8-digit CN code of your product. Accurate tariff classification is the foundation -- an incorrect code may lead to non-compliance or unnecessary compliance costs.
Step 2: Check Annex I of Regulation 1115/2023
Compare the CN code against the exhaustive list in Annex I. The annex is structured by commodity: each commodity section lists all derived product CN codes. Note:
- Some entries cover entire 4-digit headings (e.g., 4407 covers all sawn wood)
- Others are specified at 6 or 8-digit level (e.g., 1511 10 90 -- crude palm oil, other)
- CN codes may be updated annually; always check against the current Combined Nomenclature
Step 3: Assess the "relevant" criterion
Not every product containing trace amounts of a covered commodity is automatically in scope. The product must be a "relevant product" as defined in the regulation. However, the list in Annex I is broadly drawn -- composite products containing significant quantities of covered commodities (e.g., chocolate bars, leather shoes, wooden furniture, tyres) are generally covered.
Practical decision matrix
| Your situation | Covered? | Obligation |
|---|---|---|
| Import raw soy beans from Brazil | Yes | Full due diligence (operator) |
| Buy chocolate bars from a German distributor | Yes | Trader obligations (verify due diligence statement) |
| Import leather handbags manufactured in Italy from Brazilian hides | Yes | Operator (Italian manufacturer must trace to farm) |
| Import synthetic rubber tyres (no natural rubber) | No | Not in scope |
| Export French oak lumber to the United States | Yes | Export due diligence required |
| Import recycled paper from China | Yes | Paper/pulp CN codes in Annex I; must verify origin of wood fibre |
Derived products -- the complexity challenge
The EUDR's scope extends well beyond raw commodities. Derived products create a complex compliance landscape:
Food industry: soy lecithin in biscuits, palm oil in margarine, cocoa butter in confectionery, coffee extracts in ready-to-drink products. Food manufacturers must trace ingredients to the plot of land.
Fashion and leather: bovine hides pass through tanneries, often in multiple countries, before becoming leather goods. The traceability chain from Brazilian ranch to Italian shoe factory can involve 4-7 intermediaries.
Paper and packaging: wood pulp from multiple countries may be blended in a single paper mill. A cardboard box may contain fibre from dozens of forest concessions across multiple continents.
Automotive and industrial: natural rubber in tyres, palm oil derivatives in industrial lubricants, wood-based activated carbon in filtration systems.
Cosmetics and personal care: palm oil derivatives (glycerine, sodium lauryl sulphate, stearic acid) appear in the majority of personal care products under names that obscure their origin.
For each of these sectors, operators must be able to demonstrate the deforestation-free status of the raw commodity at the plot level, regardless of how many processing steps intervene.
Verify whether your products are covered by the EUDR
Frequently Asked Questions
- Are products containing only trace amounts of a covered commodity (e.g., soy lecithin in biscuits) in scope?
- Yes, if the product falls under a CN code listed in Annex I of Regulation 1115/2023. The regulation does not provide a de minimis threshold based on the percentage of a covered commodity in a product. Soy lecithin (CN 2923 20), for example, is explicitly listed. Operators must conduct due diligence on the soy used to produce the lecithin, regardless of the quantity in the final product.
- Does the EUDR apply to recycled or second-hand products?
- The regulation focuses on products that contain or have been made using relevant commodities. Recycled paper is covered because it originated from wood pulp. However, there is ongoing discussion about how to handle products where the original commodity has been recycled multiple times. The Commission is expected to provide guidance on this point. Second-hand leather goods or wooden furniture sold on the secondary market are generally not considered to be "placed on the market" for the first time.
- How do I handle products sourced from multiple countries or plots?
- The EUDR requires geolocation data for each plot of production land. For blended products (e.g., coffee from multiple origins), you must provide geolocation data for all plots that may have contributed to the final product. Segregation of supply chains or equivalent traceability systems are essential. See chapter 4 on geolocation and traceability for detailed guidance.
- Are synthetic alternatives to covered commodities (e.g., synthetic rubber) in scope?
- No. Only products derived from the seven natural commodities listed in the regulation are covered. Synthetic rubber (derived from petroleum), synthetic leather, or lab-grown meat are not in scope. However, products blending natural and synthetic materials (e.g., tyres containing both natural and synthetic rubber) are covered for the natural rubber component.
- Will the list of covered commodities be expanded?
- Article 36 of Regulation 1115/2023 mandates a review by 30 June 2025 to assess whether to extend the scope to additional commodities (maize, poultry, pork), other ecosystems (wetlands, peatlands, savannahs), and financial institutions. An update is expected, but no formal legislative amendment has been adopted as of April 2026.