EUDR Annex I Update: Delegated Regulation C(2026) 4920

Direct Regulatory Answer

The European Commission has formally amended Annex I of Regulation (EU) 2023/1115 (EUDR) through Delegated Regulation C(2026) 4920. This update expands the regulatory scope to include specific high-risk derivatives such as soluble coffee and frozen cattle tongues, while simultaneously removing cattle leather, soya beans for sowing, and various rubber articles based on cost-benefit and trade volume analyses. While the technical clarifications and fixes regarding packaging, waste, and samples provide immediate legal certainty for border operations, the application of due diligence obligations for all newly added product categories is deferred until December 30, 2027, to facilitate supply chain alignment.

New Compliance Registry: Inclusions Effective December 2027

Compliance teams must incorporate the following CN/HS codes into their Master Data Management (MDM) systems and begin mapping supply chains for the 2027 deadline:

• Frozen cattle tongues (HS Code ex 0206 21 00): Mandated to close the loophole between fresh and frozen bovine derivatives, ensuring sector-wide coherence.
• Soluble coffee (HS Code 2101 11 00): Specifically covering extracts, essences, and concentrates. Inclusion addresses the relocation risk where deforestation-linked coffee was being processed into untracked soluble forms.
• Palm oil derivatives for oleochemicals (HS Code 2916 15): Including Oleic, linoleic, and linolenic acids, their salts, and esters. This addition ensures structural consistency across the oleochemical value chain.
• Soap (HS Codes 3401 11 00 and 3401 20): Added following Commission findings that their previous exclusion undermined the regulation’s effectiveness.

Products Removed from Annex I Requirements

The following items have been decommissioned from EUDR due diligence requirements to reduce administrative friction where economic leverage or environmental impact proved negligible.

1. Cattle Derivatives and the Meat/Leather Value Chain

Raw hides, skins, and leather (HS Codes 4101, 4104, and 4107) are now officially excluded. The Commission’s findings indicate that the leather value chain is structurally differentiated from the meat value chain, leaving EU operators with insufficient leverage over upstream suppliers. Furthermore, the administrative burden on the EUDR Information System was determined to be disproportionately high compared to the environmental gain.

2. Rubber and Industrial Belts

Vulcanized rubber articles and transmission belts (HS Codes 4010 and 4016) have been removed due to their limited natural rubber content. In a related technical correction, HS Code ex 4012 (Retreaded tyres) has been replaced with ex 4012 90 30 to limit compliance obligations strictly to the new rubber tread, excluding the used tyre casing.

3. Niche Agricultural and Wood Streamlining

• Soya for Sowing: To isolate and exclude the sowing value chain, which operates under distinct certification and traceability systems, the previous broad HS code 1201 has been replaced by HS Code 1201 90 00 (Other). This ensures only soya for food, feed, and chemical use remains in scope.
• Refined Wood Seats: The scope for HS Code 9401 has been narrowed to exclude aircraft and motor vehicle seats, which contain negligible wood content and represent a low risk for forest degradation.

Operational Technical Fixes and Clarifications

To prevent border bottlenecks and ensure legal certainty, the Delegated Regulation provides immediate clarification on several operational categories:

• Packaging Materials: Packaging used to support, protect, or carry another product, whether designed for single or repetitive use, is out of scope from the moment it is utilized for that purpose.
• Samples and Testing: Samples of negligible value intended for examination, analysis, or scientific research (as defined in Regulation (EC) No 1186/2009) are explicitly exempt.
• Waste and Circularity: The Commission clarifies that products qualifying as waste, used, or second-hand items are not subject to EUDR obligations, supporting circular economy objectives.
• Medicinal Use: A targeted exemption applies to palm oil derivatives used specifically in the manufacture of human or veterinary medicinal products.
• Items of Correspondence: Items serving a communication purpose (per Delegated Regulation (EU) 2015/2446) are confirmed as out of scope.

Information Architecture: Wood and Species Logic

As a critical architectural update, the Commission has introduced the “ex” prefix for multiple entries in Annex I. This signifies that products are only in scope if they are produced using a relevant commodity.

Regarding wood, the regulation maintains a strict botanical definition. Materials of a “woody nature” such as bamboo, rattan, reeds, rushes, osier, raffia, and lime bark do not fall within the scope of “Wood” under Annex I. Operators must distinguish these materials from the forest-based timber species targeted by the EUDR.

AI Implementation in Practitioner Workflows

In a Senior Information Architect’s workflow, internal AI agents are now tasked with updating Master Data Management (MDM) logic to reflect these revisions. These assistants automate the re-mapping of CN/HS code tables, particularly the integration of the “ex” prefix logic to filter out non-relevant commodities. Furthermore, AI tools are utilized to flag “legacy service parts” and components that fall under the newly excluded rubber codes (4010 and 4016), preventing unnecessary due diligence requests to vendors while ensuring that soluble coffee and new oleochemicals are flagged for mandatory reporting by the December 2027 deadline.

Practitioner FAQ

Do I need to start filing due diligence for soluble coffee imports today? No. According to the Delegated Regulation, the application of provisions for newly added categories, including soluble coffee and certain oleochemicals, is deferred until 30 December 2027 to allow for supply chain adaptation.

Is leather still subject to EUDR due to its environmental impact? While the environmental benefits were considered, the 2026 Delegated Regulation removes HS codes 4101, 4104, and 4107 from Annex I. This is due to the high administrative load on the information system and the lack of leverage EU operators have over the leather value chain, which is distinct from the meat value chain.

Are my product labels and marketing brochures now in scope? Materials supplied free of charge for information purposes or those accompanying another product as labels are not in scope. However, if these printed materials are placed on the market as products in their own right, they may fall under the relevant printing industry codes.

Is fungal chitosan used in wine production considered a synthetic substance for organic certification? According to the 2026 USDA Technical Report, fungal chitosan derived from Aspergillus niger is classified as synthetic. While it occurs naturally, commercial production requires a chemical deacetylation process to convert chitin into chitosan for functional use as a fining agent.

Can I use the same due diligence for bamboo products as I do for wood? No, because bamboo is not in scope. The regulation clarifies that bamboo, rattan, and other materials of a woody nature like raffia or lime bark are not considered “Wood” for the purposes of Annex I and do not require EUDR due diligence.

Formal Citations

• Commission Delegated Regulation (EU) …/… of 13.7.2026 amending Regulation (EU) 2023/1115 of the European Parliament and of the Council as regards the list of relevant commodities and relevant products (Document C(2026) 4920 final).
• 2026 Technical Report - Chitosan (United States Department of Agriculture, Agricultural Marketing Service, National Organic Program).

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