Changes in EU Deforestation Regulation (EUDR)

On 13 July 2026 the European Commission adopted a delegated act that changes the product scope of the EU Deforestation Regulation (EUDR), the law that will require companies to prove their goods are not linked to deforestation before selling them in, or exporting them from, the EU. The regulation itself has not been reopened. Instead, the Commission has updated Annex I, the list that sets out, product by product, which goods fall under the rules. Soluble coffee and palm oil derivatives are now in scope; cattle leather, most of a re-treaded tyre, and several rubber and vehicle products are out; and exemptions for waste, used goods and packaging are confirmed. For most businesses it comes down to one question: is your product still on the list?

What does the delegated act change?

The EUDR covers seven commodities: cattle, cocoa, coffee, palm oil, rubber, soya and wood, plus a long list of products made from them. Annex I lists each covered product by its Combined Nomenclature (CN) customs code. If your product’s code is on the list, the rules apply; if it is not, they do not, whatever it is made from. That is why a change to Annex I can shift real obligations for companies while the main rules stay the same.

The change is part of a simplification package the Commission published on 4 May 2026, together with a review report, updated guidance, and an improved system for filing due diligence statements. The draft was open for public feedback until 1 June 2026. The version adopted on 13 July 2026 keeps the additions from the draft and removes more products than the draft did, following that feedback. It now goes to the European Parliament and the Council for scrutiny before it can take effect.

Which products have been added to the scope?

The products added share a common thread. Each is made from a commodity that is already covered but had fallen outside the list, which meant deforestation risk could shift into the part of the supply chain the rules did not reach.

Soluble, or instant, coffee is the clearest case. Green and roasted beans were already covered, but extracts, essences and concentrates of coffee (CN 2101 11 00) were not, despite coming from the same plant. Frozen cattle tongues (CN ex 0206 21 00) are added for the same reason, matching the fresh tongues already covered.

The largest group of additions is in palm oil. Annex I did not cover the full range of oleochemicals, the fatty acids, fatty alcohols and glycerol made from palm oil and used in cosmetics, detergents, lubricants and food. These are now covered where oil palm was used to make them, along with soap containing palm oil. What matters here is the raw material, not the product name, so the change lands hardest on chemicals and consumer goods firms.

Which products have been removed?

The removals go in the opposite direction. They take out products where the effort of compliance was seen as too high for the environmental gain. The clearest case is cattle leather: raw, tanned and finished hides and skins (CN 4101, 4104 and 4107) come off the list. Leather is a low-value by-product of the meat trade, and companies buying finished leather have little influence over suppliers far up the chain, so getting reliable deforestation data from them is hard.

Re-treaded tyres largely come out too: only the new rubber tread stays in (CN 4012 90 30). The adopted act goes further than the May draft and also removes soybeans for sowing, articles of vulcanised rubber, conveyor and transmission belts, and aircraft and vehicle seats. Every product taken out is one less item that needs a due diligence statement.

What is exempt, and what has been clarified?

The delegated act also settles several grey areas. Waste and used goods are now clearly outside the rules: anything that counts as waste under the EU Waste Framework Directive, along with used and second-hand products, will not need due diligence. The aim is to avoid penalising repair, reuse and recycling.

Samples and testing products are exempt, since it makes little sense to apply full due diligence to goods that are used up or destroyed in analysis. Packaging is dealt with both ways: packaging that simply carries another product, whether single-use or reusable, is out, but packaging sold as a product in its own right is not. Marketing materials, correspondence and inputs used to make medicines are also excluded.

Finally, the act is precise about which species and materials count. Cattle means the Bos genus, not buffalo or bison; oil palm means Elaeis, not babassu; rubber means Hevea, not synthetic rubber or gums such as gutta-percha. For wood, bamboo, rattan, reeds and lime bark are left out. Where an entry carries the prefix “ex”, the code applies only when one of the covered commodities was actually used.

In scope or out: a quick reference

When do the new rules apply?

The scope changes do not affect when the EUDR starts to apply. The main date stays 30 December 2026 for large and medium-sized operators and traders, and for micro and small operators already covered by the EU Timber Regulation; other micro and small operators have until 30 June 2027. Products that have just been added get more time and only fall under the rules from 30 December 2027.

The extra year for added products helps, but companies are in an awkward spot: the delegated act is adopted yet not final, so they must plan around the new scope while accepting that details could change during scrutiny. We will update this article once it is published in the Official Journal.

A simplification wave, or business as usual?

Step back from the detail and a pattern appears. The EUDR has been changed several times before it has even started. It entered into force in June 2023 with a start date of December 2024, which was pushed back to December 2025 and then December 2026; the December 2025 change also eased the rules for downstream companies. A simplification review followed in spring 2026, and this delegated act is its final piece. The Commission estimates the whole package could cut affected companies’ yearly compliance costs by around 75% compared with the original design.

The EUDR is not being changed on its own. Since early 2025 the EU has been running a clear simplification agenda, prompted by concerns about competitiveness. The sustainability Omnibus reset the thresholds and timelines of the Corporate Sustainability Reporting Directive and the Corporate Sustainability Due Diligence Directive, while other packages have reworked the EU Taxonomy, the carbon border adjustment mechanism, and rules on chemicals, data and tax. Between January 2025 and June 2026 the Commission put forward twelve of these packages, aiming to cut recurring administrative costs by 37.5 billion euros over the current mandate.

So is this a lasting change of approach, or a one-off correction? There is a case on each side. On the positive side, the core law has not been touched, and the changes fix real problems that companies raised. On the other, businesses that moved early now face shifting requirements, and constant change can weaken the certainty that rules are meant to give. What seems clear is that companies should treat EU regulation in this area as something to keep watching, rather than a fixed target they can set once and forget.

What should businesses do now?

The first step is to check your products again against the updated Annex I, paying close attention to derived products and raw materials, not just finished goods. For anything newly covered, start talking to suppliers and gathering data now, because proof that goods are deforestation-free, and the geolocation records behind it, take time to collect. For products that have been removed, you can stand down the related checks, keeping a written note of why.

At its heart, the EUDR is a data challenge. It means collecting, checking and storing details of origin, geolocation and due diligence for large numbers of products, and being able to produce them whenever they are requested. An ESG data management platform gives compliance teams one place to keep supplier evidence and link it to the products and codes it relates to, with a clear audit trail. Because the EUDR sits alongside the wider simplification of environmental legislation, the same suppliers and data often cover several requirements at once.

At Generation Impact Global, we help investors, companies and their portfolio businesses turn changes like these into clear, well-documented data processes that work across the main sustainability frameworks.