EUDR scope expanded

The EUDR Regulation (Regulation (EU) 2023/1115) is one of the most impactful recent acts for food supply chains.

It aims to reduce greenhouse gas emissions and biodiversity loss by boosting the consumption of ‘deforestation-free’ products and by reducing the EU’s impact on global deforestation and forest degradation, but it will end up impacting data management and traceability, raw material prices, certification fraud, trade routes, and supply chain configuration. And in my humble opinion, such impacts will be more profound than the environmental footprint.

The newly published Commission Delegated Regulation (EU) 2026/2102 changes Annex I of the EUDR Regulation. For some supply chains, it means more products entering scope.

News:

➡️ Coffee: soluble coffee joins the list.
Code 2101 11 00 adds coffee extracts, essences and concentrates, including soluble coffee. This closes the gap between coffee beans already covered and certain processed coffee products previously outside the scope.

It does not automatically bring every coffee-containing food or beverage into EUDR.

➡️Palm derivatives: look beyond palm oil.
New entries include certain hydrogenated or interesterified palm oils, crude glycerol, and specified fatty acids, salts, and esters, even if this is of more interest for the oleochemical industry and for food additives.

The botanical clarification expected specifies that the EUDR covers Elaeis species, while excluding babassu and oils from other palm species.

➡️Cattle: tongues in
Frozen cattle tongues are added under ex 0206 21 00.

🚩 Samples and testing: useful relief, with conditions.
Samples must be of negligible value and quantity, with presentation and quantities restricting their use to soliciting orders.
Products for examination, analysis or testing must be consumed or destroyed during that activity, or retained or returned solely to meet related legal or contractual obligations.
If those conditions are met, EUDR is not applicable.

The newly added product categories apply from 30 December 2027.

This is not a general EUDR postponement: the broader timetable remains 30 December 2026 for large and medium operators and 30 June 2027 for other micro and small operators, subject to the timber exception.

We have an upcoming webinar with an early-bird discount until 30th September, and this is perfect timing to complete the legal picture. For more info and subscriptions, CLICK HERE.