EUDR Annex I Final: What the 13 July 2026 Delegated Act Actually Decided
The draft is dead. Long live the adopted act.
On 13 July 2026, the European Commission moved the EUDR product scope from "proposed" to "decided." On 13 July 2026, the Commission adopted two measures: a Delegated Act updating and simplifying the list of products covered under Annex I of the EUDR, and an Implementing Act setting out the functioning of the Information System for submitting due diligence statements and simplified declarations. If your compliance programme was still treating the May 2026 draft as a working assumption, that assumption now needs updating.
This post covers only what became final on 13 July - the removals, the additions, the new exemptions, and the important legal caveat that still applies. For background on the May draft, see our earlier post on the 2026 simplification package.
What the 13 July Act Does (and Doesn't) Change
Before diving into the product lists, one clarification that trips up a lot of readers:
The seven covered commodities are unchanged. The Delegated Act does not alter the list of cattle, cocoa, coffee, palm oil, rubber, soy, and wood. It only updates Annex I — the list of derived products made from those commodities that trigger due diligence obligations.
This matters because companies sometimes conflate "commodity" with "product." A business trading raw green coffee beans was always in scope and remains so. What changed is which downstream, processed, or manufactured goods derived from those commodities are caught.
Products Removed from Scope
The Delegated Act removes the following products from Annex I: cattle hides, skins and leather; re-treaded tyres; soybeans for sowing; articles of vulcanised rubber; conveyor and transmission belts; and aircraft and motor vehicle seats.
Here is what each removal means in practice:
| Product Removed | Who Is Affected | Practical Implication |
|---|---|---|
| Cattle hides, skins and leather | Tanneries, leather goods, footwear, automotive interiors | No longer required to submit due diligence statements for leather products. Significant relief for the leather supply chain. |
| Re-treaded tyres | Tyre retreaders, fleet operators, logistics | Retreaded tyre products exit scope; virgin rubber tyres remain in scope. |
| Soybeans for sowing | Agricultural seed traders, crop input distributors | Soy seed for planting is out; soy for feed, food, and processing remains in scope. |
| Articles of vulcanised rubber | Industrial rubber goods manufacturers | Broad category of rubber-based manufactured goods no longer triggers EUDR obligations. |
| Conveyor and transmission belts | Industrial equipment, mining, manufacturing | Specific rubber-derived industrial components removed from scope. |
| Aircraft and motor vehicle seats | Automotive OEMs, aerospace, seat manufacturers | Seats containing leather or rubber components no longer in scope as finished goods. |
The leather removal is the most commercially significant. Leather had been treated as in scope under the original Annex I, creating compliance burdens across the entire leather supply chain - from raw hides through to finished handbags and car seats. That obligation is now gone for the derived product, though operators should note that cattle as a commodity remains covered, so raw cattle-related products further up the chain may still be relevant depending on their specific CN codes.
Products Added to Scope
The Commission did not only narrow the list. Three categories of products were added to Annex I: soluble coffee; certain palm oil derivatives; and frozen cattle tongues.
Soluble coffee is the headline addition for the food and beverage sector. Instant and soluble coffee products were a notable gap in the original Annex I - roasted coffee was in scope, but the soluble/instant form was not. That gap is now closed.
Certain palm oil derivatives - including oleochemicals and soap made using oil palm - address a similar loophole. Palm oil itself was in scope, but some downstream oleochemical derivatives were not, creating an incentive to shift deforestation risk into less-regulated processing steps.
Frozen cattle tongues is a narrower addition, targeting a specific beef offal product that was not previously listed.
The 30 December 2027 Phase-In
To give businesses time to prepare, the newly added products become subject to the EUDR from 30 December 2027 - one year after the general application date of 30 December 2026.
This is a meaningful concession. Companies in the soluble coffee and palm oil oleochemical sectors have roughly 17 months from the adoption date to build their due diligence systems for these newly in-scope products. That is enough time to act deliberately - but not enough time to ignore it.
If you produce or trade soluble coffee, palm oil oleochemicals, or frozen cattle tongues: the 30 December 2027 date gives you a runway, but supplier geolocation data takes time to collect. Start supplier conversations now, even if your formal compliance deadline is a year away.
New Exemptions and Clarifications
Beyond the product list changes, the Delegated Act introduces several targeted exemptions that provide legal certainty for categories that were previously ambiguous.
The following are now explicitly outside the scope of the EUDR: samples and products used for analysis, examination, and testing; waste and used/second-hand products; packing material; and products used in the manufacture of medicinal products.
What this means sector by sector:
- Samples and testing materials: Labs, quality control teams, and certification bodies that handle commodity-derived samples no longer need to treat those samples as triggering due diligence obligations. This removes a practical headache for testing and inspection services.
- Waste and second-hand products: Used goods and waste streams derived from in-scope commodities are out. This matters for recyclers, waste processors, and circular economy operators who handle rubber, wood, or leather-derived waste.
- Packing material: Packaging made from in-scope materials (e.g., wood-based packaging) is exempt. Note that this is distinct from the product being packaged - the packaging itself does not trigger a separate due diligence obligation.
- Medicinal product manufacturing inputs: Pharmaceutical manufacturers using palm oil derivatives or rubber-derived materials as manufacturing inputs have a targeted exemption. This addresses concerns raised during the consultation period about the impact on medicine supply chains.
The Scrutiny Caveat: Adopted, But Not Yet Law
This is the most important nuance to communicate to your legal and compliance teams.
The Delegated Act is adopted — but not yet in force. It must now go to the European Parliament and the Council of the EU for a scrutiny period before it enters into force and is published in the Official Journal. Until that happens, the current Annex I text remains the operative legal instrument. In practice, the scope changes are considered settled in substance, but the precise CN codes and final text should be confirmed once the act clears scrutiny.
The Delegated Act now goes to the European Parliament and the Council of the EU for scrutiny before entering into force. The scrutiny period is typically two months, though it can be extended. This means the act could realistically be published in the Official Journal in Q3 or Q4 2026 - well before the 30 December 2026 application date for large and medium operators.
The practical advice: plan your compliance programme around the adopted scope, but do not finalize internal product classification documentation until the Official Journal text is confirmed.
Application Dates: Nothing Has Changed
To be clear: the 13 July Delegated Act does not move any enforcement deadlines.
Application dates remain: 30 December 2026 for large and medium operators and traders (and micro/small operators already covered by the EU Timber Regulation); 30 June 2027 for other micro and small operators.
The only new date introduced is 30 December 2027 for the newly added products (soluble coffee, palm oil derivatives, frozen cattle tongues).
The Information System: Open and Training Incoming
Alongside the product scope changes, the Commission also adopted the Implementing Act governing the EUDR Information System - the platform through which operators submit due diligence statements and simplified declarations.
The Information System reopened at the end of June 2026, and the Commission will offer training sessions for companies starting at the end of July 2026. The updated system introduces simplified declarations for micro and small primary operators and updated API specifications for automated submissions.
If you have not yet registered in the system, now is the time. The acceptance (training) environment is available for testing submissions before you go live.
What to Do Now: A Practical Checklist
Use the widget below to work through whether the 13 July changes affect your specific situation, then follow the steps that apply.
For those who want a structured action plan regardless of the widget outcome:
If your product was REMOVED from scope:
- Update your internal product classification records to reflect out-of-scope status.
- Notify relevant supply chain partners who may have been preparing to provide you with due diligence documentation.
- Wait for Official Journal publication to confirm final CN codes before closing out compliance workflows entirely.
- Keep records of your assessment - enforcement authorities may ask why you concluded a product is out of scope.
If your product was ADDED to scope (soluble coffee, palm oil derivatives, frozen cattle tongues):
- Identify all affected product lines and their CN codes.
- Begin supplier outreach to collect geolocation data for production plots - this is the longest lead-time item.
- Register in the EUDR Information System if you have not already done so.
- Build your due diligence system with a target of being operational well before 30 December 2027.
If you are newly exempt (samples, waste, packing, medicinal inputs):
- Document the basis for your exemption claim internally.
- Ensure your contracts and supplier communications reflect the updated scope.
- Monitor the Official Journal text to confirm the exemption wording matches your use case.
If your scope is unchanged:
- Re-run your product mapping against the updated Annex I once it is published in the Official Journal.
- Confirm your Information System registration is current and test a submission in the acceptance environment.
- Use the Commission's training sessions (starting end of July 2026) to validate your workflow.
The Bigger Picture
These measures build on the December 2025 legislative amendment and complete the May 2026 simplification package, which also included an updated Guidance document and FAQ, now formally adopted in all EU languages.
The 13 July adoption closes the loop on a process that began with the December 2025 amendment and continued through the May 2026 consultation. The product scope is now as settled as it will be before enforcement begins. The Commission has signalled clearly that it does not intend to reopen the regulation's core text or move the deadlines again.
For businesses that have been waiting for certainty before committing to compliance investment, that certainty has now arrived - subject only to the Parliamentary scrutiny formality.
Not sure whether your specific products are in or out under the updated Annex I? Use our free EUDR Scope Checker to get a plain-English assessment, or run through the EUDR Obligations Checker to see exactly what your business needs to do and by when.
Frequently Asked Questions
Does the 13 July Delegated Act change the EUDR's application deadlines?
No. The deadlines remain 30 December 2026 for large and medium operators (and micro/small operators already covered by the EU Timber Regulation) and 30 June 2027 for other micro and small operators. The only new date is 30 December 2027, which applies exclusively to the newly added products: soluble coffee, certain palm oil derivatives, and frozen cattle tongues.
Is the Delegated Act legally binding right now?
Not yet. The act has been adopted by the Commission but must go through a scrutiny period by the European Parliament and the Council of the EU before it enters into force and is published in the Official Journal. In practice, the scope changes are considered settled in substance, but the current Annex I text remains the operative legal instrument until publication.
Leather was previously in scope — is it now completely out?
Cattle hides, skins, and leather as derived products have been removed from Annex I. This means finished leather goods and leather as a processed material no longer trigger EUDR due diligence obligations. However, cattle remains one of the seven covered commodities, so operators dealing with raw cattle products should still check their specific CN codes against the updated Annex I once it is published.
My company handles wood-based packaging. Does the packing material exemption apply?
The Delegated Act introduces a targeted exemption for packing material. This means the packaging itself does not trigger a separate due diligence obligation. However, this exemption covers the packaging — not the product being packaged. If the product inside the packaging is itself in scope (e.g., a wood product), the due diligence obligation for that product still applies.
What is the EUDR Information System and do I need to register now?
The EUDR Information System (built on TRACES NT) is the platform through which operators submit due diligence statements and simplified declarations. It reopened at the end of June 2026 after a period of technical updates. If you are in scope and have not yet registered, you should do so now — the Commission is offering training sessions from the end of July 2026, and the December 2026 deadline is approaching quickly.
The seven commodities are unchanged — so what exactly did change?
The EUDR covers seven commodities (cattle, cocoa, coffee, palm oil, rubber, soy, wood) plus a list of derived products in Annex I. The Delegated Act only changes Annex I — the derived products list. It does not alter which commodities are covered or the core due diligence obligations. If your product is derived from one of the seven commodities, you still need to check whether it appears in the updated Annex I.
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