EUDR Annex I Changes Again: What Regulation (EU) 2026/2102 Removes, Adds, and When
On 17 September 2026, the European Commission published Commission Delegated Regulation (EU) 2026/2102 in the Official Journal of the European Union, recasting Annex I of the EU Deforestation Regulation. If you read our July coverage of the Annex I delegated act, you already know the Commission adopted the underlying changes on 13 July 2026. What's new is that the text is now legally binding, published, and dated - and the operative dates are not what a casual reading of "the deadline moved" would suggest.
This is a technical, narrow update. It doesn't touch the 30 December 2026 application date for large and medium operators, and it doesn't reopen the core legal text of the Regulation. It changes which CN-coded products sit inside Annex I, and it does so on two different clocks.
The two-track timeline
Removals take effect on 7 October 2026 - twenty days after Official Journal publication, the standard entry-into-force period for an EU delegated act that doesn't specify otherwise. That's roughly ten weeks before the main 30 December 2026 deadline.
Additions don't apply until 30 December 2027 - a full year after the main deadline, and only for the specific new products listed below. This date does not push back the December 2026 deadline for any commodity or product already in scope. If your product isn't on the "added" list, nothing about your timeline has changed.
What comes out of scope on 7 October 2026
- Cattle hides, skins, and leather (ex CN 4101, 4104, 4107)
- Most retreaded tyres and other vulcanised-rubber articles, including conveyor belts
- Soybeans for sowing (as distinct from soybeans for crushing or feed, which remain in scope)
- Aircraft and motor vehicle seats
The leather removal is the highest-profile item here. It follows sustained lobbying from the leather and tanning industry, first reported as a Commission proposal back in May 2026. Now that it's in force, tanneries, hide traders, and leather-goods manufacturers who were building EUDR due diligence files for these CN codes can stop that specific work as of 7 October - though, as Mongabay's reporting on the exemption's aftermath notes, the industry is now dealing with the optics of being carved out of a deforestation law rather than treating it as an unqualified win. If you still handle cattle for meat, dairy, or (as of this regulation) frozen tongues, your EUDR obligations for those product lines are unaffected - see our cattle and leather compliance guide for what still applies.
What comes into scope on 30 December 2027
- Soluble (instant) coffee (HS 2101 11 00)
- Frozen cattle tongues (ex HS 0206 21 00)
- Additional palm-oil oleochemical derivatives
Note the precision here: only soluble coffee is newly added. Green coffee and roasted coffee remain in scope under the original Annex I listing and are entirely unaffected by this regulation - nothing changes for roasters and green-bean traders following our coffee compliance guide. If your business only touches soluble/instant coffee product lines, you now have a defined compliance runway stretching to December 2027, materially longer than the deadline everyone else is working against.
What operators should actually do this week
- Check your CN/TARIC codes against both lists. Don't assume a "leather" or "rubber" label in your product description matches the regulation's exact headings - verify against the ex-CN codes above, or better, against the full Annex I text once your customs team has reviewed it.
- Don't treat this as a general delay. The most common misreading of scope changes like this is "EUDR got pushed back again." It didn't. The 30 December 2026 deadline for existing Annex I products is untouched. Only the specific newly added products get the 2027 date.
- Watch for Commission guidance on transitional DDSs. If you've already filed, or begun preparing, a Due Diligence Statement for a product now excluded (leather, qualifying retreaded tyres, soybeans for sowing, aircraft/vehicle seats), there's an open practical question about what happens to that filing. The Commission has not yet published specific transitional guidance on this point as of this writing - treat any claim that a DDS must be withdrawn or amended with caution until that guidance lands.
- Flag soluble coffee and palm-oil derivative product lines now, even with the 2027 runway. Sourcing and traceability systems take months to stand up, and getting ahead of a deadline that looks distant today is cheaper than a scramble in late 2027.
This is at least the third time Annex I's product list has moved in 2026 - after the May proposal and the July adoption, this is the September publication that actually locks in the dates. If your compliance program is still treating Annex I as a fixed, one-time list from the original 2023 Regulation text, it's time to build a standing process for tracking delegated-act updates like this one, rather than reacting to each one individually.
Sources: Obsidian Regulatory Intelligence, prodlaw.eu, Mongabay on the leather industry's exemption.
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