EUDR and Composite Products: What You Actually Have to Do When Your Product Contains Multiple Commodities
If you make chocolate, furniture, spreads, tyres, or almost any processed food or manufactured good, there's a good chance your product contains more than one EUDR-relevant commodity. A chocolate bar typically contains cocoa butter, cocoa powder, and palm oil. A leather sofa has a wooden frame and cattle-derived upholstery. A vehicle tyre is made from natural rubber - and possibly other in-scope materials too.
The EUDR's per-commodity guides tell you what to do with cocoa, or with wood, or with rubber in isolation. This guide answers the harder question: what do you actually have to do when your finished product contains several of those commodities at once?
The answer is more nuanced than most summaries suggest - and getting it wrong in either direction (over-complying or under-complying) wastes resources or creates legal exposure.
What Is a "Composite Product" Under the EUDR?
The term "composite product" does not appear in the legal text of Regulation (EU) 2023/1115. The Commission's April 2025 Guidance (version 2) acknowledges this directly: operators and traders may deal with relevant products that contain or are made partly from other relevant products or relevant commodities, and notes that "in practice these are sometimes referred to as 'composite products' although this is not a legal term used in the EUDR."
In plain English: a composite product is any finished good whose Annex I CN code is linked to one commodity in Annex I, but which physically contains one or more additional EUDR-relevant commodities as ingredients or components.
Common examples:
| Finished product | CN code | Commodity driving scope | Other EUDR commodities present |
|---|---|---|---|
| Chocolate bar | 1806 | Cocoa | Palm oil (in many recipes) |
| Coffee-and-hazelnut spread | 1806 / 2007 | Cocoa / fruit | Coffee, palm oil |
| Wooden office furniture | 9403 30 | Wood | Leather (if upholstered) |
| Leather sofa with wooden frame | ex 9401 | Wood (if wooden-framed seat) | Cattle leather |
| Vehicle tyre | 4011 | Rubber | - |
| Retreaded tyre tread | ex 4012 90 30 | Rubber | - |
| Biscuit with cocoa coating | Bakery code (not in Annex I) | - | Cocoa present but product out of scope |
The last row matters: the presence of an in-scope commodity in your product does not automatically bring your product into scope. Scope is determined by whether your product's CN code appears in Annex I - not by what's inside it.
Step One: Does Your Product's CN Code Appear in Annex I?
This is the threshold question, and it must be answered before anything else.
Annex I is the master list of "relevant products" under the EUDR, organised by Combined Nomenclature (CN) / HS customs codes. If your product's CN code is not in Annex I, the EUDR does not apply to it - even if it contains cocoa, palm oil, leather, or soy. A soap bar made with palm oil (CN 3401) was not in Annex I until the proposed May 2026 delegated act; a biscuit containing cocoa nibs typically falls under a bakery product code not listed in Annex I.
The presence of an in-scope commodity does not equal in-scope status. Classification — your product's CN code — is what determines whether the EUDR applies. A chocolate-flavoured biscuit classified under a general bakery code is out of scope. A chocolate bar classified under CN 1806 is in scope. Do not assume; verify your CN code against Annex I.
Some CN code entries carry an "ex" prefix - meaning only a subset of products under that code is covered. For example, "ex 9401" covers only wooden seats, not seats made from other materials. Getting the "ex" classification right is essential: several rubber and palm oil codes were clarified with "ex" prefixes in the May 2026 draft delegated act precisely because the blanket codes had been creating confusion.
Use the EUDR Navigator Scope Checker to map your CN code against the current Annex I before going further.
Step Two: Which Commodities Do You Actually Owe Due Diligence On?
This is where the most widespread misconception lives, and where the Commission's guidance is genuinely important to read carefully.
The "main commodity" principle - and its limits
The Commission's FAQ (FAQ 1.3, confirmed in the April 2025 fourth iteration) clarifies that for a composite product listed in Annex I, due diligence is required only on the main commodity linked to that product's CN code in Annex I - not automatically on every EUDR-relevant ingredient the product happens to contain.
The chocolate bar example illustrates this clearly. A chocolate bar (CN 1806) typically contains cocoa powder, cocoa butter, and palm oil - three EUDR-relevant raw materials. But CN 1806 in Annex I is linked exclusively to the commodity cocoa. The due diligence obligation therefore extends only to the cocoa components (cocoa powder CN 1805, cocoa butter CN 1804). No separate geolocation is required for the palm oil contained in the chocolate bar, even though palm oil is generally EUDR-relevant as a standalone product.
This is confirmed in our own Annex I scope changes post: "in the case of composite products such as chocolate (HS 1806), where cocoa is the main product 'linked' according to Annex I, due diligence would only relate to the cocoa components - not automatically to any palm oil derivatives contained, even if those derivatives are listed in Annex I in isolation."
The critical nuance: "main commodity" ≠ "only commodity in the product"
The "main commodity" principle applies when a product contains multiple different EUDR-relevant raw materials and its CN code is linked to just one of them. It does not mean you only trace the largest ingredient by weight, or the one that sounds most prominent in the product name.
What it means is: look at which commodity Annex I associates with your product's CN code. That commodity - and all its relevant derived components within the product - is what you owe due diligence on.
For furniture, the picture is different. A wooden office desk (CN 9403 30) is linked to wood in Annex I. If that desk has a wooden carcass, wooden veneer panels, and a wooden back panel, all of those wood components require geolocation - because they all derive from the same commodity (wood) that drives the product's Annex I classification. The "main commodity" simplification does not reduce your obligation to trace a single piece of wood; it means you don't also have to trace any rubber feet or leather trim on the same desk.
Do not over-simplify the 'main commodity' rule. It means: due diligence attaches to the commodity that Annex I links to your product's CN code — and to all components of that commodity within the product. It does not mean you only need geolocation for the single largest ingredient. A chocolate bar requires geolocation for all cocoa-derived components (cocoa butter, cocoa powder, cocoa mass), not just the biggest one by weight.
When a product contains multiple commodities from the same Annex I entry
If your product's CN code is linked to one commodity in Annex I, but that commodity appears in multiple forms within the product (e.g., a furniture piece with a wooden frame, wooden veneer, and a wooden back panel), you must trace geolocation for all of those wood components. The "main commodity" logic only applies when there are several different raw materials in a product - it does not reduce the scope of tracing within a single commodity.
What about products where two separate Annex I entries could apply?
This is the genuinely hard case, and it's where you must consult the official guidance and, where necessary, seek legal advice. The Commission's guidance is clear that the obligation extends to the relevant products listed under the commodity deemed relevant to the product's classification - but the guidance also acknowledges that composite product situations can be complex. The conservative, practical approach is:
- Identify your product's CN code and which commodity Annex I links it to.
- Trace all components of that commodity within the product.
- If a second commodity is also present and its derived products are separately listed in Annex I under a different CN code that also matches your product, seek a formal classification ruling or legal advice - do not assume one commodity covers the other.
Step Three: Geolocation for Every In-Scope Commodity Component
Once you know which commodity (or commodities) you owe due diligence on, the geolocation requirement is unambiguous: there is no exception to the traceability requirement via geolocation.
For each in-scope commodity component in your product, you must collect precise GPS coordinates (or polygon files for plots over 4 hectares) of the plots of land where that commodity was produced. For composite products containing ingredients from multiple origins, each source must be documented separately.
The weakest link principle applies in full: if even one component lacks required data - missing geolocation, unknown species (for timber), or evidence of post-cut-off deforestation - the entire product cannot be placed on the EU market. A single non-compliant or untraceable component makes the whole product non-placeable.
The EUDR's deforestation cut-off date is 31 December 2020 - land used to produce any relevant commodity must not have been deforested after that date. This cut-off applies independently to each relevant commodity in your product. If your chocolate bar's cocoa is clean but the palm oil (if separately in scope) traces to land cleared in 2021, that component fails - regardless of what commodity drives the product's CN classification.
Step Four: The DDS Mechanics for Composite Products
Who files the Due Diligence Statement?
The first operator placing the composite product on the EU market (or exporting it) is responsible for filing the full Due Diligence Statement (DDS) covering all in-scope commodity components. This is the upstream operator in the chain - the importer, the manufacturer placing the finished good on the EU market for the first time.
Downstream operators and non-SME traders who subsequently handle the same product do not need to repeat the full due diligence exercise. Under the simplifications confirmed in the December 2025 amendments and the April 2025 FAQ (4th edition), they can reference the upstream DDS reference and verification numbers rather than re-doing the full exercise. The EU Information System automatically verifies the validity of reference numbers once entered.
However - and this is critical - referencing a previous DDS does not transfer responsibility. Article 4(10) of the EUDR states that any operator referring to a previous DDS "shall retain responsibility for the compliance of the relevant products." If the upstream DDS is incomplete or incorrect, the downstream operator who relied on it bears the risk.
What goes into the DDS for a composite product?
A single DDS covers the finished product as a whole, but must include traceability data for each in-scope commodity component. For a wooden desk with multiple wood-sourced components from different origins, the DDS must include geolocation data for all of those plots. For a chocolate bar, the DDS must cover all cocoa-derived ingredients.
A Practical Bill-of-Materials Approach
The most reliable way to manage composite product compliance is to treat it like a bill-of-materials exercise - the same discipline your procurement team already applies to cost accounting.
List every ingredient or material in your finished product. For each one, identify whether it derives from one of the seven EUDR commodities (cattle, cocoa, coffee, oil palm, rubber, soy, wood). Note the CN code of the raw material or semi-finished input, not just the finished product.
Check your finished product's CN code against Annex I. Identify which commodity Annex I links to your product's code. Those components — and only those — are the ones you owe full due diligence on. Document your reasoning clearly; this is your scope determination record.
For each in-scope component, trace back to the plot of land where the commodity was produced. Collect GPS coordinates or polygon files. For plots over 4 hectares, polygon mapping is required. Verify that no deforestation occurred after 31 December 2020 on any of those plots.
For each in-scope commodity, confirm that production complied with the laws of the country of origin — covering land use, environmental protection, labour rights, and anti-corruption rules. This is a separate, cumulative obligation alongside the deforestation-free requirement.
A single Due Diligence Statement covers the finished product. It must include traceability data for all in-scope commodity components. Submit via the EU TRACES NT system before placing the product on the EU market or exporting it.
Once your DDS is submitted, share the reference and verification numbers with your downstream customers. They can reference these numbers in their own simplified declarations rather than repeating the full due diligence exercise — but they retain responsibility for compliance.
Sector-Specific Notes
Food & beverage manufacturers (chocolate, spreads, ready meals): Your finished product's CN code is the starting point. A chocolate bar (CN 1806) requires cocoa traceability only. A coffee-and-hazelnut spread classified under a different CN code may have a different commodity driver - check carefully. Products classified under general food codes not in Annex I are out of scope even if they contain cocoa or coffee.
Furniture and automotive interiors: Wooden furniture codes (CN 9403 30-60) are linked to wood. If your sofa has a wooden frame and leather upholstery, the wooden frame drives scope - and you need geolocation for all wood components. Note: the May 2026 draft delegated act proposes removing cattle hides, skins, and leather (ex 4101, 4104, 4107) from Annex I entirely. If adopted, this would be significant relief for leather goods and automotive interior suppliers - but it is not yet law.
Tyres: Natural rubber tyres (CN 4011) are in scope for rubber. Synthetic rubber (SBR, NBR, EPDM) is entirely out of scope. Where a tyre contains a blend of natural and synthetic rubber, due diligence applies exclusively to the natural rubber share. For retreaded tyres, the May 2026 draft proposes narrowing scope to the new tread only (ex 4012 90 30), not the whole retreaded tyre.
Packaging and printing: Wood-based packaging is in scope only when marketed as a standalone product - not when used solely to protect or carry another product for sale. Printed products (HS Chapter 49) were removed from Annex I by Regulation (EU) 2025/2650. User manuals, leaflets, and labels accompanying other products are exempt.
The Biggest Misconceptions to Avoid
Misconception 1: "My product contains palm oil, so I need palm oil geolocation." Not necessarily. If your product's CN code is linked to cocoa (e.g., chocolate), the palm oil in the recipe is not separately in scope for that product. The obligation follows the commodity that Annex I links to your CN code - not every EUDR ingredient present.
Misconception 2: "I only need to trace the commodity that gives the product its name." Also wrong. The commodity that drives scope is the one Annex I links to your product's CN code - which is usually (but not always) the commodity that gives the product its commercial identity. Verify against Annex I; don't assume.
Misconception 3: "If my upstream supplier has a DDS, I'm covered." Partially true, but you retain responsibility. If the upstream DDS is incomplete or incorrect, you bear the risk. Collect and verify the reference and verification numbers; don't just assume the upstream DDS is sound.
Misconception 4: "There's a de minimis threshold - small amounts of a commodity don't count." There is no de minimis threshold by volume or value in the EUDR. If your product's CN code is in Annex I and the relevant commodity is present, the obligation applies regardless of how small the proportion is.
Deadlines
Large and medium operators must comply by 30 December 2026; micro and small operators have until 30 June 2027. These deadlines apply to each in-scope commodity component in your composite product - there is no separate or extended timeline for the "secondary" commodities in a multi-ingredient product.
If you are a downstream operator buying finished or semi-finished composite goods that have already been placed on the EU market by an upstream operator, your obligation is to collect and pass on the upstream DDS reference numbers - not to repeat the full due diligence. But you must register in the EU Information System (if you are a non-SME) and maintain records for at least five years.
Where to Go From Here
Composite product compliance is not more complicated than single-commodity compliance in principle - it just requires more disciplined supply chain mapping upfront. The key discipline is building a bill-of-materials that links every component to its commodity, its CN code, and its geolocation data, then consolidating that into a single DDS.
For the full picture on how DDS filing works in TRACES NT, see our step-by-step DDS filing guide. For your role-specific obligations as an operator, trader, or downstream operator, see our operator vs. trader explainer. And if Annex I scope changes are affecting your product portfolio, our May 2026 delegated act breakdown covers every proposed addition and removal in detail.
The guidance on composite products is still evolving. The Commission's April 2025 FAQ (4th edition) brought meaningful clarification, but the "main commodity" principle has nuances that depend on your specific product classification. Where your situation is genuinely ambiguous - particularly if two different Annex I commodity entries could plausibly apply to your product - treat the conservative reading as your baseline and seek legal advice before finalising your compliance approach.
Related reading
The 2026 EUDR Simplification Package Explained: What Actually Changed for Your Business
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How to Collect EUDR Geolocation Data from Suppliers: A Practical Guide
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