EUDR Annex I Changes: What Businesses Need to Know

The EU Deforestation Regulation is moving into a more detailed phase of implementation. A new draft Delegated Regulation proposes changes to Annex I of Regulation (EU) 2023/1115, the part of the regulation that lists the relevant products covered by EUDR obligations.

For businesses, this matters because Annex I determines whether a product may require EUDR due diligence before it is placed on the EU market, made available, or exported from the EU. If a product is in scope, companies need to show that it is deforestation-free, produced in accordance with the relevant laws of the country of production, and covered by a due diligence statement.

The draft is not final yet. However, companies should already review their product classifications, supplier data, and compliance workflows so they are ready if the changes are adopted.

What this means for compliance teams

The proposed Annex I changes show that EUDR compliance is not a one-time legal review. It is an ongoing product data and supply chain evidence process.

Companies need to connect:

• Product classification
• Commodity and feedstock information
• Supplier declarations
• Country of production evidence
• Geolocation data where required
• Risk assessment and mitigation
• Due diligence statement readiness
• Internal audit trails

The companies that prepare early will be better positioned to avoid supply delays, incomplete documentation, and last-minute supplier data gaps.

How ComplyMarket can support EUDR Annex I readiness

ComplyMarket helps businesses turn EUDR requirements into a structured, digital, and scalable compliance workflow.

As Annex I evolves, companies need more than a static spreadsheet. They need a controlled process to identify product scope, collect supplier evidence, assess risk, manage documentation, and keep due diligence records ready for review.

ComplyMarket can support companies by helping them:

• Map products and HS codes against EUDR scope
• Collect supplier declarations and supporting evidence
• Manage geolocation and supply chain information
• Organize due diligence documentation in one controlled workflow
• Monitor regulatory changes and product scope updates
• Prepare for due diligence statement requirements
• Maintain audit-ready records for internal and external review

For manufacturers, importers, traders, and downstream businesses, the proposed EUDR Annex I changes are a reminder that compliance depends on reliable data, traceable supply chains, and a repeatable due diligence process.

Why Annex I matters for EUDR compliance

EUDR applies to relevant products linked to seven commodities:

Annex I connects these commodities to specific product codes. That makes HS code and CN code classification a key compliance task.

A product scope error can create serious business risk. A company may fail to collect required supplier information, miss geolocation data, submit incomplete due diligence evidence, or apply EUDR obligations to products that may no longer be covered.

The proposed Annex I amendments aim to improve legal clarity, close some supply chain gaps, and reduce unnecessary administrative burden in specific cases.

What the draft EUDR Annex I changes propose

The proposed changes can be grouped into three main areas:

Key product groups affected by the draft changes

1 - Coffee: soluble coffee may come into scope

The draft proposes adding extracts, essences, and concentrates of coffee, including soluble coffee under HS code 2101 11 00.

This is important because green and roasted coffee are already covered by EUDR, while soluble coffee has created a potential gap. If this change is adopted, companies dealing with soluble coffee should expect to review supplier evidence, product origin, and due diligence documentation.

2 - Cattle: frozen cattle tongues added, leather removed

The draft proposes adding frozen cattle tongues to Annex I because fresh cattle tongues are already covered. This would reduce inconsistency between fresh and frozen forms of similar cattle products.

At the same time, the draft proposes removing certain cattle hides, skins, and leather categories from Annex I. The reasoning is linked to the separate structure of the leather value chain, limited leverage for operators to obtain upstream information, and proportionality concerns.

Businesses in the cattle, meat, offal, leather, footwear, luxury goods, and accessories sectors should review product classifications carefully rather than assuming that all cattle-derived products are treated the same way.

3 - Oil palm: more derivatives and selected soaps may be covered

The draft includes several oil palm derivatives used in the oleochemical supply chain. These may include certain hydrogenated oils, chemically modified oils, crude glycerol, fatty alcohols, amides, quaternary ammonium compounds, polyethers, and selected soap categories that contain or are made using oil palm.

This is especially relevant for companies in:

• Chemicals
• Cosmetics
• Detergents
• Personal care
• Pharmaceuticals
• Lubricants
• Food additives
• Industrial manufacturing

For these sectors, EUDR readiness will depend not only on finished product names, but also on ingredient origin, feedstock, supplier declarations, and whether a substance was made using oil palm.

4 - Rubber: retreaded tyres narrowed to tyre treads

The draft proposes replacing the broader retreaded or used tyre entry with a more specific tyre tread code. This would focus EUDR obligations on the new rubber tread rather than the entire used tyre casing.

This clarification supports circular economy practices while keeping attention on the part of the product most relevant to natural rubber.

5 - Wood, pulp, paper, and packaging: more technical clarity

The draft also clarifies exclusions and limitations for several wood, pulp, and paper-related entries. These include references to used and second-hand products, waste, recovered products, single-use packaging used to carry another product, reusable packaging used for that same purpose, correspondence items, and marketing or information materials supplied with another product.

For businesses, the practical message is clear: packaging and documentation should not be assessed in isolation. Their function, use, and presentation with another product may determine whether EUDR applies.

Species and material clarifications

The draft also adds important commodity-level clarifications:

These clarifications are valuable for compliance teams because they reduce uncertainty when products look similar but come from different species or feedstocks.

What businesses should do now

The draft is not final, but waiting until adoption may create unnecessary pressure. Companies should use this period to improve EUDR readiness.

Practical EUDR action checklist