Most EUDR projects begin with the wrong question. "Are we affected?" invites an opinion. The regulation asks something narrower and entirely checkable: does a code on your customs declaration appear in Annex I? Annex I is a list of customs codes, not a list of product names, and the code decides. This guide walks the check, the four traps that decide most real cases, and what happens the moment a code lands in scope.
Scope is a code lookup, not a judgement call
Annex I of Regulation (EU) 2023/1115 pairs seven commodities with the customs headings of the products made from them. A product is in scope when its CN code appears there, whatever it is called commercially. That cuts both ways, and the counter-intuitive direction is the useful one: roasted coffee under HS 0901 is listed, while instant coffee under HS 2101 is not, so two products from the same bean sit on opposite sides of the line. Nobody reasons their way to that from first principles. They read the annex.
The seven commodities and where to look
| Commodity | Main Annex I headings | Guide |
|---|---|---|
| Cattle | 0102, 0201, 0202, 0206, 1602.50, 4101, 4104, 4107 | Cattle and leather |
| Cocoa | 1801, 1802, 1803, 1804, 1805, 1806 | Cocoa and chocolate |
| Coffee | 0901 | Coffee |
| Oil palm | 1511, 1513, 2306, 3823 | Palm oil |
| Rubber | 4001, 4005, 4011, 4012, 4013 | Natural rubber |
| Soya | 1201, 1208, 1507, 2304 | Soy |
| Wood | Chapter 44, plus 4701-4704, 4801, 4802, 9403, 9406 | Timber and wood products |
Treat this table as a map to the right commodity page, not as the annex itself. Annex I is granular at subheading level in several places, so a heading appearing here does not mean every subheading under it is listed. When a code is close to the line, read the annex text for that heading before concluding either way.
The four traps
Derived products, not just raw commodities
The commodity names mislead people into checking only raw imports. The annex reaches well downstream: chocolate, leather, furniture, tyres, printed books and paper, soybean meal, oleochemical derivatives. A furniture importer, a printer buying paper from outside the EU and a tyre distributor are all in scope without ever touching a farm. If your business has decided it is out of scope because it does not import commodities, it has probably not checked its finished-goods codes.
Packaging
Packaging material used exclusively to support, protect or carry another product is out of scope. The wooden pallet under your machine parts and the cardboard around them do not drag the shipment into EUDR. The same pallet sold as a pallet is a product in its own right and is in scope. The distinction is function in that consignment, not material.
Recycled and end-of-life material
Products made entirely from material that has completed its lifecycle and would otherwise be waste are exempt: recycled paper, reclaimed wood. The word doing the work is entirely. A board with virgin fibre blended into recycled content is not exempt, and the burden of showing the composition is yours.
Production date
Goods produced before the regulation entered into force on 29 June 2023 fall outside it when placed on the market, with wood harvested before that date remaining under the old EUTR regime for a transitional period rather than escaping regulation. This helps with genuinely old stock and nothing else, and it only helps if you can evidence the production date from harvest records, production certificates or bills of lading. See the EUDR versus EUTR comparison for how the timber transition works.
The check, in order
- Pull the CN codes from your customs declarations or your customs agent, for everything imported, exported or placed on the market. Start from real declarations rather than a product catalogue: the catalogue reflects marketing, the declaration reflects classification.
- Match each code against Annex I at subheading level, and record the result per code including the misses. A documented negative is worth as much as a positive when an authority asks how you scoped.
- Apply the four traps to the borderline codes: derived product, packaging function, recycled content, production date.
- For each code in scope, identify the commodity, then read that commodity guide for the geolocation and evidence it implies.
- Identify your role for that flow: operator, trader or downstream operator. The code says whether the regulation applies; the role says what you file.
Once a code is in scope
Scope is the cheap half. What follows is the data work: plot geolocation for every production plot behind the product, supplier records, a deforestation-free conclusion against the 31 December 2020 cutoff, and a due diligence statement before the goods move. Smaller operators should read the SME guide next, because the scoping answer is the same for them while the timeline and the obligations are not. The dates that matter are in the deadline guide.