Companies that treated the May 2026 EUDR package as a working draft need to update that assumption. On 13 July 2026, the European Commission adopted a delegated regulation updating Annex I of the EUDR, plus Implementing Regulation (EU) 2026/1565 for the Information System, according to the Commission's announcement. Both measures were adopted, not proposed, which is the operative change from the spring draft.

The enforcement calendar has not moved. Large and medium operators still need their due diligence systems running by 30 December 2026, and micro and small operators follow on 30 June 2027, exactly as the December 2025 amendment set out. What changed is narrower: which products trigger those obligations, and how the Information System processes them.

What did the Commission adopt on 13 July 2026?

Two separate legal instruments moved the same day. The delegated regulation reshapes Annex I of Regulation (EU) 2023/1115, the list of products the EUDR covers. Implementing Regulation (EU) 2026/1565 rewrites Implementing Regulation (EU) 2024/3084, the rulebook for the Information System operators use to submit due diligence statements and simplified declarations.

Neither instrument reopens the EUDR itself. Both build on Regulation (EU) 2025/2650, the amendment adopted in December 2025 that introduced the downstream operator and micro or small primary operator categories.

Which products were removed from Annex I, and why?

The delegated regulation deletes three HS codes for cattle hides, skins and leather (4101, 4104 and 4107) from Annex I. According to the regulation's explanatory memorandum, the reasoning centers on trade flow asymmetry: operators have limited leverage to demand due diligence data from suppliers when hides carry far less economic value than the meat from the same animal.

Five other categories drop out alongside leather:

• Retreaded tyres, narrowed from the full tyre to just the new tread (HS 4012 90 30), since the tread is the only part added during retreading
• Soybeans for sowing, carved out of the broader soybean code because they run through a separate certification and traceability system
• Articles of vulcanised rubber and conveyor or transmission belts (HS 4010 and 4016), both judged to contain too little natural rubber to justify the compliance load
• Aircraft and motor vehicle seats, removed from HS 9401 because their wood content is minimal

Leather's exclusion is not final. The regulation's recitals note that the general review due in 2030, required under Article 34(2) of the EUDR, will look again at whether hides, skins and leather should return to scope.

Which products were added, and when do they need to comply?

Soluble coffee (HS 2101 11 00, extracts, essences and concentrates of coffee) and frozen cattle tongues (HS ex 0206 21 00) join Annex I, closing gaps the Commission flagged as incoherent: roasted beans and fresh tongues were already in scope, while their processed or frozen equivalents were not.

A longer list of palm oil derivatives is added too, spanning fatty alcohols, glycerol, specific acids, amines and soap forms across chapters 15, 29, 34 and 38 of the Combined Nomenclature. One code, HS 2916 15 for oleic, linoleic and linolenic acids, was added directly in response to 2026 stakeholder feedback rather than the original 2025 draft.

Every one of these additions carries a deferred application date of 30 December 2027, a year past the main deadline for large and medium operators. The removals carry no such grace period: once the delegated regulation is in force, the excluded categories drop out immediately.

For a fuller commodity-by-commodity breakdown, see which products are covered under the EUDR.

Does this change which commodities the EUDR covers?

No. The seven relevant commodities under Article 2(1) of the EUDR, cattle, cocoa, coffee, oil palm, rubber, soy and wood, are untouched. The delegated regulation only adjusts Annex I, the list of derived products made from those commodities.

It does add species-level precision. Cattle now applies only to the genus Bos, excluding buffalo and bison. Oil palm applies only to Elaeis species, excluding babassu oil from the Attalea genus.

Rubber applies only to Hevea brasiliensis, excluding balata, guayule, chicle and synthetic rubber. Wood products made from bamboo, rattan, reeds, rushes, osier, raffia, straw or lime bark fall outside scope entirely.

What products and materials are clarified as out of scope?

Samples of negligible value used to solicit orders, and products consumed or destroyed during testing, are confirmed outside the EUDR, defined by reference to Council Regulation (EC) No 1186/2009. Waste, used and second-hand goods are excluded product by product, each tied to the waste definition in Article 3(1) of Directive 2008/98/EC.

Packing materials get a sharper line. Single-use packing used only to support, protect or carry another product is never in scope, regardless of material. Packing suitable for repeated use loses EUDR coverage only from the moment it is actually used for that purpose onward, so it can still be captured if placed on the market as a standalone product later.

Marketing and information materials and items of correspondence are excluded specifically within chapters 47 and 48, the pulp and paper codes, using the correspondence definition from Delegated Regulation (EU) 2015/2446. A narrower exemption also covers certain palm oil oleochemicals used to manufacture human or veterinary medicinal products under Directive 2001/83/EC, Regulation (EC) No 726/2004 or Regulation (EU) 2019/6, rather than a blanket carve-out for medicinal inputs generally.

Is the delegated regulation already in force?

Not yet. Adopted is not the same as binding. The Commission's own announcement confirms the delegated regulation now moves to the European Parliament and the Council for scrutiny before it can take effect. That scrutiny period typically runs two months from notification, with the current Annex I still legally binding until it lapses without objection and the text is published in the Official Journal.

Treat the July changes as highly likely to stand, since the substance largely mirrors the May draft. But avoid irreversible calls, like discontinuing due diligence collection on leather, purely on the strength of a text that has not yet cleared scrutiny.

What changed in the EUDR Information System?

Implementing Regulation (EU) 2026/1565 entered into force on 17 July 2026, three days after Official Journal publication. It introduces simplified declarations for micro or small primary operators under a new Article 4a, letting them submit once and update later rather than filing per shipment.

A new Article 8a lets any Information System user group several due diligence statements or simplified declarations into one by referencing their existing reference numbers, useful for operators managing high shipment volumes. Users are now limited to a single registered account, though that account can hold multiple roles. The regulation also drops the system's dependency on the TRACES infrastructure, and requires the Commission to publish contingency arrangements by 30 December 2026 covering outages longer than 60 minutes, including a contingency reference number operators can use when the system is down.

What should companies do before December 2026?

• Re-run the Annex I mapping against the six removed and added product categories, and flag anything that moves either direction.
• Keep collecting due diligence data on leather and other removed categories until the scrutiny period closes and the text is published in the Official Journal.
• Build newly in-scope products, like soluble coffee or palm oil derivatives, into a 2027 roadmap rather than treating them as an immediate December 2026 requirement.
• Review whether grouping due diligence statements under the new Article 8a would reduce your submission volume.

For the version-controlled way to track which products sit in which category as Annex I keeps shifting, see how the EUDR stack handles supplier data without losing traceability at the plot level.

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How Coolset helps you track a moving product scope

Annex I has changed twice in eight months, and the December 2026 deadline has not moved once. Coolset's platform keeps your product-to-HS-code mapping in one place, so when a category like leather drops out or soluble coffee moves in, you can see exactly which suppliers and shipments are affected instead of re-running the exercise from scratch. The platform covers supplier data capture, geolocation verification, deforestation risk assessment and TRACES-compatible due diligence statement generation, built for first operators and downstream operators alike.

Frequently asked questions

Is the Annex I delegated regulation already in force?

No. It was adopted on 13 July 2026, but the European Parliament and Council still need to complete a scrutiny period before it enters into force. The current Annex I stays binding until that period closes and the text is published in the Official Journal.

Does this delegated regulation change the seven EUDR commodities?

No. Cattle, cocoa, coffee, oil palm, rubber, soy and wood remain the covered commodities. Only Annex I's list of derived products changes, along with new species-level clarifications for cattle, oil palm and rubber.

When do the newly added products need to comply?

Products added to scope, including soluble coffee, frozen cattle tongues and most palm oil derivatives, become subject to the regulation from 30 December 2027, a year after the deadline for large and medium operators.

Is the medicinal products exemption a blanket carve-out?

No. It applies specifically to certain palm oil oleochemical derivatives used in manufacturing human or veterinary medicinal products under EU pharmaceutical law, not to medicinal-product inputs generally.

What is Implementing Regulation (EU) 2026/1565?

It is the rulebook update for the EUDR Information System, in force since 17 July 2026. It adds simplified declarations for micro or small primary operators and a grouping feature for due diligence statements under Article 8a.

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