On 13 July 2026, the European Commission adopted two measures to support implementation of the EU Deforestation Regulation (“EUDR”):
- a Delegated Act updating the list of products covered by the Regulation; and
- an Implementing Act governing the Information System through which operators submit due diligence statements and simplified declarations.
Both measures build on the December 2025 legislative amendment and complete the simplification package presented in May 2026.
Targeted changes to the product scope (Annex I)
The Delegated Act amends Annex I, which lists the products derived from the seven in-scope commodities (cattle, cocoa, coffee, palm oil, rubber, soy and wood).
In particular, the Delegated Act removes the following products from Annex I:
- cattle hides, skins and leather;
- re-treaded tyres;
- soybeans for sowing;
- articles of vulcanised rubber;
- conveyor and transmission belts; and
- aircraft and motor vehicle seats.
At the same time, the Delegated Act adds the following products to Annex I:
- soluble coffee;
- certain palm oil derivatives; and
- frozen cattle tongues.
The newly added products become subject to the Regulation from 30 December 2027, i.e. one year after the general application date of 30 December 2026. The Delegated Act also removes samples and products used for analysis, examination and testing from the scope of the EUDR and introduces targeted exemptions for waste, used and second-hand products, packing material, and products used to manufacture medicinal products.
What happens next? The Delegated Act is adopted but not yet in force. It now goes to the European Parliament and the Council of the EU for a two-months scrutiny period before entry into force. In-house teams should treat the scope changes as settled in substance, but confirm the final Annex I text — and the precise HS/CN codes for added and removed products — once the act clears scrutiny.
Information System Implementing Act
The Implementing Act also sets the technical rules for the EUDR Information System, through which operators and traders submit due diligence statements. Key features include:
- simplified declarations for micro and small primary operators;
- updated technical specifications for the automated application programming interfaces (APIs) that high-volume operators use to submit statements; and
- further functionalities to follow later this summer.
The Information System reopened at the end of June 2026. The Commission will update its documentation regularly and begin company training sessions from the end of July 2026.
Focus: Packaging including wood packaging (pallets, crates etc.)
When determining the implications of the above Acts on obligations under the EUDR, companies should also assess the interaction of the EUDR with the upcoming requirements under the Regulation (EU) 2025/40 on packaging and packaging waste (“PPWR“).
Whether or not packaging is in-scope under the EUDR was first clarified by the Commission’s guidance and is now anchored in the Delegated Act:
- In scope: a manufacturer, importer or first seller who places new packaging (e.g. wooden pallets) or packing material on the EU market as standalone goods owes EUDR compliance on them.
- Out of scope: Packaging and packing material used only to support, protect or carry another product do not trigger respective compliance obligations under the EUDR.
The Delegated Act reinforces this by exempting packing material, alongside waste and used and second-hand products. The used-goods exemption matters for pallet pooling and repaired pallets. But significant modification, for example, rebuilding a used pallet with new relevant wood components, can constitute a fresh placing on the market and re-engage the obligations.
In parallel, PPWR separately governs packaging placed on the EU market, and its main obligations apply from 12 August 2026, ahead of the EUDR. Wood packaging exempt from EUDR compliance may still face PPWR requirements on design, minimization, recyclability and documentation. Companies should therefore map the two regimes together. For our analysis of the PPWR guidance and FAQs, see our previous blog post here.
Next steps
With these two acts, the product scope and submission infrastructure are effectively fixed for 30 December 2026. In-house counsel should therefore:
- re-run product-scope mapping against the amended Annex I — checking whether added products (e.g., soluble coffee, in-scope palm oil derivatives) pull previously excluded lines into scope from 30 December 2027, and whether removed products (e.g., leather, re-treaded tyres) reduce existing obligations;
- align API builds to the updated technical specifications and factor the reopened Information System and late-July training into onboarding;
- assess the simplified declaration route for micro and small primary operators; and
- coordinate EUDR and PPWR readiness where the business relies on in-scope packaging and pallets, given the overlapping 2026 timelines.
