EU RD: the list of products is changing, are you concerned?

On 4 May 2026, the European Commission published a simplification package of the EUDR, the Forest Deforestation and Degradation Regulation, which entered into force in June 2023. Among the measures announced are a draft delegated act amending Annex I of the Regulation, i.e. the official list of products concerned by traceability and due diligence obligations. This project is not yet binding, it still requires the approval of the Member States and its publication in the Official Journal of the EU. But in a context where the deadline of 30 December 2026 is approaching for large and medium-sized enterprises, purchasing teams, supply chain and compliance cannot wait until the final version to act.

What enters the scope, and what comes out of it

As for additions, the project includes soluble coffee, hitherto absent while the beans coffee was already covered, an inconsistency that could have created an obvious circumvention. Above all, a series of palm oil derivatives used in the oleochemistry make its entrance: industrial fatty alcohols, fatty acids, esters, but also soaps in bars and flakes. Products in lubricants, detergents, cosmetics or industrial cleaning products, as many categories as companies did not spontaneously associate with the EU RD.

In return, several reliefs are proposed. Cattle leather is removed from the perimeter, recognized as a by-product difficult to trace in a separate value chain from meat. For retreaded tyres, the requirement is limited to the only new natural rubber tread, the used carcase being considered as end-of-life material. The project also explicitly clarifies what has never been in the scope: packaging (including reusable), samples, marketing media and commercial correspondence. Expected clarifications that put an end to divergent interpretations on the ground.

Why act now, even on a project

The public consultation ended on 1 June 2026. Publication in the Official Journal could take place in the following weeks without a transitional period provided for in the current text. For companies whose products incorporate the new added codes, particularly in the oleochemical, agri-food or distribution sectors, this leaves a very short time to adapt processes, inform suppliers and prepare declarations.

The Commission has clearly confirmed that there will be no third postponement. On 30 December 2026, the obligations apply to large enterprises and ITEs (SMEs with an additional six months, i.e. until 30 June 2027).

Have you ever trained your purchasing, quality, customs, CSR teams on EUDR obligations and mapped derivatives in your supply chain?

What ACTE International recommends:

• Check now whether your products or those of your suppliers match the new customs codes added (soluble coffee, palm oil derivatives, industrial soaps)
• Document and formalize products benefiting from the new exemptions (packages, marketing, samples) to secure your argument in case of control
• Anticipating communication to your suppliers affected by the new codes: they will need time to submit their due diligence statements
• Update your flow mapping before the official publication in the Official Journal, marking changes as « expected », not to start from zero on day D

To go further, we offer you training Awareness of the Deforestation Regulation (DREU), animated with dual CSR and customs expertise. Next remote session on 22 September 2026 : Registration.

You're not sure you're concerned about these developments? Contact us to discuss with an expert and take stock of your situation.

• European Commission, draft delegated act amending Annex I of the EUDR, May 2026
• Hogan Lovells, EU Deforestation Regulation: Commission publishes simplification packageMay 2026
• Lawcode GmbH, Deleted act EUDR 2026: New products in scopeMay 2026
• Sourcemap, EUDR Update: 2026 Confirmed, Simplification Proposed, New Product ScopeMay 2026