EUDR Annex I Revision Adds Palm Oil Derivatives and Soap Products, Reshaping Compliance Mapping for Buyers
On 13 July 2026, the European Commission adopted a Delegated Act amending Annex I to the EU Deforestation Regulation (EUDR) and an Implementing Act updating the rules on the EUDR Information System. Annex I lists the commodities and derived products in scope. The Delegated Act is accompanied by an Annex and an impact assessment.
The Delegated Act adds soluble coffee, certain palm oil derivatives, frozen cattle tongues and certain soap products to Annex I. These products become subject to EUDR requirements from 30 December 2027. It removes cattle hides, skins and leather, retreaded tyres, soybean seeds for sowing, certain rubber products, conveyor and transmission belts, and aircraft and motor vehicle seats. The list of commodities does not change, so the amendments mainly affect derived products.
The text also introduces exclusions and clarifications covering samples used for testing and analysis, waste, used or second-hand products, packing materials and containers, marketing and information materials, and products used in the manufacture of medicinal products. The impact assessment reviews 31 product codes and sets out how environmental benefits were balanced against compliance costs.
Information System changes
The Implementing Act amends Implementing Regulation (EU) 2024/3084 to reflect Regulation (EU) 2025/2650. It sets rules for simplified declarations by micro and small primary operators and confirms automated electronic risk profiling of each due diligence statement and simplified declaration. Users cannot see the risk profile. Competent authorities, customs authorities and the Commission can.
Businesses will be able to group statements and declarations, which is meant to address limits such as file size. Contingency arrangements apply when the system is unavailable for more than 60 minutes, and the Commission must provide information on them by 30 December 2026. The reference to the TRACES infrastructure is deleted. The system reopened at the end of June 2026, with company training from the end of July 2026.
The Delegated Act now goes to the European Parliament and the Council for a two-month scrutiny period, extendable by two months. They can veto but not amend it. The period ends on 13 September 2026 unless extended. If no objections are raised, the act is adopted and published in the Official Journal.
What the revision means for buyers of palm derivatives
The source does not name the CN codes behind the palm oil derivatives or soap products, so no specific ingredient can be confirmed as in or out of scope. What the text does establish is direction: compliance pressure is extending to buyers of certain palm derivatives and soap products, with a later date of 30 December 2027 than the main application dates of 30 December 2026 and 30 June 2027.
For procurement and compliance teams, the decision affected is scoping. Product mapping may need rerunning against the amended Annex I once the codes are confirmed, and the new exclusions for samples, waste and packing materials may change how some flows are treated. The staggered dates suggest that supplier data requests for newly added products could follow a different timetable from those already in scope.
Formulators may face indirect effects. If a derivative or finished soap product enters scope, traceability data could become a specification question alongside purity and functionality. This may sharpen interest in palm-free routes for products that cannot yet be traced to the standard due diligence requires, though the source offers no evidence of reformulation activity.
Suppliers of oleochemicals and soap products will want to know which of their codes are caught. The Information System rules, including grouping of statements and contingency identifiers, bear on how operational filing will work for high-volume traders.
Open points to check
It will be worth checking whether the scrutiny period due to end on 13 September 2026 was extended, and whether publication in the Official Journal has followed. The broader product scope review scheduled for June 2030 suggests this list may move again, so any scoping exercise is better treated as provisional than final.