On September 17, 2026 the European Commission published Commission Delegated Regulation (EU) 2026/2102 in the Official Journal L series. Adopted on July 13, 2026 under Article 34(1) of Regulation (EU) 2023/1115 (EUDR), it rewrites Annex I. Operators who mapped due-diligence, geolocation and due-diligence-statement (DDS) programmes to the 2023 annex must recut that list now: several Combined Nomenclature lines leave the perimeter before December 30, 2026; newly listed products bite only on December 30, 2027.
EUDR remains directly applicable. Large and medium-sized operators, traders and downstream operators still apply on December 30, 2026, and micro and small primary operators on June 30, 2027, after Regulation (EU) 2025/2650. This act does not move those dates. It changes which product lines sit inside Annex I.
Which products enter Annex I, and which leave?
Soluble coffee, frozen cattle tongues and additional palm-oil oleochemical derivatives enter Annex I; cattle hides, skins and leather, most retreaded tyres, conveyor belts, other vulcanised-rubber articles, soybeans for sowing, and aircraft and motor vehicle seats leave it.
The recitals close two gaps on commodities already covered: frozen tongues versus fresh, and soluble coffee versus beans. Leather leaves because that chain is economically distinct from meat, with limited operator leverage over geolocation. Live-cattle codes 0102 21 and 0102 29 become ex 0102, a coding simplification. The Commission's July 13, 2026 Environment announcement of the same act also records the removal of soybeans for sowing and of aircraft and motor vehicle seats, and puts samples for testing, waste, used and second-hand goods, and packing material outside the perimeter.
| Change | Line | Effect |
|---|---|---|
| Add | Soluble coffee, HS 2101 11 00 | In from December 30, 2027 |
| Add | Frozen cattle tongues, ex 0206 21 00 | In from December 30, 2027 |
| Add | Added palm-oil oleochemical derivatives | In from December 30, 2027 |
| Delete | Hides, skins, leather, ex 4101 / 4104 / 4107 | Out at entry into force |
| Narrow | Retreads: ex 4012 to ex 4012 90 30 (new tread) | Other 4012 lines drop |
| Delete | Vulcanised-rubber belts and articles, ex 4010 / 4016 | Out at entry into force |
| Exempt | Inputs used to make human or veterinary medicines (Directive 2001/83/EC, Regulation (EC) No 726/2004, Regulation (EU) 2019/6) | EUDR does not apply to that use |
Oil-palm and rubber headings now carry an "ex" prefix where the product is in scope only if produced from a relevant commodity. Wood lines do not catch bamboo, rattan, reeds, rushes, osier, raffia, cereal straw or lime bark. Recital 2 sends hides, skins and leather back to the Article 34(2) review in 2030.
When does each change apply, and what stays on the 2026 clock?
Removals, narrowings and HS fixes take effect on the twentieth day after Official Journal publication, October 7, 2026; products added to Annex I become subject to EUDR only from December 30, 2027.
| Date | Event |
|---|---|
| July 13, 2026 | Commission adopts the delegated act (C/2026/4920) |
| September 17, 2026 | Delegated Regulation (EU) 2026/2102 published in OJ L |
| October 7, 2026 | Entry into force: deletions (leather, belts, sowing soya) are out of Annex I |
| December 30, 2026 | EUDR applies for large and medium operators, traders and downstream operators on the remaining list |
| June 30, 2027 | Application for micro and small primary operators |
| December 30, 2027 | Soluble coffee, added oleochemicals and frozen cattle tongues become subject to EUDR |
December 30, 2026 is unchanged for coffee beans, palm oil, cattle meat, rubber and wood already in Annex I. The 2027 deferral is not a general extra year.
Who must recut due diligence, and who can drop a line?
Importers and manufacturers of soluble coffee, palm-oil oleochemicals and frozen cattle tongues must build geolocation, traceability and DDS capability for those SKUs by December 30, 2027; leather, belt and most retread operators can remove those lines from the 2026 go-live build.
Soluble-coffee plants placing instant coffee on the Union market, or exporting it, now have a 15-month onboarding window after the large-operator date, as do oleochemical users and meat operators placing frozen tongues. Tanners whose only cattle exposure was hides or leather drop those CN lines once the act is in force. Tyre makers keep the new-tread line and lose the rest of heading 4012 plus belts. The medicinal carve-out is use-based, not a heading deletion.
What should EUDR owners lock in before December 30, 2026?
Map every SKU coded to Annex I against the recast list, freeze the leather and belt deletions into the DDS build, and open a 2027 workstream for soluble coffee, added oleochemicals and frozen tongues.
Re-run the CN / TARIC extract against the published annex, including the new "ex" prefixes and the live-cattle recode to ex 0102. Pull the deleted lines out of the December 30, 2026 control framework. Set a December 30, 2027 onboarding plan for soluble coffee, added oleochemicals and frozen tongues, and document any medicinal-use allocation. Brief customs, procurement and the competent authority (BLE, MASAF / ICQRF, MTE / MASA). A continuous, per-jurisdiction real-time monitoring setup surfaces each Official Journal rewrite of Annex I the moment it publishes, so due-diligence owners do not learn of a scope recast from a trade-press roundup.
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Download the OJ text this week and overlay it on your SKU-to-annex map. Confirm which lines drop before December 30, 2026 and which new families need a 2027 plan. Obsidian keeps the EUDR lineage current through this recast, so the next move is a product-list decision, not a search.
