(EU) EUDR Product List Finalized, with Implementation Due by Year-End

On 17 September 2026, the European Commission Authorizing Regulation (EU)2026/2102 was published in the Official Journal of the European Union and entered into force on 18 September 2026, finalizing the list of products in Annex I of the EU Zero Deforestation Products Regulation (EUDR). As the European Parliament and the Council did not raise any objection before the deadline of the objection period on September 13, the product scope of this regulation, which has been postponed twice since its promulgation in 2023, will no longer change and enter the final stage before its formal implementation at the end of the year.

This round of adjustment does both subtraction and addition. The items removed from the list include cow leather and hide, retreaded tires, seed soybeans, vulcanized rubber products, conveyor belts and transmission belts, aircraft and motor vehicle seats, etc. Instant coffee, some palm oil derivatives (including palm oil soap) and frozen cow tongue will be added. The new categories will only be applicable from December 30, 2027. The regulations also specify exemptions, covering waste, second-hand and used goods, packaging materials, medical uses, and samples and products for analysis and testing. The reasons for the adjustment given by the European Commission include limited economic value, insufficient influence of operators, and encouragement of recycling.

The implementation schedule will remain unchanged: large and medium-sized enterprises and all downstream operators (regardless of scale) will be applicable from December 30, 2026; micro and small enterprises established before December 31, 2024 can be extended to June 30, 2027; Timber products governed by the original EU Timber Regulation will be applicable from December 30, 2026 regardless of the size of the enterprise. The deadline for determining whether a product is under control is December 31, 2024, and products harvested or born before June 29, 2023 are not subject to this Regulation.

For China, the impact of EUDR is concentrated on three levels. First, compliance costs rise: seven types of controlled commodities and their derivatives to enter the EU market, must submit due diligence statements and land-level geographical coordinates, domestic rubber tires, wood furniture, paper packaging and other industries export enterprises have been asked by customers to provide origin coordinates information. Second, the trade pattern shift: on the one hand, the export of related products to the EU is blocked, on the other hand, high deforestation risk sources may be diverted to China and other markets, forming a double squeeze. Third, rule spillover: the zero deforestation requirement is evolving from an EU regional rule to the default standard for global commodity trade. In response, the Brazilian Chamber of Foreign Trade has launched an official socio-environmental analysis report for the country's soybean, beef, coffee, timber, palm oil, rubber and cocoa exporters.

The follow-up focus is on the operation of the EU Information System (TRACES) and the enforcement efforts of member states after its implementation on December 30, as well as the availability of traceability data for China's relevant export industries.

Source: Directorate-General for the Environment of the European Commission; Regulation of the Official Journal of the European Union (EU)2026/2102; Shanghai Securities News, September 2026.