Which products are covered by the EUDR?

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Products are covered by the EUDR

The EU Deforestation Regulation (EUDR) sets requirements for materials and products covered by listed CN codes in Annex I. This includes both raw materials and certain types of finished products.

This guide lists commodities and product categories which are within the scope of such CN codes, and therefore covered by the EUDR.

Methodology

1. This guide lists the commodities covered by Annex I of the EU Deforestation Regulation. For each commodity, we list all the covered CN codes, relevant product categories, and product examples for each CN code / product category.

2. A CN code is an eight-digit commodity code used to classify goods in the EU. CN codes are set out in Regulation (EEC) 2658/87.

3. The tables in this guide only list examples of covered products, as found in Regulation (EEC) 2658/87. You can find the full list of products for each CN code in Regulation (EEC) 2658/87.


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Wood

The EU Deforestation Regulation covers certain products made of wood. This section lists examples of wooden products under their respective categories.

Furniture

Product category Classification (CN code) Product examples
Wooden furniture, and parts thereof 9403 30

9403 40

9403 50

9403 60

9403 91

Desks

Fitted kitchen units

Bedroom furniture

Living and dining room furniture

Wooden furniture parts

Seats ex 94 01 Swivel seats of wood

Note: According to the EU’s Implementation of the EU Deforestation Regulation page, the “ex” preceding CN codes means that the covered products are an “extract” – that is a subset – of the products classified under that CN code.

For example, “ex 94 01” means that the regulation only covers wooden seats, even if the code 94 01 also covers seats made other materials.

Other wooden products

Product category CN code Product examples
Fuel wood 4401 Fuel wood in logs, coniferous

Wood in chips, coniferous

Sawdust in wood pellets

Bark and production waste

Wood charcoal 4402 Wood charcoal of bamboo

Wood charcoal of shell

Nut charcoal

Wood in the rough 4403 Sawlogs of pine

Stripped wood, treated with paint

Wood and articles of wood 4404 Wooden sticks, coniferous

Wooden stakes, non-coniferous

Wood wool; wood flour 4405 Wood wool

Wood flour

Railway or tramway sleepers (cross-ties) of wood 4406 Tramway sleepers, coniferous, not impregnated

Railway sleepers, non-coniferous, not impregnated

Wood sawn or chipped lengthwise, sliced or peeled, planed, sanded or end-jointed, more than 6 mm thick 4407 End-jointed coniferous pine wood

Planed coniferous pine wood

Planed coniferous fir wood

Sheets for veneering 4408 Wood for veneering, coniferous, planed

Small boards for manufacturing pencils

Wood shaped along its edges 4409 Coniferous wood moulds for painting frames

Non-coniferous bamboo wood mouldings for mirror frames

Unassembled wood block flooring

Particle board of wood materials 4410 Unworked particle board of wood

Unworked oriented strand board (OSB)

Fibreboard of wood 4411 Raw MDF not exceeding a thickness of 5mm

Raw MDF between 5-9mm

Plywood, veneered panels, and similar laminated wood 4412 Bamboo plywood

Bamboo plywood with at least one outer ply of mahogany

Laminated veneered lumber (LVL) with at least one outer ply of non-coniferous wood

Densified wood 4413 Densified wood blocks

Densified wood plates

Densified wood strips

Densified profile shapes

Wooden frames for paintings, photographs, mirrors, or similar objects 4414 Wooden frames of tropical wood
Wooden cooperage products 4416 Casks of wood

Barrels of wood

Vats of wood

Tubs of wood

Wooden tools 4417 Wooden tool bodies

Wooden broom handles

Wooden brush handles

Wooden shoe lasts

Builders’ wood joinery and carpentry 4418 French windows and their frames of tropical wood

Doors and their frames and thresholds of coniferous wood

Wooden shingles and shakes

Tableware and kitchenware 4419 Bread boards

Chopping boards

Chopsticks

Wood marquetry and inlaid wood 4420 Jewellery cases of tropical wood

Caskets for cutlery of tropical wood

Other articles of wood 4421 Wooden clothes hangers

Wooden coffins of fibreboard

Wooden coffins of bamboo

Printed books, newspapers, pictures and other products of the printing industry ex 49 Dictionaries

Newspapers

Children’s drawing books

Prefabricated buildings 9406 10 Prefabricated buildings of wood

Packaging

The EU Deforestation Regulation also applies to certain packaging products made of wood. However, according to the FAQ published in the EU website, it does not cover include packing material used to carry, protect, or support another product for sale.

This means that, for example, if you sell furniture that is packaged in a wooden box, the box should not be subject to the requirements of the regulation.

Product category CN code Product examples
Packing cases, boxes, crates, and similar products 4415 Packing cases of wood

Cable drums of wood

Pallet collars of wood

Flat pallets of wood

Rubber

The EU Deforestation Regulation covers certain rubber products (e.g. clothing accessories). This section lists examples of such products.

Apparel and clothing accessories

Product category CN code Product examples
Apparel and clothing accessories ex 40 15 Gloves, mittens and mitts of vulcanised rubber

Medical gloves of vulcanised rubber

Veterinary mitts of vulcanised rubber

Surgical gloves of vulcanised rubber

Other rubber products

Product category CN code Product examples
Natural rubber, balata, gutta-percha, guayule, chicle and similar natural gums, in primary forms or in plates, sheets or strip 4001 Natural rubber latex strips

Smoked sheets of natural rubber

Balata strips

Compounded rubber, unvulcanised, in primary forms or in plates, sheets or strip ex 40 05 Rubber plates compounded with carbon black or silica

Plates of compounded rubber

Unvulcanised rubber in other forms (e.g. rods, tubes and profile shapes) and articles (e.g. discs and rings) ex 40 06 Unvulcanised rubber ‘Camel-back’ strips for retreading rubber tyres
Vulcanised rubber thread and cord ex 40 07 Vulcanised rubber thread and cord
Plates, sheets, strips, rods and profile shapes, of vulcanised rubber other than hard rubber ex 40 08 Sheets and strips of cellular rubber

Non-cellular rubber floor mats

Conveyor or transmission belts or belting, of vulcanised rubber ex 40 10 Vulcanised rubber conveyor belts reinforced only with metal

Vulcanised rubber conveyor belts reinforced only with textile materials

New pneumatic tyres, of rubber ex 40 11 New pneumatic rubber tyres for racing cars

New pneumatic rubber tyres for aircraft

New pneumatic rubber tyres for motorcycles

Retreaded or used pneumatic tyres of rubber; solid or cushion tyres, tyre treads and tyre flaps, of rubber ex 40 12 Retreaded pneumatic tyres for station wagons

Retreaded pneumatic tyres for buses

Solid, used pneumatic tyres

Inner tubes, of rubber ex 40 13 Inner rubber tubes for motor cars, buses or lorries

Inner rubber tubes for bicycles

Other articles of vulcanised rubber other than hard rubber, not elsewhere specified in chapter 40 ex 40 16 Floor mats of cellular, vulcanised rubber

Erasers of vulcanised rubber

Dock fenders vulcanised rubber

Hard rubber (e.g. ebonite) in all forms including waste and scrap; articles of hard rubber ex 40 17 Ebonite

Cattle

Annex I of the EU Deforestation Regulation lists various types of cattle products, including leather.

Leather and hides

Product category CN code Product examples
Raw hides and skins of cattle ex 41 01 Fresh whole raw hides of bovine
Tanned or crust hides and skins of cattle, without hair on, whether or not split, but not further prepared ex 41 04 Whole bovine hides, tanned, of bovine, of a unit surface area not more than 2.6 m2

Whole hides and skins of bovine of a unit surface area exceeding 2.6 m2

Leather of cattle, further prepared after tanning or crusting, including parchment-dressed leather, without hair on, whether or not split, other than leather of heading 4114 ex 41 07 Boxcalf bovine full grains, unsplit whole hide leather

Bovine grain split leather

Other cattle products

Product category CN code Product examples
Live cattle 0102 21 Live heifers as pure-bred breeding cattle

Live cows as pure-bred breeding cattle

Live buffalo as pure-bred breeding animals

Live cattle 0102 29 Cattle of the sub-genus Bibos or of the sub-genus Poephagus, for slaughter, of a weight not exceeding 80 kg
Meat of cattle, fresh or chilled ex 02 01 Carcases and half-carcases of fresh bovine meat

‘Compensated’ quarters as cuts with bone in chilled bovine meat

Boneless fresh meat of bovine

Meat of cattle, frozen ex 02 02 Carcases and half-carcases of frozen meat of bovine animals

Unseparated or separated forequarters of other cuts with bone in frozen bovine meat

Crop, chuck-and-blade and brisket cuts of boneless meat of bovine animals

Edible offal of cattle, fresh or chilled ex 0206 10 Chilled edible bovine offal for the manufacture of pharmaceutical products

Thick skirt and thin skirt of fresh edible offal of bovine animals

Edible cattle livers, frozen ex 0206 22 Livers
Edible cattle offal (excluding tongues and livers), frozen ex 0206 29 Thick skirt and thin skirt of bovine animals for the manufacture of pharmaceutical products
Other prepared or preserved meat, meat offal, blood, of cattle ex 1602 50 Uncooked, preserved bovine animals

Corned beef, in airtight containers, of preserved bovine animals

Cocoa

Annex I of the EU Deforestation Regulation also lists products made of or that contain cocoa. Here are several examples of cocoa products (e.g. raw cocoa beans) and their CN codes.

Product category CN code Product examples
Cocoa beans 1801 Whole cocoa beans

Broken cocoa beans

Raw cocoa beans

Roasted cocoa beans

Cocoa shells 1802 Cocoa shells

Cocoa husks

Cocoa skins

Cocoa waste

Cocoa paste 1803 Cocoa paste, not defatted

Cocoa paste, wholly defatted

Cocoa paste, partly defatted

Cocoa butter 1804 Cocoa butter fat

Cocoa butter oil

Cocoa powder 1805 Cocoa powder not containing added sugar

Cocoa powder not containing other sweetening matter

Chocolate and other food preparations containing cocoa 1806 Cocoa powder with added sweeteners, without sucrose

Coffee

Annex I to the EU Deforestation Regulation lists products that are made of contain coffee. This section features some examples of relevant coffee products (e.g. coffee husks).

Product category CN code Product examples
Coffee, whether or not roasted or decaffeinated; coffee husks and skins; coffee substitutes containing coffee in any proportion 0901 Not decaffeinated, not roasted coffee

Decaffeinated, not roasted, coffee

Coffee husks and skins

Oil palm

Annex I to the EU Deforestation Regulation lists products made or that contain oil palm. Here are some examples of those products (e.g. palm nuts), and their CN codes.

Product category CN code Product examples
Palm nuts and kernels 1207 10 Palm nuts

Palm kernels

Palm oil and its fractions 1511 Crude palm oil for industrial uses

Non-crude palm oil for technical uses

Crude palm kernel and babassu oil and fractions thereof 1513 21 Crude palm kernel oil for industrial uses

Babassu crude oil for technical uses

Palm kernel and babassu oil and their fractions 1513 29 Solid palm kernel in immediate packings of a net content not exceeding 1 kg

Palm kernel for technical or industrial uses other than the manufacture of foodstuffs for human consumption

Oilcake and other solid residues of palm nuts or kernels 2306 60 Oilcake of palm nuts

Oilcake of palm kernels

Glycerol, with a purity of 95 % or more ex 2905 45 Glycerol
Palmitic acid, stearic acid, their salts and esters 2915 70 Palmitic acid and its salts and esters

Stearic acid and its salts and esters

Saturated acyclic monocarboxylic acids, their anhydrides, halides, peroxides and peroxyacids 2915 90 Lauric acid and its salts and esters
Stearic acid, industrial 3823 11 Stearic acid as an industrial monocarboxylic fatty acid
Oleic acid, industrial 3823 12 Oleic acid as an industrial monocarboxylic fatty acid
Industrial monocarboxylic fatty acids; acid oils from refining 3823 19 Distilled fatty acids

Fatty acid distillate

Industrial fatty alcohols 3823 70 Industrial fatty alcohols

Soya

Finally, the EU Deforestation Regulation lists products made or that contain soya in Annex I. Here are several examples of those products (e.g. soya bean flour), as well as their CN codes.

Product category CN code Product examples
Soya beans, whether or not broken 1201 Soya bean seed, broken

Soya bean seed, not broken

Other soya beans

Soya bean flour and meal 1208 10 Soya bean flour of oil seeds

Soya bean meal of oleaginous fruits

Soya-bean oil and its fractions 1507 Crude oil, degummed, of soya-bean oil for industrial uses

Crude oil, not degummed, for technical uses

Oilcake and other solid residues, whether or not ground or in the form of pellets, resulting from the extraction of soya-bean oil 2304 Ground oilcake

FAQ

What products are exempted from the EUDR?

The EU Deforestation Regulation exempts from its requirements products that are made entirely from recycled waste material.

Is packaging exempt from the EUDR?

The EU Deforestation Regulation does not exempt packaging as whole, as it covers packing cases and boxes, for example. However, Annex I mentions an exemption for packing material that is specifically used to carry, protect, or support another product for sale.

The FAQ on the implementation of the EU Deforestation Regulation expands on this, explaining that the regulation exempts packaging that is not sold as the final product to consumers, for example because it is used to protect the final product.

However, the regulation does not exempts “standalone packaging”.

Additionally, the FAQ explains that there exist a draft Delegated Act that proposes that the following products should also fall under this exemption, unless they are sold “on their own right”:

  • Information leaflets
  • Catalogues
  • Marketing materials
  • Labels

Does the EUDR only cover products that belong to listed CN codes?

Yes, the EU Deforestation Regulation only covers products that are made from listed commodities and for which the CN codes is listed in Annex I.

According to the EU’s Implementation of EU Deforestation Regulation page, if the CN code of a product is not listed in Annex I, then that product is not subject to the regulation’s requirements, even if the product includes elements made from covered commodities (e.g. wood).

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    Sources: Our articles are written in part based on publicly available information, and our own practical experience relating to product compliance. These are some of the primary sources we use:

    • European Commission - europa.eu
    • EUR-Lex - eur-lex.europa.eu
    • European Chemicals Agency - echa.europa.eu
    • eCFR - ecfr.gov
    • U.S. Consumer Product Safety Commission - cpsc.gov
    • U.S. Federal Trade Commission - ftc.gov
    • U.S. Federal Communications Commission - fcc.gov
    • GOV.UK
    • Legislation.gov.uk
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