On September 18, 2026, the EU’s Delegated Act updating Annex I of the Deforestation Regulation (EUDR) entered into force. It redraws the list of products covered by the regulation, just three months before EUDR applies to large and medium operators on December 30, 2026.
In our advisory work, we’ve seen companies treat EUDR as a fixed checklist. This update is a reminder: the regulation’s scope is still moving, and exporters who don’t track these shifts risk preparing for the wrong list of products.
What’s out
The Commission removed several products from scope: cattle hides, skins and leather; soybeans for sowing; re-treaded tyres; articles of vulcanised rubber, conveyor and transmission belts; and aircraft and motor vehicle seats.
The leather exemption is the headline. It’s a win for the leather industry, which argued that leather is a by-product of meat production, not a driver of deforestation. Environmental groups disagreed, but the Commission’s simplification review sided with industry.
For African exporters, this is a material change. Countries with significant hides, skins and leather exports no longer face EUDR due diligence on these products. If you diverted compliance budgets toward leather traceability, reallocate them now.
What’s in: with a grace period
The Act adds three products to scope: soluble (instant) coffee, frozen cattle tongues, and certain palm oil derivatives used in oleochemicals.
Importantly, these additions only become subject to the regulation on December 30, 2027, a full year after the main application date. The grace period is deliberate: the Commission wants to give businesses time to prepare. Exporters should treat it as a deadline, not a reprieve.
Note what didn’t change: the core commodities list (cattle, cocoa, coffee, oil palm, rubber, soya and wood) remains intact. The update concerns derived products, not the underlying commodities.
The exemptions people will overlook
The Act also introduces targeted exemptions worth knowing: waste, used and second-hand products, packing materials, samples and products for analysis or testing, and products used in medicinal-product manufacturing. For exporters shipping samples or handling returns, this meaningfully reduces the compliance surface.
Three actions for exporters right now
- Re-check your product scope. Compare every product you export, at HS-code level, against the updated Annex I, not last year’s version. If you export leather, stand down. If you export soluble coffee or palm oil derivatives, start your due diligence clock for December 2027.
- Lock your geolocation data for everything in scope from December 30, 2026. The main deadline hasn’t moved, and the EU’s information systems are already live.
- Use the extra year wisely. Soluble coffee and oleochemical-derivative producers have until December 2027, but supply-chain mapping, supplier engagement and traceability systems take months to build.
The pattern matters as much as the list
The EU is still calibrating EUDR: simplifying where industry pressure is strong, expanding where enforcement gaps appear. Exporters who build compliance as a one-time project will be caught out. Those who build it as a standing capability won’t.
This is the work we do at BALIA every day: keeping African exporters ahead of the regulation instead of behind it. If your product mix touched any of the categories above, now is the time to reassess.
Did any of your products move on or off the EUDR list with this update? Tell us how it changes your compliance plan. We’d like to hear how exporters are responding.
Sources: European Commission announcement on the updated product scope; EOS: EUDR Delegated Act on the product scope (OJ publication, September 17, 2026, entry into force September 18, 2026); Reuters reporting, July 2026.
This is the work we do at BALIA every day. If you export to the EU or trade under AfCFTA and want an assessment of where you stand, book a consultation, or get our free monthly AfCFTA briefing with regulatory changes, tariff news and market opportunities.
