Does the July 2026 Change to EUDR Annex I Apply Yet?

Which Annex I to use today

The one in the consolidated Regulation (EU) 2023/1115.

If your classification work has already been done against it, nothing has to change today. If you have been handed a list that includes the July changes and told it is the current scope, it is not, and the page you are reading is the reason.

The three-part scope test itself does not move: what is the product's correct Combined Nomenclature classification, is that code or description in the current Annex I, and which relevant commodity is connected to it. That test and the rest of the scope question belong to the EUDR page.

What the act is for

Its recitals give three reasons, and they are worth reading because they tell you the direction of travel rather than the detail:

• legal certainty for operators, downstream operators, traders and competent authorities

about which categories of products fall within scope;

• stopping downstream derived products of certain relevant commodities reaching the Union

market without the obligations applying;

• preventing the relocation of deforestation risk, which would undermine the Regulation's

purpose.

So the shape of the change is a scope boundary being tidied, in both directions. Some derived products are brought in, some entries are narrowed or removed, and some categories are clarified. A business whose products sit near the edge of a current Annex I entry should expect to re-run the test when the act is published, in both directions.

This page does not reproduce the amended entries. The act is the list, and a second-hand copy of a list that has not yet taken effect is the worst of both: not authoritative, and not yet relevant.

What to do now

1. Keep classifying against the current Annex I. That is the operative list.
2. Record which Annex I version each classification decision was made against. A decision with no version against it cannot be re-run cheaply when the list moves.
3. For products near the boundary of a current entry, note them as re-run candidates rather than reclassifying them now against a list that is not in force.
4. Watch for publication, not for adoption. Adoption has already happened. Publication is the event.

Why this page exists separately from the EUDR page

Because it has a different lifetime.

The EUDR page states the scope test, the dates and the data. Those are durable. Whether one particular delegated act has been published is a fact with a short shelf life, and the moment it changes, every sentence on this page changes with it.

Keeping the two apart means the durable page does not have to be re-verified every fortnight to stay true, and this one can be.

Review cadence

This page is reviewed every two weeks until the act is published, and immediately on publication. What a review checks:

• whether C(2026) 4920 has an Official Journal reference and a published regulation number;
• whether it has been objected to, withdrawn or replaced;
• whether the consolidated Regulation's Annex I has changed for any other reason.

On publication this page's answer inverts, and the amended Annex I becomes the list the scope test runs against.

What would change this answer

Everything on this page turns on one fact: whether the act has been published in the Official Journal. Recheck if:

• C(2026) 4920 is published, at which point it enters into force the following day;
• the European Parliament or the Council objects to it;
• the Commission adopts a further delegated act amending Annex I;
• Annex I is amended by any other instrument.

Last verified 12 September 2026.

Sources and legal basis

• Commission Delegated Regulation C(2026) 4920, adopted 13 July 2026
• Regulation (EU) 2023/1115, consolidated text