Is My Product in EUDR Scope? Reading Annex I Against Your CN Code

The classification sequence

Use this order:

1. Establish the product as placed on the market.
2. Establish its CN code at the appropriate level of precision.
3. Check whether that code is represented in the current Annex I.
4. Read any ex limitation, commodity/species boundary, exclusion or deferred application note attached to the entry.
5. Only then decide which EUDR role, timing and due-diligence requirements follow.

This avoids a common error: starting with the material and working backwards to an assumed legal outcome.

What `ex` means, and why it decides many hard cases

An ex entry does not bring every product under the stated CN heading into scope. It limits the EUDR entry to the part described in Annex I.

For example, ex 4011 is not a shorthand for “all tyres are in EUDR”. The Annex wording and rubber commodity boundary still have to be met. By contrast, a bare listed code can operate differently because the Annex is not using ex to narrow it in the same way.

Always read the code and the Annex description together.

Case one: a finished shoe

A finished shoe normally classifies in Chapter 64. Chapter 64 is not made a relevant-product family merely because the shoe contains leather or rubber.

The 2026 amendment also deleted the old cattle hide/leather entries ex 4101, ex 4104 and ex 4107. So the old shortcut, “finished footwear is outside but the cattle leather input is an Annex I product”, is no longer a current general answer.

A separately traded rubber component may still need its own classification if it falls under a remaining listed rubber entry. See leather and footwear and tyres and rubber.

Case two: a vehicle tyre

ex 4011 remains relevant, but scope is bounded by the Annex wording and the rubber commodity definition. Regulation (EU) 2026/2102 also deleted ex 4010 and ex 4016 and replaced the previous broad 4012 treatment with the narrower ex 4012 90 30 tyre-tread entry.

Do not carry an old “most rubber articles are covered” rule into the amended Annex.

Case three: a wooden seat or furniture item

Wood and furniture require their own CN analysis. The amended Annex changes and clarifies several wood and seat entries, while also adding exclusions for bamboo, rattan and other materials of woody nature in the relevant wood context.

Do not infer scope from the word “wooden” alone. See wood products.

Case four: a detergent containing a palm-derived ingredient

The finished detergent is not made an EUDR relevant product just because a palm-derived substance appears in its formulation.

Classify the finished product itself. If a separately traded palm-derived product is listed in Annex I, classify that product against the current oil-palm entries. Several new downstream entries are expressly deferred to 30 December 2027. See palm derivatives and detergents.

Cross-cutting exclusions and boundaries

The amended Annex includes boundaries for areas such as:

• used and second-hand goods in specified contexts
• waste and products made entirely from material that has completed its lifecycle and would otherwise be discarded as waste, where the legal conditions are met
• packing material used exclusively to support, protect or carry another product rather than placed on the market in its own right
• samples and products used for examination, analysis, testing, marketing, information or correspondence where the Annex wording establishes the exclusion
• species or commodity limitations, including the current rubber and oil-palm boundaries

These are not generic exclusions that can be applied to every heading without reading the Annex. Use them only where the legal text supports them.

Which version to classify against

For decisions made now, use the Annex as amended by Regulation (EU) 2026/2102, effective from 18 September 2026.

If you are reviewing an older decision, keep the historical version in the evidence trail. Do not silently overwrite what was legally current at the time. For the amendment timeline, see What changed in EUDR Annex I?.

After scope: what comes next?

Scope is only the first gate. If the product is a relevant product and the role/timing conditions are met, the core EUDR page covers due diligence, geolocation and business roles: EUDR dates, geolocation and what product teams need. The output of that process is set out in what goes in the due diligence statement.

What this page does not do

This page does not provide customs classification advice for every product, replace the Combined Nomenclature or decide operator/trader status. It gives the legal reading sequence for Annex I and current worked boundaries.

What would change this answer

A further Annex I amendment, a legally relevant CN change, a new authoritative classification ruling affecting a worked example, or a change to an Annex exclusion would require this page to be re-run.

Sources and legal basis

• Regulation (EU) 2023/1115, especially Article 2 and Annex I
• Commission Delegated Regulation (EU) 2026/2102 amending Annex I