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

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

Annex I lists some codes bare and some with an ex prefix. Compare two lines from the annex:

4001 Natural rubber, balata, gutta-percha, guayule, chicle and similar natural gums, in primary forms or in plates, sheets or strip

ex 4011 New pneumatic tyres, of rubber

A bare code covers the whole heading. An ex code covers only the part of that heading the description names. So ex 4011 reaches new pneumatic tyres of rubber and not the rest of 4011, and ex 4107 reaches leather of cattle and not leather of other animals that shares the heading.

This is the single most useful thing to know about reading Annex I, because a business that treats ex 0206 29 as all of 0206 29 will pull products into scope that are not there, and a business that reads an ex line as excluding its product without reading the description will miss ones that are.

Case one: the product has more than one plausible code

A running shoe with a leather upper and a rubber sole.

The instinct is to test the materials. Both are in Annex I somewhere: cattle leather at ex 4107, vulcanised rubber articles at ex 4016. So the shoe looks doubly in scope.

It is not, and the reason is question one. The shoe classifies in Chapter 64, footwear. Chapter 64 does not appear in Annex I at all. The finished shoe is out.

What is in scope is what you buy in. If you import cattle leather under ex 4107 or rubber sheet under ex 4008 and make the shoe in the Union, the leather and the rubber are relevant products and the obligations attach to them, at the point they are placed on the market. The shoe is not the object the Regulation is looking at; the material you imported is.

The test that resolves this is always the same: classify the thing you are placing on the market, not the things inside it.

Case two: the code is in Annex I but the finished article is not a relevant product

A desk chair with a steel frame, a moulded plastic seat and two wooden armrests.

Annex I includes ex 9401, Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof, of wood. Chapter 94 appears in the annex, so a keyword check on "9401" says in scope.

The ex and the qualifier decide it. The line reaches seats of wood. A steel-and-plastic chair with wooden armrests is not a seat of wood, and the question of whether the armrests alone are a relevant product turns on how the parts are classified and placed on the market, not on their presence in the assembled chair.

Two further wood lines are worth reading next to it, because they have their own boundaries written in:

• 4415 covers packing cases, boxes, crates, drums and similar packings of wood, pallets

and pallet collars, and then excludes packing material used exclusively as packing material to support, protect or carry another product placed on the market.

• Pulp and paper of Chapters 47 and 48 are in, with the exception of bamboo-based and

recovered, meaning waste and scrap, products.

Both are carve-outs inside a listed heading. Neither is visible to anyone reading the code list alone.

Case three: the material is there but the article is not listed

A car. It has tyres on it, and ex 4011 is in Annex I.

Vehicles are not in Annex I. The tyres are relevant products when they are placed on the market as tyres. Fitted to a vehicle that is itself being placed on the market, the object being placed is the vehicle, and the vehicle is not listed.

The same shape covers most "but it contains" questions: a machine with rubber seals, a book with a leather cover, a building with wooden joists. Ask what is being placed on the market and classify that.

Your category, worked

Four pages take one commodity each, quote the Annex I lines it rests on and say what Article 9 then requires. A business is often in two of them at once.

• EUDR: tyres and rubber, for chapter 40
• EUDR: leather and footwear, for cattle

hides and leather

• EUDR: wood products, for panels, flooring,

furniture and wooden packaging

• EUDR: palm derivatives, for the oil palm

chemicals that reach detergents and cleaning products

The waste carve-out, which is easy to miss

Annex I carries its own exclusion before the table starts, and it is not a footnote:

Except for by-products of a manufacturing process, where that process involved material that was not waste, this Regulation does not apply to goods produced entirely from material that has completed its lifecycle and would otherwise have been discarded as waste as defined in Article 3, point (1), of Directive 2008/98/EC.

Two conditions, and both have to hold. The goods have to be produced entirely from end-of-life material, and the material has to be waste within the Directive's definition rather than in the ordinary sense of the word. A by-product of a process that ran on non-waste input does not qualify, which is the exception the sentence opens with.

So a recycled-rubber product can be out of scope where a partly recycled one is not, and the line between them is a definition in another Directive rather than a percentage.

Which version to classify against

The consolidated Regulation. Not the version in the Official Journal as first published, and not a copy in a supplier pack.

The annex extract this page works from is the text as published in OJ L 150 of 9 June 2023. It is the right thing to reason from and the wrong thing to rely on for a live decision, because an annex can be amended and a page quoting the original would not know.

There is one amendment in flight. Commission Delegated Regulation C(2026) 4920 amends the list of relevant commodities and relevant products, and it is not published, so it is not the operative Annex I. That question has its own page and its own review cadence: does the July 2026 change to Annex I apply yet.

Record which version each classification decision was made against. A decision with no version against it cannot be re-run cheaply when the list moves, and the list is moving.

What this page does not do

It does not reprint Annex I. The annex is long, it is amendable, and a copy of it here would be a second version of a list that has one authoritative home.

It does not classify your product. A CN classification is a customs determination with its own process and its own consequences, and a Knowledge page that guessed one would be handing you a liability.

It does not tell you what to collect once you are in scope. That is what goes in a due diligence statement and how precise a plot geolocation has to be.

What would change this answer

Recheck if:

• C(2026) 4920 or any later delegated act amending Annex I is published;
• the Combined Nomenclature is amended in a way that moves one of the listed codes;
• the waste carve-out or the packing-material exclusion is amended.

Last verified 12 September 2026.

Sources and legal basis

• Regulation (EU) 2023/1115, consolidated text
• Regulation (EU) 2023/1115 as published, OJ L 150, 9.6.2023
• Regulation (EEC) No 2658/87 on the tariff and statistical nomenclature and on the Common Customs Tariff
• Directive 2008/98/EC on waste