Summary
- Commission Delegated Regulation (EU) 2026/2102 expands the EUDR product list to include additional palm-derived chemicals and specified soap products, as well as instant coffee and frozen bovine tongues, while removing or narrowing coverage for certain other products. [edgp.gazetaprawna.pl], [cirs-group.com]
- The newly added product categories are scheduled to become subject to the EUDR from 30 December 2027. Cosmetics, personal-care, detergent, and oleochemical businesses may therefore enter scope even where they have not previously regarded themselves as operators dealing in forest-risk commodities. [edgp.gazetaprawna.pl], [cirs-group.com]
- Businesses should perform a CN or HS code review, identify palm-derived inputs, clarify whether they act as operators or traders, and determine whether suppliers can provide origin, geolocation, legality, and due-diligence information for the relevant production chain. [erwaysolutions.com], [jga.com.pl]
Article
The European Union has expanded the product scope of the EU Deforestation Regulation to include a broader group of palm oil derivatives and downstream oleochemical products. Commission Delegated Regulation (EU) 2026/2102 was published in the Official Journal on 17 September 2026 and amends Annex I to Regulation (EU) 2023/1115. [cirs-group.com]
The additions include products under several tariff headings covering palm-derived alcohols, acids, esters, certain glycerol products, soaps, chemical preparations, and polymers. Instant coffee and coffee extracts and frozen bovine tongues were also added. The amendment simultaneously removes or narrows coverage for certain hides, leather products, rubber articles, soybeans for sowing, and other products. It also clarifies exclusions for waste, used goods, test samples, and certain packaging and promotional materials. [cirs-group.com]
For the cosmetics and personal-care sector, the most prominent change is the inclusion of specified soap products containing, or manufactured using, oil-palm commodities. Additional oleochemical feedstocks commonly used in cosmetics and detergents are also affected. The new product entries are due to apply from 30 December 2027. [edgp.gazetaprawna.pl], [erwaysolutions.com]
The practical impact extends beyond import customs classification. An in-scope operator must be able to demonstrate that relevant commodities are deforestation-free, produced in accordance with applicable legislation in the country of production, and covered by the required due-diligence process. Traceability for palm supply chains can be particularly difficult because material from multiple plantations may be aggregated at mill and refining stages. [erwaysolutions.com], [jga.com.pl]
Businesses should begin with a product and bill-of-materials screening using the amended Annex I codes. Procurement teams should identify palm-derived ingredients that may be described chemically rather than as palm oil. Contracts should allocate responsibility for geolocation data, legality evidence, reference numbers, and cooperation with risk assessments.
Customs, sustainability, tax, sourcing, IT, and product-regulatory teams should coordinate implementation. The additional transition period should be used to test whether existing supplier data can be connected reliably to customs declarations and EUDR due-diligence records.
Source Links
- Gazeta Prawna: New products with EUDR requirements
- CIRS: Amendment to the EU Deforestation Regulation
- JGA: EUDR deadlines and changes to product scope
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