Amendment to the EU Deforestation Regulation (EUDR): Multiple Palm Oil-Derived Chemicals Brought Under Anti-Deforestation Oversight

On September 17, 2026, the Official Journal of the European Union published Delegated Regulation (EU) 2026/2102, amending the list of "relevant commodities and products" in Annex I of Regulation (EU) 2023/1115 (the "EU Deforestation Regulation," or EUDR). The amendment incorporates previously omitted products, such as various palm oil-derived chemicals and frozen bovine tongues, removes low-association products including leather, products with low rubber content, and soybeans for sowing, and clarifies exemptions for waste and used products.

Key Amendments

1. Clarification of Commodity Definitions:

Notes have been added to the four relevant commodity categories—cattle, oil palm, rubber, and wood—to specify the scope of applicable species.

2. Newly Included Products

Various palm oil-derived chemicals (such as alcohols, acids, and esters, covering HS codes 2905, 2915, 2916, 2921, 2923, 2924, 3401, 3823, 3824, and 3907).
Frozen bovine tongues (HS 0206 21 00).
Instant coffee and coffee extracts (HS 2101 11 00).

3. Removed/Deleted Products

Raw hides and skins of bovine or equine animals, and leather (HS ex 4101, ex 4104, ex 4107).
Conveyor or transmission belting (HS ex 4010) and articles of vulcanized rubber (HS ex 4016).
Soybeans for sowing (original HS code 1201).

4. Adjustments to HS Codes

The HS code for live bovine animals has been simplified from "0102 21, 0102 29" to "ex 0102."
The code for retreaded tyres has been replaced from "ex 4012" with "ex 4012 90 30" (limited to those with new treads).
Aircraft seats and motor vehicle seats have been separated from the wood commodity code due to their limited wood content.

5. Exemptions/Clarifications

The regulation explicitly states that the following products do not fall under its scope:

Relevant palm oil derivatives used in the manufacture of medicinal products for human or veterinary use.
Waste and used/second-hand products.
Samples and products used for testing or analysis.
Packaging materials and containers (when used solely to support, protect, or carry other products).
Marketing and promotional materials accompanying products.
Correspondence and letters.

The regulation shall take effect on the day following its publication. Among these, the 17 newly added product provisions shall be deferred and apply as of December 30, 2027, namely: ex 1516 20 (chemically modified palm oil), ex 1518 00 (other chemically modified palm oil derivatives), ex 1520 00 (crude glycerol), 2101 11 00 (coffee extracts/instant coffee), octanol, lauryl alcohol/cetyl alcohol/stearyl alcohol, saturated monohydric alcohols, acetates, oleic acid/linoleic acid/linolenic acid, undecylenic acid, monoamines, quaternary ammonium salts, amides/carbamates, ex 3401 11 00 (soap in bar form), ex 3401 20 (soap in other forms), ex 3824 99 (other chemicals not elsewhere specified), and ex 3907 29 (polyethers), so as to grant economic operators preparation time.

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