EUDR checker: is your product in scope?

Regulation (EU) 2023/1115 on deforestation-free products (EUDR) covers products made from cattle, cocoa, coffee, oil palm, rubber, soya and wood when their CN code is listed in Annex I. With the free EUDR checker below, enter your CN (HS) code and see in a few minutes whether your product is in scope, what your role is, when your obligations start and what you need to do, with the article behind each obligation.

The check follows the official EU texts, including the changes made by Regulation (EU) 2025/2650 and Delegated Regulation (EU) 2026/2102, which added many palm oil derivatives such as fatty alcohols, esters and soaps.

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EUDR 2026 update: what changed in 2025 and 2026

  • New dates: obligations apply from 30/12/2026, and from 30/06/2027 for operators that were natural persons, micro or small companies on 31/12/2024 (Article 38).
  • New "downstream operator" role: whoever processes or exports products already covered by a due diligence statement does not submit their own statement, just like a trader (Article 5).
  • A simplified declaration for micro or small primary operators in low-risk countries, instead of due diligence statements (Article 4a).
  • Annex I changes by Delegated Regulation (EU) 2026/2102: from 30/12/2027, oleochemicals, soaps, instant coffee and frozen cattle tongues are added. Removed: cattle hides and leather, belts and other heading 4016 articles of vulcanised rubber, retreaded and used tyres (except treads), soya for sowing, and aircraft and motor vehicle seats. Printed matter had already been removed by Regulation (EU) 2025/2650.
  • Not in scope: samples, products used for analysis and testing, many used and second-hand products, and packing that only accompanies another product (Annex I).

EUDR frequently asked questions

What is the EUDR regulation?

The EUDR (Regulation (EU) 2023/1115) prohibits placing on the EU market or exporting certain products unless they are deforestation-free since 31/12/2020, produced in line with the laws of the country of production, and covered by a due diligence statement or a simplified declaration (Article 3). It was amended by Regulation (EU) 2025/2650 and Delegated Regulation (EU) 2026/2102.

Which products does the EUDR cover?

Only products listed by CN code in Annex I to Regulation (EU) 2023/1115 that contain, or are made from, cattle, cocoa, coffee, oil palm, rubber, soya or wood. A product that is not in Annex I is not in scope, even if it contains one of these (Article 1(1)). For example, biscuits with cocoa or cars with natural rubber tyres are not in scope.

What is the EUDR deadline in 2026, and for small companies?

In general from 30/12/2026 (Article 38(2)). Operators that were natural persons, micro or small companies on 31/12/2024 have until 30/06/2027, except for timber listed in the Annex of Regulation (EU) No 995/2010 (Article 38(3)). For downstream operators and traders the date is always 30/12/2026. Products added by Delegated Regulation (EU) 2026/2102 are covered from 30/12/2027.

Are oleochemicals such as fatty acids, fatty alcohols and glycerol in scope?

Yes, if their CN code is listed in Annex I and they were made using oil palm. From 30/12/2026 the list includes, among others, glycerol of at least 95% purity (2905 45), palmitic and stearic acid (2915 70) and industrial fatty acids and fatty alcohols (3823). From 30/12/2027 it adds, among others, lauryl, cetyl and stearyl alcohol (2905 17 00), esters of acetic acid (2915 39), soaps (3401) and other chemical preparations containing oil palm (3824 99). Several of these codes are excluded to the extent they are used to manufacture medicinal products. Because they carry the "ex" mark, each product needs to be checked.

Is there a list of EUDR CN codes (HS codes) in scope?

Yes: Annex I to Regulation (EU) 2023/1115, as amended by Delegated Regulation (EU) 2026/2102. It lists Combined Nomenclature (CN) codes by commodity, for example 0901 for coffee, 1511 for palm oil, 4011 for new tyres and chapters 44, 47 and 48 for wood and paper. The checker above compares your code with Annex I and with the 2026 Combined Nomenclature.

What does "ex" in front of a CN code mean?

That only part of the products under that code is covered. For example, ex 4402 covers only charcoal made from wood, and ex 2905 45 only glycerol made using oil palm (Commission FAQ 2.2). That is why, for these codes, the check shows "Probably in scope of the EUDR. Individual check required" rather than a plain yes.

Am I an operator, a downstream operator or a trader?

An operator is whoever first places a product on the EU market or exports it, for example the importer (Article 2, point 15). A downstream operator places on the market or exports a product made from products already covered by a due diligence statement, for example a roaster buying green coffee in the EU (Article 2, point 15b). A trader resells in the EU a product already placed on the market, without changing its CN code (Article 2, point 17, Commission FAQ 3.1.1).

What does an importer have to do?

Before customs clearance, the importer carries out due diligence: collects information, including the geolocation of the plots of land of production, assesses and mitigates the risk, and submits a due diligence statement in the EU Information System. The statement's reference number is given to customs (Articles 4, 8 to 11 and 26(4)). If all countries of production are low risk, risk assessment and mitigation are not required, under conditions (Article 13).

As a trader or downstream operator, do I need a due diligence statement?

No. Since Regulation (EU) 2025/2650, downstream operators and traders do not carry out due diligence and do not submit statements. They keep, for at least five years, the details of their suppliers and business customers and, if their supplier is an operator, the reference numbers of its statements. Those that are not SMEs must also register in the EU Information System (Article 5).

Which countries are low risk?

Under Implementing Regulation (EU) 2025/1093, 140 countries, including all EU Member States, are low risk and 4 are high risk: Belarus, North Korea, Myanmar and Russia. All other countries, such as Indonesia, Malaysia and Brazil, are standard risk, so products from them need full due diligence.

Do customs brokers, carriers or toll processors have obligations?

No, as long as they do not become the owner of the goods: they do not place the product on the market, so they are neither operators nor traders (Commission Guidance C/2026/3896, section 2, Commission FAQ 2.10 and 3.15). Toll processing is not expressly regulated, so this answer is based on interpretation.

What penalties apply?

Penalties are set by each Member State. For legal persons, the Regulation requires a maximum fine of at least 4% of annual EU turnover, as well as confiscation of the products and of the revenue from the transaction (Article 25).

Does the tool store what I enter?

No. The check runs entirely in your browser, nothing is sent or stored, and no cookies are used. The tool gives general information and is not legal advice.

How Rchem can help

  • Classifying your products in the Combined Nomenclature and checking "ex" codes, especially for chemicals and cosmetics with palm oil derivatives.
  • Mapping your supply chain and collecting geolocation and proof of legality from your suppliers.
  • A due diligence system with written procedures, risk assessment and risk mitigation.
  • Due diligence statements or simplified declarations in the EU Information System.

Request a quote on our Collaboration page or contact us: Collaboration · +30 210 220 9604 · info@rchem.gr