A European Commission staff working document published on 13 July 2026 proposes amendments to the product list (Annex I) of the EU Deforestation Regulation (EUDR), adding or removing 31 specific HS codes based on a new quantitative and qualitative assessment. The changes aim to balance environmental benefits against compliance costs and supply-chain continuity, affecting imports worth approximately €85 billion per year.
The document, accompanying a draft delegated regulation, evaluates each HS code through a stepwise logic: first a supply-chain continuity check, then a cost-benefit analysis comparing environmental benefits (deforestation reduction valued at €10,000 per hectare per year for ecosystem services and €100 per ton of CO₂) against recurring compliance costs. Products pass if benefits exceed costs and meet criteria under one of two pathways. Pathway I requires that the commodity share exceeds 75% in the product and that EU production capacity is at least 50% of import volume, to prevent deforestation relocation. Pathway II applies when the deforestation footprint is at least 0.005 hectares per ton or 100 hectares total, and compliance costs do not exceed 5% of product trade value. Qualitative factors such as supply-chain coherence, avoidance of circumvention, and policy overlaps with circularity or food security are also considered.
The current scope covers 76 HS codes (after removing printed paper in December 2025), representing roughly 112 million tons per year of imports. The proposed changes apply evenly to products produced inside or outside the EU. The assessment follows a 2025 draft that made simplifications and technical fixes, and now introduces a more formalised methodology for scope adjustments.
EU producers of commodities like palm oil, soy, and cocoa may face reduced compliance burdens if certain processed products are removed from scope, but could also see increased competition if imported products are exempted. EU importers and distributors will need to adapt due diligence procedures for the 31 changed codes, with potential cost savings for removed products but new obligations for added ones. Environmental NGOs may welcome the continued focus on high-deforestation-risk products but could criticise the removal of codes where environmental benefits are deemed lower than costs. EU regulatory bodies will need to update enforcement guidance and monitoring systems to reflect the revised list.
The draft delegated regulation will now be transmitted to the European Parliament and the Council, which have the right to object within two months, extendable by two months. The Commission expects the amendments to enter into force in early 2027.