A Commission Staff Working Document published on 14 July 2026 sets out a new methodology for assessing which product codes should be added to or removed from the scope of the EU Deforestation Regulation (EUDR), based on stakeholder feedback received until February 2026. The document accompanies a draft Delegated Act that would amend Annex I of Regulation (EU) 2023/1115, and proposes a two-component framework combining quantitative and qualitative criteria to evaluate 31 product codes suggested by stakeholders.
first a supply-chain continuity check, then a cost-benefit analysis weighing environmental benefits against compliance costs. If benefits exceed costs, two pathways are considered. Path I addresses deforestation relocation risk, requiring that the embedded commodity share exceed 75% and that EU production capacity be at least 50% of import volume. Path II targets deforestation and administrative burden, requiring deforestation thresholds of 0.005 hectares per tonne or 100 hectares absolute, and compliance costs not exceeding 5% of trade value. The qualitative assessment complements these criteria with considerations on supply chain structure, sector situations, spill-over effects, and coherence with other EU policies such as circularity, energy security, and food security.
The analysis applies evenly to all relevant products regardless of origin, whether EU or non-EU. The document does not specify which of the 31 product codes would be included or excluded; that decision is left to the forthcoming Delegated Act. The methodology aims to balance environmental benefits against compliance costs and administrative burden, addressing concerns from industry about disproportionate impacts while maintaining the regulation's deforestation objectives.
EU producers and importers of derived products face potential changes in compliance obligations, with some products possibly removed from scope, reducing administrative costs, while others may be added, increasing due diligence requirements. EU regulatory bodies will need to implement the new methodology and update the product list accordingly. Environmental NGOs may welcome the data-driven approach but could criticise any exclusions that weaken deforestation protections. The methodology's emphasis on cost-benefit analysis may favour sectors with lower deforestation footprints, potentially excluding high-risk products from scope.
The Commission will now finalise the Delegated Act amending Annex I, which will be subject to scrutiny by the European Parliament and the Council under the delegated act procedure. Both institutions have two months to object, extendable by two months. The revised product scope is expected to apply from a date specified in the Delegated Act.