EUDR: The Commission has revised the product list. Five months remain until it comes into force.
The European Commission on July 13 adopted two acts concerning the Deforestation Regulation (EUDR) — a delegated act amending the list of affected products and an implementing act for the information system. It follows the legislative change from December 2025 and the simplifying package from May 2026.
EUDR covers seven commodities — cattle, cocoa, coffee, palm oil, rubber, soy and timber — plus products derived from them. The core seven remain unchanged; only derived products in Annex I are being altered.
What fell out of scope:
▪️ leather, hides and processed leather goods
▪️ aircraft and automobile seats
▪️ protected tires
▪️ vulcanised rubber products
▪️ transport and drive belts
▪️ soy beans for sowing
What has been added: e.g., soluble coffee or some palm oil derivatives.
Key timing: cancelled obligations take effect immediately, newly added products are governed by the regulation only from 30 Dec 2027. Also out of scope are now samples for testing, waste, second‑hand goods, packaging material and products for pharmaceutical manufacturing.
What Czech companies need to do by 30 Dec 2026?
1. Determine your role and size. Are you an operator (placing on the EU market or exporting) or a trader? Large and medium start on 30 Dec 2026, micro and small in mid‑2027.
2. Check your portfolio against the new Annex I. Those building traceability for leather goods or car seats can stop — the obligation applies immediately. Those importing soluble coffee, on the other hand, have an extra year.
3. Find out the origin — here is good news for the Czech Republic. The Commission classified the Czech Republic, Slovakia and the whole EU as low‑risk countries. For domestic wood, a simplified due diligence under Article 13 applies: only information collection, without formal analysis or risk mitigation.
But watch out for two catches:
1) The simplification does not apply if there is mixing with material of unknown origin or from countries with standard or high risk
2) You cannot avoid inspections — for low risk, 1 % of operators are checked annually (3 % for standard, 9 % for high). Those importing coffee, cocoa, palm oil, rubber or soy from tropical origins will not escape the full regime.
4. Collect data — geolocation is the biggest task. You need the geographic coordinates of all production plots, the country of origin, the date, supplier information, and verifiable evidence of legality according to the law of the country of origin.
5. Submit a due diligence statement (DDS) via the EUDR information system before placing on the market and keep the reference number.
6. Archive for 5 years and anticipate annual reporting on the due diligence system.
The delegated act is still heading to the Parliament and Council for review — changes to the product list are not final.
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