EUDR for cattle: scope, obligations, and how establishments are screened

Beef, offal and leather, and a geolocation rule unlike any other commodity: every establishment where the animal was kept, not one farm.

Updated 15 September 2026, 6 min read

Cattle is one of the seven commodities of Regulation (EU) 2023/1115 (Art. 2(1)). Annex I covers live cattle, fresh and frozen beef, edible offal and prepared beef under ex 1602 50. Delegated Regulation (EU) 2026/2102 removed the hides and leather entries on 18 September 2026 and adds frozen tongues (ex 0206 21 00) from 30 December 2027. Cattle means the genus Bos: buffalo and bison are not covered.

In scope: Annex I codes for cattle

HS codeProductStatus
ex 0102Live cattle (of the genus Bos; buffalo, bison and other bovine animals are not covered)In force
ex 0201Meat of cattle, fresh or chilledIn force
ex 0202Meat of cattle, frozenIn force
ex 0206 10Edible offal of cattle, fresh or chilled (in-force Annex I entry)In force
ex 0206 22Edible cattle livers, frozenIn force
ex 0206 29Edible cattle offal (excluding tongues and livers), frozenIn force
ex 1602 50Other prepared or preserved meat, meat offal, blood, of cattleIn force

Commission Delegated Regulation (EU) 2026/2102, in force since 18 September 2026, adds one entry for this commodity, each binding from 30 December 2027.

HS codeProductApplies from
ex 0206 21 00Frozen edible offal of bovine animals: tongues30 December 2027

The same regulation took 4 entries for this commodity out of Annex I on 18 September 2026. Products under these codes are no longer relevant products.

HS codeProductStatus
0102 21, 0102 29Live cattleRemoved 18 September 2026
ex 4101Raw hides and skins of cattle (fresh, or salted, dried, limed, pickled or otherwise preserved, but not tanned, parchment-dressed or further prepared), whether or not dehaired or splitRemoved 18 September 2026
ex 4104Tanned or crust hides and skins of cattle, without hair on, whether or not split, but not further preparedRemoved 18 September 2026
ex 4107Leather of cattle, further prepared after tanning or crusting, including parchment-dressed leather, without hair on, whether or not split, other than leather of heading 4114Removed 18 September 2026

What the regulation asks of a beef or leather importer

The obligations apply from 30 December 2026. An operator that is a micro or small undertaking, established as such by 31 December 2024, has until 30 June 2027, except for products that were already covered by the EU Timber Regulation. The amendment is Regulation (EU) 2025/2650.

For every consignment the operator must hold, and the statement must rest on:

  • The geolocation of every plot of production, as a polygon where the plot is above four hectares, with the production period (Art. 9(1)(d)).
  • Evidence that the products are deforestation-free against the 31 December 2020 cutoff (Art. 9(1)(g)) and were produced in accordance with the country's laws in the eight areas of Art. 2(40) (Art. 9(1)(h)).
  • The product description with its HS code, the quantity, the country of production, and who supplied and who bought (Art. 9(1)(a) to (f)).
  • A risk assessment on that information (Art. 10), and before placing, a due-diligence statement filed in the Information System, whose reference number goes into the customs declaration (Arts. 4, 26 and 33). Everything is kept for five years (Art. 12).

What is specific about cattle

Geolocation. For every other commodity it is the plot of production. For products that contain or were made using cattle, the geolocation must cover all establishments where the cattle were kept (Art. 9(1)(d)): the ranch of birth, the fattening farm, the feedlot. An animal moves, so a consignment of beef stands on the establishments of every animal in it, and the indirect supplier, the farm that sold calves to the farm that sold to the slaughterhouse, is exactly where deforestation in the beef chain is found. Pasture is agricultural use, so forest cleared for pasture after 31 December 2020 is deforestation in the regulation's own words (Art. 2(3)), and pasture conversion is what the loss datasets see most clearly.

How Konstata screens cattle establishments

Every plot is screened in more than one pass. The first runs the plot through WHISP, the open analysis developed under FAO's Open Foris, against the EU's own 2020 forest map, the global loss datasets and the alert layers, joined by national records where a country publishes them. Where that finds loss after the cutoff, a second pass locates it on the ground against the forest map, so a reading on land that was not forest in 2020 is not mistaken for the conversion of forest. Where the plot is still unclear, a third pass reads ten years of monthly satellite greenness for the pattern of an established crop. Each plot ends with a verdict and a written reason, never milder than WHISP's own headline, and a plot the data cannot settle is held for a person, with what to check written next to it.

Each establishment is recorded as a plot of production with its period and screened against the cutoff like any other; the greenness pass built for evergreen crops is not applied to pasture. The case holds the establishments behind a consignment together, so a statement can be filed on all of them and the record shows which animal batch stood on which. Cattle is the commodity with the least production history in Konstata to date; the screening is the same forest-cutoff test, and the cattle-specific traceability is the operator's record to keep.

Where to start

  • Check your own product codes in the HS code lookup and the Annex I browser under /eudr/tools.
  • Settle which date binds you with the company size test, and read the benchmark for each country of production in the country risk tool.
  • Open a free Konstata workspace with room for three plots, import them, and read the screening on your own data. No card and no sales call.

Questions

Is leather in scope of the EUDR?
No longer. Raw hides (ex 4101), tanned hides (ex 4104) and leather (ex 4107) of cattle were deleted from Annex I by Commission Delegated Regulation (EU) 2026/2102 on 18 September 2026. The regulation says the Commission will revisit hides, skins and leather in the 2030 review under Art. 34(2).
What geolocation does beef need?
All establishments where the cattle were kept (Art. 9(1)(d)), not only the last farm before slaughter. Each establishment is a plot of production with its own period, and each is screened.
Is pasture agricultural use?
Yes. Deforestation is the conversion of forest to agricultural use (Art. 2(3)), and pasture for cattle is agricultural use, so forest cleared for grazing after 31 December 2020 disqualifies the products.
Does Konstata support cattle today?
Yes, with the same screening every commodity gets: each establishment is a plot, screened against the 2020 cutoff with the loss located on the forest map. The cattle-specific parts, animal movements between establishments and the traceability behind a batch, are recorded on the case and are the operator's evidence.

Sources

Every claim on this page is drawn from Regulation (EU) 2023/1115 as amended, the Commission’s guidance and FAQ, and the implementing and delegated acts. Read the consolidated text on EUR-Lex.

Konstata is compliance software, not legal advice. Verify obligations against the consolidated EUDR text on EUR-Lex.