What the EUDR covers: the seven commodities, and where coffee products fall

The regulation applies to seven commodities (Art. 2(1)): cattle, cocoa, coffee, oil palm, rubber, soya and wood. But the duty does not attach to the commodity in the abstract; it attaches to the relevant products listed in Annex I by HS code. If your product's code is in Annex I, the regulation applies to it. If not, it does not, even when the product plainly contains one of the seven.

Coffee in Annex I

Coffee sits under HS heading 0901, which covers coffee whether or not roasted or decaffeinated, together with coffee husks and skins. Green coffee (0901 11) and roasted coffee (0901 21) are both in scope. Soluble and instant coffee under heading 2101 is currently outside Annex I, which produces the counter-intuitive result that a jar of instant is out of scope while the beans it was made from were in scope on import.

What the July 2026 Delegated Regulation changes

On 13 July 2026 the Commission adopted the Delegated Regulation amending Annex I. It adds coffee extracts, essences and concentrates (HS 2101 11 00) along with palm-oil oleochemicals and certain cattle products, removes cattle hides and leather and most retreaded tyres, and introduces exemptions for samples of negligible value, products used for testing, waste, and second-hand goods. The Commission's reasoning on coffee was that leaving soluble out produced a fragmented scope, with the beans covered on import and the jar made from them not.

The newly added products apply from 30 December 2027, a year after the main application date, which is the transition period for anyone whose input changes status.

Adopted is not yet in force. The act is in the Parliament and Council scrutiny period, and the current Annex I stays binding until the text is published in the Official Journal. Plan against the addition, comply against today's list.

What this means in practice

• Check the HS code of what you actually place on the market, not the commodity it came from.
• If you trade green and roasted coffee, you are in scope today and the deadline that matters is your company-size date.
• If you produce soluble coffee, your input changes from out-of-scope to in-scope on 30 December 2027, so the supplier data you will need is data you should start collecting on this season's contracts.