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 joins Annex I from 30 December 2027 under Delegated Regulation (EU) 2026/2102. Until then it is outside the list, 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 Delegated Regulation (EU) 2026/2102 changes

Commission Delegated Regulation (EU) 2026/2102 amending Annex I was published in the Official Journal on 17 September 2026 and entered into force on 18 September 2026. It adds coffee extracts, essences and concentrates (HS 2101 11 00), sixteen palm oil derivative codes and frozen cattle tongues. It removes cattle hides, skins and leather, conveyor belts and other articles of vulcanised rubber, retreaded and used tyres, soya beans for sowing, and aircraft and motor vehicle seats. It also states that samples of negligible value, products used up in testing, waste, second-hand goods, packaging and marketing material are not covered. 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 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. The removals took effect on 18 September 2026.

In force is not the same as applying. The removals apply from 18 September 2026. The additions, soluble coffee among them, bind from 30 December 2027, and until then the coffee entries are green and roasted only. Plan against the addition now; comply against the list as it stands.

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.