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Among the recent updates released by the EU Commission is the EUDR Draft Delegated Act that provides further clarifications on the scope of EUDR, addressing stakeholders' requests for guidance on specific product categories.
It proposes updates to Annex I of the EUDR regarding the list of relevant commodities and products.
The key updates include exemptions for certain products from the scope of the EUDR:
Several HS codes listed under ‘Oil Palm' and ‘Rubber’ in Annex I have led to confusion as they encompass products that could be made with both relevant and non-relevant commodities. The draft act clarifies that these products only fall within the scope of the EUDR if they are produced using a relevant commodity. This is highlighted by the addition of ‘ex’ in front of the products.
The Draft Act confirms that relevant products under the commodity Wood made entirely from bamboo, rattan or other materials of woody nature are excluded from the scope of the regulation.
Waste as defined in Article 3, point (1) of Directive 2008/98/EC of the European Parliament and of the Council, as well as second-hand and used products do not fall within the scope of that Regulation.
It is proposed that samples of products, that are of negligible value and quantity and can be consumed or used only to seek orders of those goods, are not in scope of the EUDR.
The same applies to products that are analysed or tested to determine their composition, quality or other technical characteristics for information or research purposes.
Examples include:
Where packaging is classified jointly with the carried product, it is considered packaging material to support/protect/carry another product and is thus exempt from the EUDR.
It is proposed that besides user manuals, information leaflets, catalogs, marketing materials and labels accompanying other products should also be exempt from the EUDR unless they are placed or made available on the market or exported in their own right.
Items of correspondence, such as written letters, are not subject to due diligence. Relevant products contained within items of correspondence (e.g., in an envelope) are subject to due diligence.
If you wish to add your comments - the draft act is open for public feedback until 13 May 2025 (midnight Brussels time).
In our overview table highlighting the changes within the Draft Act, you can easily check if your products are affected by the proposed changes:
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Caroline is an experienced data scientist with a management degree from TU Munich and a degree in earth observation from the University of Würzburg, which is co-chaired by the German Aerospace Center (DLR). She has worked as a data scientist in the areas of nature conservation and land use change monitoring at WWF, the German Centre for Integrative Biodiversity Research (iDiv), and at tech companies such as Celonis and Deloitte.
