The EUDR landscape
The EU Deforestation Regulation (Regulation (EU) 2023/1115) covers seven commodities: coffee, cocoa, soy, wood, rubber, cattle, and palm oil, plus products derived from them. Large and medium operators and traders must comply from 30 December 2026; micro and small operators from 30 June 2027. A delegated act adopted on 13 July 2026 would update Annex I: soluble coffee, certain palm oil derivatives, and frozen cattle tongues would enter scope, while cattle hides, skins, and leather (among other items) would leave it. That act is still under European Parliament and Council scrutiny and has not been published in the Official Journal, so today's Annex I is unchanged and leather remains in scope. If it enters into force, the newly added products become subject to the Regulation from 30 December 2027.
Source: Commission delegated act of 13 July 2026 amending Annex I to Regulation (EU) 2023/1115 (no OJ number yet), Regulation (EU) 2023/1115, Article 36(4) and (5) (scrutiny); Annex I (primary source) · checked on 23 August 2026
Source: Regulation (EU) 2023/1115, Article 38(2) and (3), as replaced by Regulation (EU) 2025/2650, Article 1, point (25) (primary source) · checked on 6 September 2026
Every fact below is checked against the Regulation's own text or an official source, noted alongside it.
EUDR Cattle
Cattle is the most exposed and hardest commodity to trace: the animal moves between farms over its lifetime, supply chains run through indirect suppliers upstream of the final sale, and the relevant records sit in Brazil's animal transit system (GTA/SISBOV).
EUDR Cocoa
Brazil is, in fact, a net importer of cocoa beans: its chocolate industry sources far more from West Africa than the country exports to the EU (USDA FAS, 2025).
EUDR Coffee
Coffee is a perennial crop grown on fixed plots, typically with a clean CAR (Brazil's rural land registry) polygon: one of the more traceable EUDR commodities for that reason alone.
EUDR Palm oil
Palm oil production in Brazil is concentrated in a modest base in the state of Pará, well below the scale of the dominant Southeast Asian producers.
EUDR Rubber
Brazil is the native home of the rubber tree, but most of today's natural rubber supply comes from Southeast Asia; Brazil's own rubber trade with the EU is comparatively small.
EUDR Soy
Soy moves in enormous volume, but it aggregates in silos before export, blending harvests from many farms into a single declaration, with a buyer base that is diffuse rather than concentrated.
EUDR Wood
Plantation wood, pine and eucalyptus, is mostly low risk and grown specifically for export markets including the EU. Native Amazon timber sits at the other end: higher risk, traced through Brazil's own documentary chain (DOF/Sinaflor).
AnyLAI started with coffee because the fit is the cleanest one available today: a perennial crop, a fixed plot, the right document, and a buyer base concentrated in Germany. The same architecture (deterministic document parsing, human attestation, sovereign processing, and a credential built on UNTP) extends, where it makes sense, to other commodities and corridors of multipolar trade. It is an extensible architecture, not a product catalog.
Working with a different EUDR commodity and want to talk through the landscape? This is a conversation, not a sales pitch: get in touch
