Soluble coffee enters EUDR scope: the delegated act of 13 July 2026 amends Annex I and is still under scrutiny

What changed

On 13 July 2026 the European Commission adopted delegated act C(2026) 4920, amending Annex I to Regulation (EU) 2023/1115. Entering scope: soluble coffee (2101 11 00), frozen cattle tongues (ex 0206 21 00), soap (ex 3401 11 00 and ex 3401 20) and palm oil oleochemical derivatives, 2916 15 among them. Leaving scope: cattle hides and skins (ex 4101, ex 4104 and ex 4107), conveyor and transmission belts of vulcanised rubber (ex 4010) and other articles of vulcanised rubber (ex 4016). Three entries were narrowed rather than deleted: ex 4012 becomes ex 4012 90 30, limiting the obligation to the tyre tread; 1201 becomes 1201 90 00, leaving out soya beans for sowing; and ex 9401 becomes a list of wooden seats that excludes aircraft seats (9401 10 00) and motor vehicle seats (9401 20 00). The act is not yet in force: under Article 35(6) of Regulation (EU) 2023/1115 it enters into force only if neither the European Parliament nor the Council objects within two months of the notification of 13 July 2026, a period extendable by two more. As at 22 August 2026 the text had not been published in the Official Journal.

Who is affected

Brazilian exporters of soluble coffee, cattle products, palm oil oleochemical derivatives and soap, who are outside scope today and would come inside it. And, the other way round, operators in cattle leather, retreaded tyres, vulcanised rubber articles and seats who have been preparing for obligations the act removes or narrows.

What to do

Do not treat the new list as binding yet: the current Annex I holds until scrutiny closes and the text is published in the Official Journal. For the new entries, the act's own Annex sets application from 30 December 2027, a year after the deadline for medium and large operators. Worth reading too are the act's clarifications on waste, used and second-hand goods, samples, packing materials and items of correspondence, which fall outside scope.

Related deadlines

• December 30, 2027. Start of application of the entries added to EUDR Annex I by the delegated act of 13 July 2026, soluble coffee among them.