Seven commodity families
The relevant commodities are cattle, cocoa, coffee, oil palm, rubber, soya and wood. Annex I specifies which goods associated with those commodities are relevant products. This is why a broad list of commodities is a useful orientation but an incomplete scope test.
For example, cocoa beans and several cocoa preparations appear in Annex I. Coffee has its own product entries, while the rubber section distinguishes relevant natural-rubber goods. Check the complete entry and its exclusions rather than relying on the name of a commodity.
Use the current Annex I
The consolidated text dated 18 September 2026 incorporates Commission Delegated Regulation (EU) 2026/2102. Changes include new coverage, clarified entries and exclusions. Certain additions, including coffee extracts and frozen cattle tongues, specify application from 30 December 2027.
Do not attach the general December 2026 application date to every newly listed product. Keep the classification decision and date together in the product register, with a link to the legal entry used.
A defensible scope record
- Record the product description and relevant customs classification.
- Document the relevant commodity content and its source.
- Read any “ex” limitation and the full description of the entry.
- Check product-specific exclusions and transition rules.
- Record the reason for an in-scope or out-of-scope conclusion and who reviewed it.
This is an organisational method for keeping decisions traceable. Seek classification advice where the code, material or product treatment is uncertain. A supplier’s informal assurance is not a classification ruling.
Recycled and mixed materials
Annex I contains a specific rule concerning goods made entirely from material that has completed its lifecycle and would otherwise have been discarded as waste, with a qualification for certain manufacturing by-products. “Recycled” as a marketing term is not enough to apply that rule.
For mixed inputs, retain evidence about composition and each relevant source. If scope depends on an exception, explain exactly how its conditions are met. Continue with supply-chain traceability once the product boundary is clear.
Primary sources
Article 1; current Annex I. Legal review used the consolidated text dated 18 September 2026. Consolidated texts are documentation tools; authentic acts are published in the Official Journal.
Check the current sources and relevant competent authority guidance for your situation. This page is not legal advice or a compliance determination.