The EU Deforestation Regulation (EUDR) applies to wood, cattle, coffee, cocoa, soy, oil palm and rubber, as well as certain products derived from these commodities, as listed in annex I to the Regulation (hereinafter referred to as "EUDR products").
Whether a product falls within the scope of the Regulation is determined by its customs classification (CN code). Annex I to the Regulation lists the CN codes to which the obligations apply.
"Ex" designation in CN codes
Some CN codes in annex I are preceded by the designation "ex". This indicates that the Regulation applies only to certain products within that CN code, not to all products classified under it.
Example 1: CN code 9401 may include seats made from materials other than wood. However, only wooden seats fall within the scope of the Regulation.
Example 2: CN code 1602 50 may include products other than beef preparations. However, only products made from cattle fall within the scope of the Regulation. Bison meat sold under the same CN code is therefore not covered by the Regulation.
Example 3: Natural rubber obtained from Hevea brasiliensis falls within the scope of the EUDR. However, balata, gutta-percha, guayule rubber, chicle and similar natural gums, as well as synthetic rubber products, are not covered.
How do I determine whether my product falls within the scope of the Regulation?
- Determine the CN code of your product. Finnish Customs is the competent authority for customs classification. For more information, see the guidance on customs classification on the Finnish Customs website and, if necessary, contact Customs advisory services.
- Check whether the CN code is listed in annex I to the Regulation.
- If the CN code is preceded by the designation "ex", verify whether the product is made from the relevant commodity.
When is a product not covered by the Regulation?
1. The product's CN code is not listed in Annex I
If the CN code of a product is not listed in annex I to the Regulation, the product is not subject to the obligations, even if it contains one or more of the relevant commodities.
Example 1: A boat manufactured using plywood is not covered by the Regulation if the CN code of the finished boat is not listed in annex I.
Example 2: A toy containing wooden parts is not covered by the Regulation if the CN code of the finished product is not listed in annex I.
Example 3: Coffee beverages (HS 2101) produced from coffee (HS 0901) are not covered by the Regulation.
2. Products purchased on the EU internal market for a company's own use
The purchase of EUDR products on the EU internal market for a company's own use is not subject to the obligations under the Regulation. This includes, for example, office coffee or furniture purchased for the company's own use.
If a company uses EUDR products itself and does not make them available on the market or place them on the market, the company is not subject to EUDR obligations in relation to those products.
3. Further processing into a product not covered by the Regulation
If a company purchases EUDR products on the EU internal market and further processes them into a product that is not listed in annex I, the company is not subject to EUDR obligations in relation to that activity.
Examples of activities that are not subject to the obligations under the Deforestation Regulation include:
- Purchasing cocoa on the internal market for the manufacture of biscuits (biscuits are not listed in annex I).
- Purchasing soybeans on the internal market for the manufacture of soy sauce (soy sauce is not listed in annex I).
- Purchasing paper on the internal market for the manufacture of books (under Regulation (EU) 2025/2650 amending the Deforestation Regulation, Chapter 49 (books, newspapers and other printed products) has been removed from the product scope).
4. Packaging materials used to package another product
Packaging materials (such as cardboard packaging, cardboard boxes and pallets) used exclusively to support, protect or carry another product are not subject to the obligations under the Regulation.
However, where packaging materials listed in annex I are imported from outside the EU as standalone products, or are placed or made available on the market as standalone products, they are subject to the obligations under the Regulation.
For further information, see FAQ v5 (Questions 2.5 and 2.6) and the Guidance Document (Chapter 7).
5. Product samples
Small quantities of low-value product samples are not covered by the Regulation, for example where they are used solely for the purpose of making purchasing decisions.
The Regulation also does not apply to products intended for examination, analysis or testing in order to determine their characteristics, provided that they are consumed or destroyed during the testing process and are not subsequently placed on the market or otherwise used for commercial purposes.
For further information, see FAQ v5 (Question 2.14).
6. Instructions for use and similar accompanying materials
According to the draft Delegated Regulation, instructions for use, manuals, leaflets and similar materials accompanying other products are not covered by the Deforestation Regulation, provided that they are not placed on the market, made available on the market or exported as standalone products.
7. Correspondence
Correspondence is not subject to customs declaration requirements and is not placed on the market or made available on the market. It therefore does not fall within the scope of the Deforestation Regulation.
However, any products listed in annex I that are enclosed in correspondence (for example, an EUDR product sent in an envelope) remain subject to the obligations under the Regulation.
For further information, see FAQ v5 (Question 2.13).
8. Recycled products
The Deforestation Regulation does not apply to products manufactured entirely from material that has reached the end of its life cycle and would otherwise have been disposed of as waste (for example, timber recovered from demolished buildings).
However, where EUDR products made from recycled material contain even a small proportion of non-recycled material, that non-recycled material falls within the scope of the Regulation. Examples include the use of virgin pulp in paper production and new timber used to repair used pallets.
By contrast, by-products generated during the manufacture of products made from non-recycled material are subject to the obligations under the Deforestation Regulation. For example, sawdust generated as a by-product of sawing is covered by the Regulation.
For further information, see the Guidance Document (Chapter 7).
9. Rental
The rental of products listed in annex I (such as wooden furniture) within the European Union does not fall within the scope of the Deforestation Regulation.
For further information, see FAQ v5 (Question 2.15).