COMMISSION STAFF WORKING DOCUMENT Accompanying the document COMMISSION DELEGATED REGULATION (EU) …/... amending Regulation (EU) 2023/1115 of the European Parliament and of the Council as regards the list of relevant commodities and relevant products
Date: 2026-07-13
Institutions: Directorate-General for Environment, European Commission
Subjects: administrative formalities, commodities market, deforestation, environmental impact, export (EU), impact study, market approval, primary product, reduction of gas emissions, specification of tariff heading

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 13.7.2026  SWD(2026) 194 final  COMMISSION STAFF WORKING DOCUMENT Accompanying the document COMMISSION DELEGATED REGULATION (EU) …/... amending Regulation (EU) 2023/1115 of the European Parliament and of the Council as regards the list of relevant commodities and relevant products {C(2026) 4920 final}  
 
 
1.  INTRODUCTION 

Regulation (EU) 2023/11151 on deforestation-free products (hereafter EUDR) establishes rules 
for making available on the Union market and export certain commodities and derived products 
associated with deforestation and forest degradation. The goal of the EUDR is to minimise the 
EU’s contribution to global deforestation, greenhouse gas emissions and global biodiversity 
loss, in accordance with the EU’s international obligations.  

Art. 2(1) of EUDR defines relevant commodities as cattle, cocoa, coffee, oil palm, rubber, soya 
and wood.  Art 2(2) of EUDR defines relevant products as products listed in Annex I of the 
same  Regulation  that  contain,  have  been  fed  with  or  have  been  made  using  relevant 
commodities. The products listed in Annex I are identified through codes from the customs 
combined nomenclature (‘Harmonised System’ or HS codes).  

The impact  assessment for the EUDR did  not provide a  detailed assessment of the  relevant 
products based on HS codes.  The related Staff Working Document (SWD) also states that: 
“the identification of derived products to be specified in the scope requires a specific study […] 
and subsequent implementing legislation”. This specific study needs to present: “an analysis 
of  derived  products,  based  on  potential  costs  and  benefits,  similar  to  the  analysis  of 
commodities. The analysis would need to map which products would maximise the impact of 
the intervention - covering more ground in terms of embodied deforestation - at the smallest 
potential cost”. 

Art. 34(1) of the EUDR, as amended by Regulation (EU) 2025/26502, enables the Commission 
to adopt delegated acts in accordance with Art. 35 to amend the list of relevant products in 
Annex I of that Regulation (not the commodities).  

In April 2025, the Commission published for a 4-week public feedback a draft delegated act 
which did not alter the product scope of EUDR but introduced simplifications and technical 
fixes for specific use-cases and products categories. These proposed changes presented in the 
2025 draft delegated act gained broad consensus from stakeholders during the public feedback 
period. The  feedback  period  was  also  used  by  40%  of  respondents,  mainly  businesses  and 
business associations, to recommend the inclusion or removal of certain derived products from 
Annex I.  

This  Staff  Working  Document  now  presents  a  comprehensive  assessment,  consisting  of  a 
quantitative  as  well  as  a  qualitative  component,  building  among  others  on  stakeholders’ 
feedback concerning the EUDR product scope. The assessment evaluates the 31 product codes, 
and  thereby  all  codes  suggested  by  stakeholders,  for  inclusion  in  or  exclusion  from  EUDR 
Annex I, based on input received until February 2026.  The Commission services have received 
many contributions from industry associations, individual companies, NGOs and third country 
authorities, and have endeavoured to take these into account to the largest extent possible.  

Although the EUDR applies to all relevant products placed on the EU market, the focus on 
embedded  deforestation  in  imports  for  the  purpose  of  this  analysis  is  justified  from  an 

1 OJ L 150, 9.6.2023, p. 35. ELI: http://data.europa.eu/eli/reg/2023/1115/oj 
2 OJ L, 2025/2650, 23.12.2025. ELI: http://data.europa.eu/eli/reg/2025/2650/oj  

1 

 
 
 
environmental perspective. The environmental benefits of the EUDR derive from preventing 
deforestation  where  it  occurs.  FAO’s  Global  Forest  Resources Assessment  2025  shows  that 
most deforestation takes place outside of the EU.  

The conclusions and findings of this SWD underpin a new draft Delegated Act which contains 
additional changes to the EUDR product scope in addition to the simplifications and technical 
fixes presented already for public feedback in April 2025.  

2.  METHODOLOGY  

This chapter outlines the methodology used to assess products for potential inclusion/exclusion 
within the scope of the EUDR. In line with the task of the original Impact Assessment, which 
said  that:  ‘it  was  not  possible  […]    to  perform  the  necessary  analysis  to  map  and  list  the 
products derived from the relevant commodities that should be included in scope’, a new and 
more robust methodology has been developed.  

Compared  to  the  original  impact  assessment,  the  methodology  has  been  updated  and 
strengthened to reflect developments in global deforestation and trade patterns, the availability 
of more granular data and improved analytical tools, as well as the current scope of the EUDR 
following the extension of product coverage through the 2022 legislative process. 

The  revised  approach  addresses  a  number  of  limitations  identified  in  the  original  Impact 
Assessment. In particular, it allows for a more granular assessment of costs and benefits at HS 
custom code level, it extends the analysis beyond CO₂ emissions to include quantified impacts 
on biodiversity and ecosystem services based on established scientific literature, and it draws 
on more recent and methodologically refined estimates of embedded deforestation. It also no 
longer  relies  on  an  effectiveness  reduction  factor  derived  from  the  EU  Timber  Regulation, 
instead applying an analytical framework that reflects the full range of environmental effects 
associated  with  the  new  policy  intervention.  The  new  methodological  framework  and 
assessment  consist  of  two  complementary  components.  First,  a  quantitative  assessment 
evaluates measurable factors such as the embedded deforestation footprint in derived products 
placed on the EU market, the environmental benefits of including a derived product in the scope 
of the EUDR, and the recurring compliance costs for operators placing the derived products in 
scope on the market. Second, a qualitative assessment considering additional factors which is 
to be taken into account alongside the quantitative assessment. Both components inform the 
proposed  draft  act,  ensuring  a  balanced  approach  that  integrates  numerical  evidence  with 
considerations that cannot be fully captured through quantitative analysis alone. 

In line with the original impact assessment of the EUDR, the methodology examines recurrent 
environmental benefits and compliance costs derived from the activities of operators importing 
the  relevant  goods  into  the  EU  market. The  figures  on  benefits  and  costs  for  the  HS  codes 
analysed would be broadly similar if domestic operators, downstream operators, traders and 
had been included in the calculations.  

2 

 
 
 
The conclusion of the analysis and the proposed changes to the scope via the draft Delegated 
Act apply in an even-handed and non-discriminatory manner to all relevant products regardless 
of whether they are produced inside or outside of the EU. 

2.1 QUANTITATIVE ASSESSMENT   

The  quantitative  assessment  evaluates  products  in  a  structured,  data-driven  approach.  This 
chapter  first  presents  the  key  variables  and  then  introduces  a  stepwise  logic,  which  screens 
products for inclusion or exclusion based on a combination of environmental and economic 
criteria. 

2.1.1 Key variables and data sources 

The key computed variables used in the quantitative assessment are the deforestation footprint, 
environmental benefits, and recurring compliance costs, all of which are calculated at the level 
of the individual HS codes analysed. A short description is provided below, while further details 
on the quantitative assessment, calculations, and data sources can be found in the Annex to this 
document.  

The  deforestation  footprint  represents  the  estimated  area  of  land  converted  from  forest  to 
agricultural use for the production of the relevant product corresponding to the HS code. The 
emissions footprint reflects the net difference in carbon stocks associated with this land-use 
change. The deforestation footprint and associated emissions linked to  derived products  are 
estimated using a range of literature sources. First, country-level estimates of total deforestation 
and emissions associated with the production of the seven commodities in scope of the EUDR 
are  obtained  from  the  DeDuCE  database  based  on  the  work  of  Singh  and  Persson  (2026)3. 
Using production data from FAOSTAT, the deforestation- and emission intensity is calculated 
for each country–commodity combination, defined as the ratio of deforestation or emissions to 
national production of that commodity.  

The  estimated  embedded  deforestation  and  emissions  associated  with  the  placement  on  the 
market of derived products by operators is then calculated by multiplying the deforestation or 
emission intensity by the volume of the derived product placed on the EU market (COMEXT), 
and by the mass fraction of the primary commodity contained within the final product. Due to 
data  availability  constraints,  the  embedded  deforestation  and  emissions  in  product  are 
computed over the period 2015–20204.  

The estimated environmental benefits Bp are quantified based on the estimated deforestation 
and emissions footprints associated with the placing on the market of goods covered under the 
EUDR. Limited by the availability of authoritative data sources, the quantitative assessment 

3 Singh, C., & Persson, U. M. (2026). Global patterns of commodity-driven deforestation and associated carbon 
emissions. Nature Food, 7(2), 138-151. 
4 The DeDuCE dataset, which provides estimates of deforestation by country and commodity, is only available 
up to 2022. However, the model exhibits limitations for the years 2021–2022, making it difficult to accurately 
assess recent trends in the deforestation impact of derived products. In particular, delays in national reporting of 
agricultural land-use and harvested area data, which serve as inputs to the DeDuCE model, may distort 
deforestation signals. 

3 

 
 
 
 
 
does not capture the environmental benefits of a reduction in forest degradation. As a result, 
the potential environmental benefits of keeping/including wood products in the scope would 
be systematically underestimated. The assessment does capture the environmental benefits of 
a  reduction  of  deforestation,  and  the  emissions  associated  with  the  land  cover  or  land  use 
change. The deforestation and emission indicators are monetized separately and subsequently 
aggregated to estimate total environmental benefits. Deforestation impacts are valued using an 
ecosystem  services  approach  and  emissions  are  valued  using  a  carbon  price. An  ecosystem 
services value5, of €10,000 per hectare per year is adopted from Brander et al. (2024)6 as a 
representative value for tropical, subtropical and temperature forests, while a carbon price of 
€100 per ton of CO₂ is adopted in line with the initial impact assessment7.   

Recurring compliance costs include, in line with the definition in the initial impact assessment, 
the costs of employees dedicated for the task, maintenance of systems, and costs related to the 
collation, aggregation and analysis of the data, including in some cases professional services 
for  3rd  party  audit  costs  and  surveys.  The  estimated  recurring  compliance  costs  Cp  are 
computed following a standard cost estimation approach, calculating annual recurrent costs by 
multiplying the number of operators and traders subject to the EUDR with a fixed average cost 
per actor. The average cost per actor builds upon the economic quantifications from the initial 
impact assessment8 published in 2021. The number of unique operators placing a product on 
the market is derived from the Surveillance database of the Directorate-General for Taxation 
and Customs Union (TAXUD). 

Given that the methodology is designed to inform decisions on the inclusion or exclusion of 
specific products from the scope, it focuses on recurrent annual compliance costs for operators 
placing those products on the market. This provides a consistent basis for comparison with the 
corresponding  annual  environmental  benefits  associated  with  their  inclusion  or  exclusion. 
Accordingly,  the  analysis  does  not  cover  broader  enforcement  costs  incurred  by  public 
authorities in the Member States or by the Commission in implementing the EUDR as a whole. 
Nor does it account for one-off costs borne by operators in establishing due diligence systems. 
For these elements, the original impact assessment remains the appropriate reference. 

In addition to the computed variables, the assessment relies on two key data inputs: the traded 
volumes,  both  imported  from  extra-EU  (Vin,extra,p)  and  traded  intra-EU  (Vin,intra,p),  and  the 
corresponding value of these inflows (Wp). 

5 An ecosystem service value is the quantified benefit that humans derive from natural ecosystems, such as clean 
water, food production, climate regulation, recreation, and the maintenance of genetic resources that support 
crop improvement, medicine development, and ecosystem resilience. 
6 Brander, L. M., De Groot, R., Schägner, J. P., Guisado-Goñi, V., Van't Hoff, V., Solomonides, S., ... & Thomas, 
R. (2024). Economic values for ecosystem services: A global synthesis and way forward. Ecosystem 
Services, 66, 101606. 
7 Commission Staff Working Document – Impact Assessment (2021) 
8 Staff working document on the initial impact assessment (EUR-Lex - 52021SC0326 - EN - EUR-Lex) 

4 

 
 
 
 
 
 
2.1.2 Overview of the quantitative assessment 

Based on the variables described in Section 2.1.1, all products are individually assessed using 
a stepwise logic. As illustrated in Figure 1, the process begins with a general screening based 
on ensuring continuity of obligations along the supply chain and a cost–benefit analysis. It then 
outlines  two  potential  pathways  that  may  lead  to  the  recommended  inclusion  of  a  product 
within the scope of the EUDR, provided that the relevant criteria are met. A detailed description 
of all steps in the quantitative assessment is provided in the following paragraphs. 

As a first step, a supply-chain continuity check is conducted to identify downstream derivatives 
of the product being analysed and to assess whether these derivatives fall within the scope of 
the  EUDR.  This  ensures  that  potential  linkages  to  already  regulated  products  are  properly 
understood as part of the broader value-chain analysis and that the entire supply chain is treated 
consistently and prevents gaps in the product coverage of the Regulation. This is done to avoid, 
for example, a situation where operators are obliged to  file a due diligence statement when 
placing chocolate on the EU market but not for the cocoa powder to produce chocolate within 
the EU. 

Following  the  supply-chain  continuity  check,  a  cost–benefit  analysis  per  product  evaluates 
whether  environmental  benefits  of  a  potential  inclusion  (i.e.,  the  reduced  deforestation  and 
resulting emissions reduction) outweigh associated recurring compliance costs. This analysis 
compares  the  environmental  benefit  Bp  of  including  the  derived  product  with  the  recurring 
compliance  costs  Cp.  If  compliance  costs  exceed  environmental  benefits,  the  quantitative 
analysis stops there, indicating that the product should not be included in, or should be removed 
from,  the  scope.  By  contrast,  if  expected  environmental  benefits  are  larger  than  expected 
recurring  compliance  costs,  the  product  is  subject  to  the  next  phase  of  the  analysis,  which 
presents additional criteria under two alternative pathways.   

Figure 1: Schematic overview of the quantitative assessment methodology with two pathways to assess inclusion (in 
green) or exclusion (red) from the scope of EUDR     

5 

                                                                                                                                                                                                                                                                                                                                                  
 
 
 
 
 
2.1.3 Path I: deforestation relocation risk 

In  the  first  pathway,  following  a  positive  cost–benefit  analysis,  the  assessment  considers 
whether the absence of the product code in Annex I could have a significant contribution to 
deforestation by relocating rather than eliminating the deforestation risk. This risk is higher for 
those  products  currently  not  in  scope  of  the  EUDR  but  whose  upstream  ingredients  are, 
particularly where these products contain a high share of the relevant primary commodity, like 
cocoa in a pure chocolate bar. EU-based producers of goods with a lower percentage of the 
relevant commodity, where the ingredients are in scope, can spread recurring compliance costs 
for those ingredients over a broader cost base. This reduces the relative impact on the final 
product price.  

To be proposed for inclusion based on this path, the product and its supply chain must fulfil 
two  criteria,  relating  to  the  commodity  share  in  the  derived  product  and  the  ratio  between 
imports and domestic production of the good concerned. 

Firstly,  the embedded commodity share  fcs,p in  the derived product (representing, at  product 
code  level,  the  typical  percentage  of  the  final  product’s  volume  composed  of  the  relevant 
commodity), must be above 75%. A 75% embedded-commodity threshold ensures that in the 
derived products considered the regulated commodity represents a significant majority of the 
product,  and  associated  compliance  costs  borne  by  EU  producers  are  likely  to  constitute  a 
material share of total production costs. Setting the threshold significantly lower (e.g., 50%) 
would risk capturing products where the regulated commodity is not the principal cost driver, 
raising proportionality concerns for operators, while setting it much higher (e.g., 90%) would 
be  too  restrictive  and  could  unnecessarily  disadvantage  further  downstream  industries  that 
transform the commodity into more complex products.  

In  addition,  to  prevent  a  situation  in  which  the  inclusion  of  a  derived  product  with  a  high 
embedded commodity share would impose additional costs on a significantly larger group of 
importers compared with a relatively small group of EU-based producers, a second criterion is 
introduced. This criterion considers the ratio between imports and EU production of the product 
concerned. Specifically, the EU production capacity of derived products must at least be 50% 
of the import volume9.  

9 In the absence of a comprehensive EU27 production database by HS code, the difference between EU imports 
Vin,extra,p and intra-EU trade flows Vin,intra,p is used as a proxy for domestic production. Given limited external 
entry points and subsequent internal trade flows within the EU, most EU imports are assumed to circulate 
further as intra-EU trade. The excess of intra-EU trade over EU imports Vin,extra,p is therefore considered to equal 
the EU production.  In other words, this criterion requires intra-EU trade flows to be at least 1.5 times larger 
than EU imports.  

6 

 
 
 
 
 
 
 
2.1.4 Path II: deforestation and administrative burden 

If a product does not meet the criteria under the first pathway, the product can be considered 
for inclusion under the second pathway based on the magnitude of the deforestation impact as 
well as on the administrative burden, i.e., the relative compliance costs as compared to trading 
values. This second pathway helps ensure that there is environmental relevance for inclusion 
and that the recurring compliance costs remain proportionate. 

Under this pathway, the product must first meet a minimum threshold of relative or absolute 
embedded deforestation. Two separate thresholds are applied to distinguish the deforestation 
footprint per HS code from the associated trade volumes. The relative deforestation share is 
computed as the ratio between the absolute deforestation embedded in the product placed on 
the market Dp and the total volume of the products placed on the market Vin,extra,p. This threshold 
captures  products  with  smaller  trade  volumes  but  a  high  deforestation  footprint  per  unit. 
Conversely, an absolute threshold is introduced to capture products that have a smaller per-unit 
footprint but are traded in large volumes, resulting in a substantial total deforestation impact.  

For  individual  products,  the  relative  and  absolute  thresholds  are  respectively  set  at  0.005 
hectares per ton of product and 100 hectares. These thresholds are designed to help ensure that 
those products commonly associated with a high deforestation footprint remain in scope of the 
EUDR.  

Secondly, the administrative burden, defined as the ratio of recurring compliance costs Cp to 
the total value of products placed on the EU market Wp, must not exceed 5%. While the cost–
benefit analysis ensures that inclusion is defensible from a macroeconomic and environmental 
perspective,  by  comparing  the  environmental  benefits  with  the  compliance  costs,  the 
administrative burden criterion focuses on microeconomic considerations, notably the balance 
sheets  of  individual  operators,  by  comparing  the  compliance  costs  with  the  value  of  traded 
products.  A higher ratio is considered undesirable because of potential consumer price impacts. 

2.2 QUALITATIVE ASSESSMENT 

The quantitative assessment provides a first screening of the potential products considered for 
inclusion/exclusion  from  Annex  I  of  the  EUDR,  based  on  the  estimated  environmental 
footprint, costs of compliance and trade data. However, to take informed decisions on product 
scope  and  on  the  potential  inclusion/exclusion  of  certain  derived  products,  the  quantitative 
criteria are complemented with qualitative considerations such as the objectives of coherence 
along and between supply chains and avoiding disproportionate disruptions and circumvention. 
The qualitative assessment looks at the structure of the relevant supply chains, the particular 
situations of sectors, and at potential spill-over effects. It also aims to avoid potential overlaps 
with other policy initiatives in order to prevent excessive administrative burden and looks at 
the  coherence  with  policy  objectives  in  other  areas  (e.g.  circularity,  energy  security,  food 
security).  

7 

 
 
 
 
 
 
3.  RESULTS OF THE QUANTITATIVE AND QUALITATIVE ASSESSMENTS 

This chapter provides an assessment of the environmental benefits of the current EUDR scope 
and  evaluates  potential  changes  to  the  product  scope.  Section  3.1  gives  an  overview  of  the 
benefits  delivered  by  the  current  scope.  Section  3.2  presents  an  analysis  of  stakeholder-
requested changes,  to  which  both  quantitative  and qualitative assessments are applied, with 
conclusions supporting the proposed changes. Section 3.4 presents the assessment for those 
requests where the conclusions do not support the proposed changes. Finally, Section 3.4 offers 
a consolidated overview of the findings. 

3.1 CURRENT SCOPE OF THE EUDR AND REQUESTED CHANGES 

This section first provides an overview of the current scope of the EUDR and the environmental 
benefits it delivers. It then outlines the requested changes and presents their high-level impacts 
on trade flows covered by the regulation, as well as the associated environmental benefits. 

3.1.1 Current scope of the EUDR 

The  current  scope  of  the  EU  Deforestation  Regulation  (EUDR),  following  the  removal  of 
printed paper (HS Chapter 49) during the co-legislative process in December 2025, comprises 
76 product codes of the Combined Nomenclature. During the period 2015-2020, on average a 
volume of 112 million tons of EUDR relevant goods was imported into the EU per year with 
an average trade value per year of €85 billion. Figure 2 presents a breakdown of the trade value 
by geographic origin. 

Figure 2 Import value of EUDR  relevant goods broken down by geographic origin,  in  € per year between 2015-2020. 
Europe excludes imports from EU Member States. 

Cattle

Leather

Soya

Cocoa

Coffee

Oil Palm Rubber Wood

North America

Africa

Oceania

South America

Asia

Europe

€-

€10 

€20 

€30 

€40 

Billions

8 

 
 
 
 
 
 
 
 
 
 
Building on trade and deforestation data from this period, the current scope of the EUDR is 
estimated  to  capture  228  thousand  hectares  of  deforestation  embedded  in  derived  products 
placed  on  the  EU  market  by  operators  per  year.  Figure  3  illustrates  that  the  origin  of  this 
footprint  is  not  evenly  distributed  across  continents.  It  is  primarily  concentrated  in Africa 
(driven largely by cocoa production); South America, (driven by leather production and cattle); 
and Asia (driven by wood and oil palm production). Compared with Figure 2, it illustrates that 
the deforestation footprint is not proportional to overall trade volumes from these continents. 
This highlights that exposure is driven more by the nature of the commodities sourced than by 
the sheer scale of trade flows. 

Figure 3: deforestation footprint broken down by geographic origin - ha/yr 

Cattle

Leather

Soya

Cocoa

Coffee Oil Palm Rubber Wood

North
America

Africa

Oceania

South
America

Asia

Europe

 -

 10.000

 20.000

 30.000

 40.000

 50.000

 60.000

 70.000

 80.000

 90.000

Converted into economic values, the EUDR under the current scope is estimated to generate 
environmental benefits of approximately €8.3 billion per year by reducing the deforestation 
footprint and the associated emissions embedded in derived product placed on the EU market 
by operators.  

Figure 4 illustrates the breakdown of these environmental benefits. The environmental benefits 
profile differs from the pure deforestation breakdown presented in Figure 3, as it also accounts 
for greenhouse gas emissions associated with land-use and land-cover change. The emissions 
linked to these changes vary significantly depending on the type of conversion. For example, 
the conversion of natural forest to pasture typically leads to substantial carbon emissions due 
to the loss of high-carbon biomass and soil disturbance. In contrast, conversion to plantation 
forest may, in some cases, maintain or even increase carbon stocks over time, depending on 
management practices  and species composition. Overall, roughly 73% of the environmental 
benefits stem from the monetization of emissions and 27% from the ecosystem services. 

9 

 
 
 
 
Figure 4: Estimated annual environmental benefit per commodity in the period 2015-2020 by geographic origin, in €/yr 

Cattle

Leather

Soya

Cocoa

Coffee

Oil Palm Rubber Wood

North America

Africa

Oceania

South America

Asia

Europe

€-

€1.000 

€2.000 

€3.000 

€4.000 

Millions

3.1.2 Overview of proposed changes to the scope of the EUDR  

This assessment evaluates 31 product codes for potential inclusion in or exclusion from Annex 
I  of  the  EUDR.  Of  these,  10  codes  are  proposed  for  removal  from  the  scope,  while  21  are 
proposed for addition. Products proposed for exclusion include cattle skins and hides, retreaded 
tyres, and fatty acids derived from palm oil. Products proposed for inclusion comprise several 
palm  oil  derivatives  used  in  the  oleochemical  industry,  as  well  as  biodiesel,  animal  feed 
preparations, soluble coffee, and cattle tongue. 

Figure 5 illustrates the magnitude of these requested changes relative to the current scope of 
the  EUDR:  proposed  removals  account  for  €2.5  billion  in  import  value,  while  proposed 
additions represent €9.3 billion. 

Figure 5: Import value of EUDR relevant goods into the EU-27 broken down by commodity, in € per year between 2015-
2020. Yellow bars indicate the deforestation footprint of products currently in, but proposed for removal from the EUDR 
scope: leather under cattle, fatty acids under oil palm and retreaded tyres under rubber. The green bars indicate the 
deforestation  footprint  of  the  products  proposed  to  be  added  to  the  scope:  palm  oil  derivatives,  animal  feed 
preparations and biodiesel under oil palm, soluble coffee and cattle tongue. 

In scope

In scope but requested for removal

Requested for inclusion

Wood

Oil Palm

Rubber

Soya

Coffee

Cocoa

Cattle

€0

€10

€20

€30

€40

Billions

10 

 
 
 
 
 
Figure  6  illustrates  the  impact  of  these  proposals  on  the  deforestation  footprint  within  the 
current  scope  of  the  EUDR.  Proposed  removals  account  for  40.9  thousand  hectares  of 
deforestation,  while  potential  inclusions  represent  an  additional  7.4  thousand  hectares  of 
embedded deforestation. 

Figure 6: Annual deforestation footprint per commodity in the period 2015-2020, in hectares/yr. Yellow bars indicate 
the  deforestation  footprint  of  products  currently  in,  but  proposed  for  removal  from  the  EUDR  scope:  leather  under 
cattle, fatty acids under oil palm and retreaded tyres under rubber. The green bars indicate the deforestation footprint 
of the products proposed to be added to the scope: palm oil derivatives, animal feed preparations and biodiesel under 
oil palm, soluble coffee and cattle tongue.  

In scope

In scope but requested for removal

Requested for inclusion

Cocoa

Cattle

Wood

Coffee

Soya

Oil Palm

Rubber

0

10.000

20.000

30.000

40.000

50.000

60.000

70.000

80.000

In terms of environmental benefits, products proposed for removal from Annex I correspond 
to  €2.1  billion,  while  products  proposed  for  addition  account  for  €367  million.  Figure  7 
illustrates the impact of these proposed changes on the overall environmental benefits of the 
current scope of the EUDR. 

Figure  7:    Annual  environmental  benefit  per  commodity  in  the  period  2015-2020,  in  €/yr.  Yellow  bars  indicate  the 
environmental benefit of products currently in, but proposed for removal from the EUDR scope: leather under cattle, 
fatty acids under oil palm and retreaded tyres under rubber. The green bars indicate the environmental benefit of the 
products proposed to be added to the scope: palm oil derivatives, animal feed preparations and biodiesel under oil 
palm, soluble coffee and frozen tongue under cattle. 

In scope

In scope but requested for removal

Requested for inclusion

Cocoa

Cattle

Oil Palm

Coffee

Soya

Rubber

Wood

€0

€1.000

€2.000

€3.000

€4.000

Millions

11 

 
 
 
 
  
3.2 CHANGES TO THE SCOPE OF THE EUDR EXAMINED AND IMPLEMENTED 

IN THE PROPOSAL 

Following the assessment of the total environmental benefits associated with the current scope 
of the EU Deforestation Regulation (EUDR), this section examines a set of modifications to 
the product scope that have been proposed by stakeholders. The six subsections below present, 
for the analysed product codes, the quantitative impact in terms of environmental benefits and 
administrative  burden,  and  a  qualitative  reasoning.  Each  subsection  introduces  the  data 
underpinning  the  quantitative  assessment,  with  detailed  information  provided  in Annex  II. 
Finally, it concludes with a recommendation regarding inclusion or exclusion of the product 
group from the Regulation’s scope. 

3.2.1 Soluble coffee  

Soluble coffee (HS 2101 11 00) is made from brewed coffee beans that have been processed 
and dried into a powder or granules. While roasted or green coffee beans are included in the 
product scope of the EUDR, soluble coffee is not. It was therefore proposed by stakeholders to 
include soluble coffee in the scope of the EUDR.  Soluble coffee is a derived product from 
codes that are in scope of the EUDR; however, there are no further derived products of soluble 
coffee within scope that would justify its inclusion on supply-chain continuity grounds. 

In terms of the quantitative assessment, soluble coffee presents a high deforestation footprint 
(1865 hectares) and significant emissions (356 thousand tons CO2e) combined with rather low 
recurring compliance costs relative to their trade value. With an environmental benefit of €54.2 
million and a recurring compliance cost of €4.2 million, soluble coffee meets the cost-benefit 
criteria. All other criteria under both pathway 1 and 2, such as competitiveness, deforestation 
and  administrative  burden,  are  also  met,  leading  to  a  quantitative  assessment  suggesting  its 
inclusion in the EUDR scope. 

From a qualitative perspective, the current non-inclusion of soluble coffee in scope creates a 
fragmented  and incoherent  approach  for the coffee sector for operators placing  the relevant 
goods on the Union market, as soluble coffee may be placed on or exported from the Union 
market without complying with EUDR obligations, ultimately undermining its objectives. This 
situation leads to the risk that the embedded deforestation in the coffee used to make soluble 
coffee is relocated, rather than eliminated. Therefore, on the basis of both the quantitative and 
qualitative analysis, it is proposed to add soluble coffee to the EUDR product scope. 

12 

 
 
 
Figure 8: Import value  of soluble coffee (HS 2101 11 00) into  the EU  in 2024 sorted  by total  value, in thousand €/yr 
(COMEXT). 

€-

€50.000 

€100.000 

€150.000 

€200.000 

€250.000 

Vietnam

United Kingdom

Switzerland

India

Brazil

Ecuador

Colombia

United States

3.2.2 Palm oil derivatives  

Palm oil derivatives are used in the oleochemicals industry as raw materials or intermediates 
in  a  wide  variety  of  applications,  including  the  manufacturing  of  paints  and  coatings, 
pharmaceuticals,  lubricants  and  food  additives.  It  was  proposed  by  stakeholders  to  include 
several of those derivatives. The proposed products are derived from codes that are in scope of 
the EUDR; yet there are no further derived products of the suggested additions within scope 
that would justify their inclusion on supply-chain continuity grounds. 

Most  palm oil derivatives suggested for inclusion meet  the  quantitative  cost-benefit criteria 
(See Annex II) 10. Only oleic, linoleic, linolenic acids (HS 291615) and acyclic polyamines (HS 
29212900)  do  not  pass  the  cost-benefit  analysis  and  are  for  that  reason  not  suggested  for 
inclusion in scope of the EUDR.  

With a compliance cost ratio below 3% and significant absolute or relative deforestation values, 
all remaining products fulfil the additional criteria under pathway 2 for inclusion within the 
scope of the EUDR. Having in general a high embedded commodity share (above 75%) and a 
significant intra EU trade compared to imports (Annex II), several products identified by the 
quantitative assessment also meet the conditions for inclusion under pathway 1. 

10 The environmental benefits and compliance costs are  estimated under the assumption that all derivatives are 
produced exclusively from palm oil and that all operators trade only in palm oil derivatives. In practice, many of 
these products can also be derived from other vegetable oils and fats. However, provided that derivatives from 
different feedstocks are not mixed and that the number of operators scales proportionally with traded volumes, 
both environmental benefits and compliance costs would decline proportionally. Consequently, the overall cost–
benefit ratio remains unaffected. 

13 

 
 
 
 
 
 
 
Annex  I  of  the  EUDR  does  not  contain  all  relevant  palm  oil  derivatives  used  in  the 
oleochemicals industry. The absence of certain oleochemicals from the scope of EUDR leads 
to gaps in obligations applicable in the supply chain, as certain oleochemicals may be placed 
on the Union market without complying with the EUDR obligations. For the oleic, linoleic, 
linolenic acids (HS 291615) and acyclic polyamines (HS 29212900) which do not  meet the 
cost-benefit analysis, there are no clear qualitative findings at this stage that would require to 
modify  the  quantitative  assessment.  On  the  basis  of  the  quantitative  analysis  and  of  the 
qualitative  assessment,  it  is  proposed  that  the  majority  of  palm  oil  derivatives  used  in  the 
oleochemicals industry be included in Annex I of EUDR. 

Figure 9: Import value of palm oil derivatives into the EU in 2024 sorted by total value, in thousand €/yr (COMEXT). The 
products requested for inclusion are hydrogenated vegetable oils (HS 151620), chemically modified animal/veg oils 
(HS 1518), crude glycerol (HS 152000), octanol (HS 290516), lauryl, cetyl, and stearyl alcohols (HS 290517), saturated 
monohydric  alcohols  (HS  290519),  acetic  acid  esters  (HS  291539),  oleic,  linoleic,  linolenic  acids  (HS  291615), 
undecenoic  acid  (HS  29161910),  acyclic  monoamines(HS  292119),  acyclic  polyamines  (HS  29212900),  quaternary 
ammonium  salts  (HS  292390),  acyclic  amides  (292419),  misc.  chemical  products  (HS  382499)  and  polyethers  (HS 
390729)  

20 
HS 1516
HS 290519
HS 29212900

HS 1518
HS 291539
HS 292390

HS 152000
HS 291615
HS 292419

HS 290516
HS 29161910
HS 382499

HS 290517
HS 292119
HS 390729

€0

€400.000

€800.000

€1.200.000

€1.600.000

€2.000.000

China

South Korea

United States

United Kingdom

Malaysia

India

Japan

Switzerland

3.2.3 Frozen cattle tongue  

Cattle meat and most offal products are already included, both in fresh and frozen form, in the 
scope of the EUDR. However, only  fresh cattle  tongues fall within the scope of the EUDR 
whereas  frozen  cattle  tongues  (HS  0206  21  00)  do  not.  It  was  therefore  proposed  by 
stakeholders to include frozen cattle tongues. 

Trade data show that a significant share of cattle tongues marketed in the Union are imported 
from  third countries in  frozen form. In practice,  frozen  cattle tongues can be considered an 
upstream product in the supply chain of fresh cattle tongues.  

14 

 
 
 
 
 
 
 
 
The  absence  of  frozen  cattle  tongue  in  Annex  I  therefore  creates  a  risk  of  supply  chain 
discontinuity. Hence, frozen cattle tongues are proposed for inclusion within the scope of the 
EUDR based on the supply chain continuity criterion, the first test in the stepwise approach of 
the quantitative assessment, rendering a cost-benefit test unnecessary.    

Excluding frozen cattle tongues, while their fresh counterparts are included, creates a risk of 
circumvention, as imports may shift from fresh to frozen products. To prevent such potential 
circumvention, the qualitative assessment aligns with the quantitative assessment. Therefore, 
it is proposed to include HS 02062100 in Annex I of the EUDR. 

Figure 10: Import value of frozen cattle tongue (HS 0206 21 00) into the EU27 in 2024 sorted by total value, in thousand 
€/yr (COMEXT). 

€0

€100

€200

€300

€400

€500

€600

United Kingdom

Norway

Switzerland

Iceland

Japan

3.2.4 Soap in the form of bars, cakes, flakes and granules 

Soap,  soap  noodles  and  surfactants  are  downstream  oleochemical  products.  Surfactants  are 
surface-active agents that help break down the interface between water and oils or dirt. They 
are  one  of  the  main  ingredients  used  in  detergents.  The  inclusion  of  soap  (HS  3401)  and 
surfactants  (HS  3402)  has  been  proposed  by  several  stakeholders,  while  other  stakeholders 
expressed opposing views.  

There are no further products derived from soap and surfactants in scope of the EUDR that 
would justify their inclusion based on supply-chain continuity grounds. 

The  quantitative  assessment  indicates  that  the  cost  of  compliance  for  soap  (HS  3401)  and 
surfactants (HS 3402) exceeds the environmental benefits from their inclusion in the product 
scope. This is due to the high fragmentation of the import base and the relatively low palm oil 
content  for  soap  (between  20-50%)  and  surfactants  (below  20%)11.  The  highly  fragmented 
importer  base  increases  estimated  recurring  compliance  costs.  As  background,  there  are 
approximately 750 EU importers of palm oil (HS 1511), compared to nearly 16 thousand EU 
importers  of  soap  (HS  3401).  This  dispersion  of  operators  results  in  estimated  recurring 
compliance  costs  of  approximately  €43.7  million.  By  contrast,  the  relatively  low  palm  oil 
content  in  soap,  and  therefore  limited  embedded  deforestation  risk,  limits  potential 
environmental benefits to an estimated €8.0 million.  

11 WWF 2019: The Impact of the Consumption of Palm Oil in Poland on the Global Natural Environment and 
Analysis of the Possibility of Replacing it by Other Vegetable Oils 

15 

 
 
 
 
 
Similarly, for surfactants, the estimated recurring compliance costs of €16.5 million per year 
exceed  the  expected  environmental  benefits  worth  €9.4  million  per  year.  Therefore,  the 
quantitative assessment does not suggest including both products in scope of the EUDR.  

At the same time, some considerations can support inclusion of soap and surfactants despite 
the outcome of the quantitative assessment. Keeping these products outside the scope  could 
result in a fragmented approach along the palm oil supply chain, as these products containing 
palm oil could be placed on the Union market without being subject to EUDR obligations. This 
would risk undermining the effectiveness of the Regulation and maintaining gaps in obligations 
applicable in the supply chain. 

Taking  into  account  the  opposing  views,  the  results  of  the  quantitative  analysis,  and  the 
fragmented  approach  resulting  from  non-inclusion,  the  Commission  has  analysed  the 
possibility of including products at a more granular level. In particular, the inclusion of non-
liquid  soaps,  namely  soap  bars  (HS  3401  11  00)  and  soap  flakes  (HS  3401  20)  has  been 
assessed. These products are characterised, on average, by a higher share of natural oils in their 
composition compared to liquid soaps classified under HS 3401 and surfactants under HS 3402.  

Although compliance costs for these subproducts, estimated at €10.9 million and €9.7 million 
for  soap  bars  and  flakes  respectively,  still  exceed  the  associated  environmental  benefits, 
estimated at €4.0 million and €2.5 million, these two subcodes account for 82% of the total 
environmental benefits associated with the proposed inclusion of HS 3401, while representing 
only 52% of the estimated compliance costs. 

In this context and taking into account the need to ensure coherence and effectiveness across 
the supply chain, the Commission considers that there are sufficient qualitative grounds at this 
stage to support the inclusion of soap bars and flakes within the scope of the Regulation. It is 
therefore proposed to include these products in Annex I of the EUDR. 

Figure 11: Import value of soap bars (HS 3401 11 00) and soap flakes (HS 3401 20) into the EU in 2024 sorted by total 
value, in thousand €/yr (COMEXT). 

€0

€20.000

€40.000

€60.000

€80.000

€100.000

HS 340120

HS 34011100

Turkey

United Kingdom

Indonesia

China

Malaysia

Israel

United States

Kosovo

16 

 
 
 
 
3.2.5 Hides, skins and leather of cattle  

Hides  and  skins  are  the  raw,  unprocessed  outer  coverings  of  bovine  animals  removed  after 
slaughter, preserved with different techniques, and processed for commercial use. Through the 
tanning process, hides and skins are transformed into leather. Hides come from large, mature 
cattle, and thus are thicker and suitable to produce durable leather goods (e.g. shoes, belts). 
Skins of cattle typically derive from younger or smaller bovines and are thinner and finer in 
grain and thus often used for high-quality leather products (e.g. gloves, luxury accessories).  

In the reaction to the public consultation on the draft delegated Act of April 2025, 25% of the 
respondents  referred to  leather. Industrial  stakeholders proposed  to  remove leather from  the 
scope of the EUDR.   Some of them have mentioned, as a possible alternative, the inclusion of 
leather derived products in the scope, to avoid risks of relocation outside the EU. Their main 
arguments  highlight  leather  as  a  by-product  of  meat  production.  On  the  other  side,  a  broad 
range  of  NGOs  have  requested  to  keep  leather  products  in  scope  of  the  EUDR.   The  main 
arguments  presented  highlight  leather  as  a  co-product  of  meat  production,  the  substantial 
market size and its value. 

When considered as  a by-product  of cattle production, hides and skins account  for 2.5% of 
deforestation through price effects and demand interactions in the cattle meat market, and meat 
is  the  main  revenue  source  of  cattle  producers.12 The  remaining  97.5%  of  the  deforestation 
footprint is attributed to other cattle products. When considered as a co-product (i.e. a material 
produced  simultaneously),  hides  and  skins  are  set  accountable  for  5%  of  cattle-related 
deforestation  by  following  a  value-allocation  approach.  The  remaining  95%  of  the 
deforestation footprint is attributed to other cattle products13.  

Depending on the approach, the environmental benefit from leather inclusion could range from 
€979 to €1957 million per year. Recurring compliance costs are €16.7 million per year. These 
estimates are subject to a certain level of uncertainty stemming from assumptions around the 
absolute deforestation  allocated to  cattle, the  share allocated  to the skin  and the  conversion 
factors used to reflect the processing of raw skins to semi processed goods.  

12  To  analyse  the  impact  of  leather  when  solely  seen  as  a  by-product  and  not  a  driver  of  deforestation,  a 
hypothetical  scenario  is  considered  where  no  additional  income  is  generated  from  hides.  Under  this  scenario, 
producers would lose around 5% of their revenues, the value of skins, and would therefore need to raise meat 
prices by roughly 5%. When meat becomes more expensive, people buy less of it. Based on typical consumer 
behaviour, cattle meat has a price elasticity of -0.5 (Tonsor et al, 2018), meaning that a 5% increase in beef prices 
would reduce demand by about 2.5%. Hence, with leather as a byproduct, the income from hides and skins keeps 
prices  for  meat  slightly  lower,  supporting  higher  meat  consumption  and  thereby  more  deforestation.  Without 
revenues from cattle skins and thus higher prices for meat, beef demand would fall by around 2.5%, which would 
in turn reduce cattle-related deforestation by approximately the same percentage. 
13 Value allocation approach based on the scientific publication from Singh, C. and Persson, U.M. (2026) 
“Global patterns of commodity-driven deforestation and associated carbon emissions”; it deviates from the 
general mass-based approach (deforestation linked to a commodity is distributed across its subproducts based on 
the share of total mass each subproduct represents) according to which hides and skins would count for 8% of 
cattle related deforestation. This is a conservative estimate, as in some large slaughterhouses leather has been 
reported to account for up to 26% of total earnings, as reported by Bain & Company (2020). 

17 

 
 
 
 
 
Were cattle skins and hides not to be included in the scope of the EUDR, by having cattle meat 
and offal products in scope of the EUDR, a slice of these environmental benefits would still be 
indirectly captured in most cases when meat is imported into the EU, as the hides associated 
with  meat  imports  into  the  EU  are  inherently  required  to  comply  with  the  no-deforestation 
criteria. 

A number of further qualitative considerations need to be taken into account. First, given the 
lower  economic  value  of  cattle  skins  and  hides  compared  to  meat  within  overall  cattle 
production,  combined  with  asymmetries  in  trade  flows  between  meat  and  hides,  economic 
operators have limited leverage to obtain information required to comply with the EUDR from 
suppliers outside the Union market (cattle farmers within the Union are in any event subject to 
the Regulation). Second, leather has, compared to other products, a separate value chain from 
meat products; the downstream leather value chain is distinct from the meat value chain and 
typically involves additional processing stages and intermediaries which also reduces the direct 
link  between  leather  operators  and  cattle  farmers,  and  maintaining  the  inclusion  would 
therefore represent a high burden on the industry. 

Third, maintaining leather within the scope risks creating an unbalanced approach, as importers 
of finished leather goods (such as footwear, handbags or other articles) could continue to place 
them on the Union market without being subject to equivalent due diligence obligations, while 
operators producing  leather goods within the EU would face  compliance  requirements.  The 
inclusion of derived products to address this situation cannot be considered at this stage due to 
the specificities of the sector including the high number of new products that would enter the 
scope of the Regulation as this would not give sufficient time for businesses from EU and third 
EU  countries  to  prepare  before  entering  into  application.  Moreover,  the  potential  impact  of 
including  derived products  on the load of the EUDR IT system  also  needs  to  be taken into 
account. 

Against this background and taking into account the need to ensure proportionality and to avoid 
unintended economic distortions, it is therefore proposed to exclude these products from the 
scope of the EUDR.  

18 

 
 
 
 
Figure  12:  Import  value  of  cattle  skin  products  from  3rd  countries  into  the  EU27  in  2024  sorted  by  total  value,  in 
thousand  €/yr  (COMEXT).  The  three  products  requested  for  exclusion  are  raw  hides  and  skins  of  cattle  (HS  4101), 
tanned or curst hides and skins of cattle (HS 4104), and leather of cattle, further prepared after tanning or crusting (HS 
4107) 

€0

€50.000

€100.000

€150.000

€200.000

€250.000

 HS 4101

HS 104
HS 4104 

HS 4107

Brazil

United States

United Kingdom

New Zealand

India

Turkey

Argentina

Switzerland

3.2.6 Retreaded tyres 

Retreaded tyres are used tyres at the end of their life cycle. Through the retreading process, a 
new  rubber  tread  is  applied  to  the  old  tyre  casing,  allowing  a  life-extension  of  the  tyre. 
As retreaded tyres are manufactured from used tyres, it is difficult for retreaders to retrieve the 
traceability information of the original tyre casing. Therefore, it has been proposed to exclude 
retreaded tyres from Annex I and limit the EUDR obligations to the new rubber thread applied 
to the old casing. 

Rubber tyres are end-product; hence, there are no further derived products that would prevent 
the exclusion of retreaded tyres from the scope of the EUDR based on supply-chain continuity 
grounds. 

As only a small fraction of a retreaded tyre, the new tread (approximately 25%), falls within 
the scope of the EUDR, and that fraction consists of only about 20% natural rubber, recurring 
compliance costs exceed environmental benefits for most products considered for removal (cf 
Annex II). Only rubber tyres for buses (HS 40121200) meet the cost–benefit criteria, driven by 
their  slightly  higher  natural  rubber  content.  However,  this  product  does  with  an  absolute 
deforestation value of 5 hectares and a relative deforestation value just below 0.0005 not meet 
the  thresholds  for  the  deforestation  criterion  required  for  inclusion  via  the  second  pathway. 
Therefore, retreaded tyres products would not meet the criteria of the quantitative assessment 
for remaining in scope.  

In addition, retreading allows for a life-extension of used tyres, thus encouraging circular and 
resource  efficient  practices.  Based  on  the  insights  from  the  quantitative  and  qualitative 
assessment, it is therefore proposed that retreaded tyres are removed from the product scope of 
EUDR. Only new rubber thread imported as a standalone product into the EU, to be applied to 
the old tyre casing in the domestic EU market, remains in scope. 

19 

 
 
  
 
 
Figure 13: Import value of retreaded tyres from 3rd countries into the EU27 in 2024 sorted by total value, in thousand 
€/yr  (COMEXT).  The  products  requested  for  exclusion  are  retreaded  rubber  tyres  for  motor  cars  (HS  40121100), 
retreaded rubber tyres for buses (HS 40121200), retreaded rubber tyres for aircrafts (HS 40121300), other retreaded 
rubber tyres (HS 40121900), solid or cushion rubber tyres (40129020) and rubber tyre flaps (HS 40129090). 

HS 40121100

HS 40121200

HS 40121300

HS 40121900

HS 40129020

HS 40129090

€0

€20.000

€40.000

€60.000

€80.000

€100.000 €120.000 €140.000 €160.000

Sri Lanka

United Kingdom

China

United States

Vietnam

India

South Korea

Mexico

3.3 CHANGES  PROPOSED  BY  STAKEHOLDERS  BUT  NOT  IMPLEMENTED  IN 

THE PROPOSAL 

This section provides an overview of proposed modifications to the product scope that have 
not  been implemented  in  the draft Delegated Act  at  this stage. The  three subsections below 
present  the  requested  changes  by  stakeholders  and  describe,  based  on  the  results  of  the 
quantitative  and  qualitative  analysis,  why  those  requests  have  not  been  implemented  in  the 
draft Delegated Act. 

3.3.1 Biodiesel 

Biodiesel is a renewable liquid fuel made from biomass (‘biofuels’ and ‘bioliquids’). It serves 
as a renewable alternative to fossil fuels in hard-to-abate sectors, such as aviation and maritime 
transport,  where  electrification  is  not  a  viable  option.    It  was  proposed  by  stakeholders  to 
include biodiesel.  

Biodiesel is an end-product; hence, there is no further derived products that could justify its 
inclusion in the scope of the EUDR based on supply-chain continuity grounds. 

With a small importer base and a significant percentage of palm oil embedded in biodiesel (HS 
38260010),  the  quantitative  analysis  concludes  that  the  environmental  benefits  of  including 
biodiesel in scope of the EUDR, with an estimated value of €66.9 million per year, far exceed 
the estimated recurring compliance costs of €353 thousand per year14.  

14 The analysis assumes that all imported biofuels consist of 50% palm oil, that all importing operators handle 
palm oil–based biofuels, and that import volumes scale linearly with the number of operators. In practice, not all 
biofuels  are  palm  oil–based,  and  not  all  operators  import  such  products.  As  a  result,  both  the  estimated 
environmental benefits and associated compliance costs are likely overstated. However, provided that the number 
of operators trading in palm oil–derived biofuels scales linearly with the traded volume, compliance costs would 
remain at any time lower than the environmental benefits. 

20 

 
 
 
 
 
Whilst  biodiesel  does  not  meet  the  criteria  for  inclusion  under  pathway  1,  it  fulfils  the 
additional criteria for inclusion via pathway 2 of the quantitative assessment, i.e.,  palm  oil-
based biodiesel exceeds the deforestation threshold while the administrative burden remains 
below the 5% threshold.  

However, biodiesel is already subject to Directive (EU) 2018/2001 as amended by Directive 
(EU)2023/241315  (Renewable Energy Directive). The placement of biodiesel on the market is 
therein  regulated  in  a  strict  and  effective  manner,  addressing  both  direct  and  indirect 
environmental impacts. Including biodiesel within the scope of the EUDR would therefore lead 
to  double  regulation  without  providing  additional  environmental  benefits.  It  is  therefore 
suggested to maintain this product out of the scope of EUDR. 

Figure  14:  Import  value  of  biofuels  from  3rd  countries  into  the  EU27  in  2024 sorted  by  total  value,  in  thousand  €/yr 
(COMEXT). 

€-

€100.000  €200.000  €300.000  €400.000  €500.000  €600.000  €700.000  €800.000 

China

Malaysia

United Kingdom

Argentina

South Korea

Indonesia

Brazil

Norway

3.3.2 Preparations used in animal feed  

Animal  feed  preparations  are  feed  products  obtained  by  processing  animals  or  vegetable 
materials. The inclusion of preparations used in animal feed was proposed by stakeholders. 

Animal feed preparations are an end-product; hence, there is no further derived products that 
could  justify  their  inclusion  in  the  scope  of  the  EUDR  based  on  supply-chain  continuity 
grounds. 

According  to  the  quantitative  assessment,  with  a  small  importer  base  and  a  significant 
percentage  of  palm  cake  embedded  in  animal  feed  preparations,  environmental  benefits  of 
including animal feed preparations (HS 2309) in scope are with an estimated value of €51.4 
million per year 4 times higher than the recurring compliance costs of €12.4 million per year16.  

15 OJ L, 31.10.2023. ELI: http://data.europa.eu/eli/dir/2023/2413/oj. 
16 The analysis assumes that all imported  animal feed preparations consist of 50% palm oil, that all importing 
operators handle palm oil–based feed preparations, and that import volumes scale linearly with the number of 
operators. In practice, not all feed preparations are palm oil–based, and not all operators import such products. As 
a  result,  both  the  estimated  environmental  benefits  and  associated  compliance  costs  are  likely  overstated. 

21 

 
 
 
 
 
Animal feed preparations do not meet the criteria for inclusion under pathway 1 but do meet 
the criteria relating to relative deforestation risk and administrative burden and are therefore 
suggested for inclusion via pathway 2. 

At the same time,  while the  quantitative assessment  indicates potential benefits,  the overall 
impacts on the agricultural sector have not yet been sufficiently assessed.  This is particularly 
relevant in light of the Commission’s Vision for Agriculture and Food, which highlights that 
the  EU’s  food  sovereignty  depends  to  a  large  extent  on  imported  inputs  such  as  feed  and 
underlines the need to reduce strategic dependencies and ensure resilient supply chains. 

In this context, there is not sufficient qualitative evidence at this stage for the Commission to 
support  inclusion  of  preparations  used  in  animal  feed  in  the  scope  of  the  Regulation.  It  is 
therefore suggested to maintain these products outside the scope. 

Figure 15: Import value of animal feed preparations from 3rd countries into the EU27 in 2024 sorted by total value, in 
thousand €/yr (COMEXT). 

€0

€200.000

€400.000

€600.000

€800.000

€1.000.000

China

United Kingdom

Thailand

Liechtenstein

United States

Canada

Serbia

Norway

3.3.3 Oilcake and other solid residues of palm nuts or kernels  

Oilcake and other solid residues of palm nuts or kernels (HS 230660) are palm oil derivatives 
resulting from the physical refining of palm oil. They are used in the manufacturing of animal 
feed. Stakeholders requested their removal from the EUDR product scope.  

As further prepared animal feed preparations are not proposed for inclusion in the scope of the 
EUDR (Section 3.3.1), there are no grounds would that prevent the removal of palm cake from 
the EUDR scope, based on the supply chain continuity criterion. 

However, according to the quantitative assessment, the environmental benefits derived from 
their  inclusion  in  the  scope  of  EUDR  exceed  the  recurring  compliance  costs,  with 
environmental  benefits  of  €154.5  million  and  compliance  costs  of  €187,000. Additionally, 
while the product does not meet the criteria for inclusion under pathway I, the product meets 
the  deforestation  and  administrative  burden  criteria  under  pathway  II.  Therefore,  the 
quantitative approach suggests keeping HS 230660 in scope.  

However, provided that the number of operators trading in palm oil–derived feed preparations scales linearly with 
the traded volume, compliance costs would remain at any time lower than the environmental benefits. 

22 

 
 
 
 
 
In addition to relevant environmental impact of this product shown by the quantitative analysis, 
the exclusion of oilcake and other solid residues of palm nuts or kernels would be in contrast 
with  the approach  proposed for the  palm oil supply chain,  where the  proposed  inclusion of 
further  palm  oil  derivatives  aims  to  ensure  a  uniform  regulatory  approach  and  avoid 
inconsistencies in the obligations applicable throughout the supply chain, in particular for the 
oleochemicals  sector.  Excluding  oilcake  would  also  affect  this  balanced  approach  between 
derived products used in animal feed, as some of these products such as soya cake or cocoa 
husks would still be covered by EUDR obligations while oilcake would be out of scope. On 
the basis of the quantitative and qualitative insights, it is therefore proposed to maintain oilcake 
within the product scope of EUDR.  

Figure 16: Import value of palm oil products from 3rd countries into the EU27 in 2024 sorted by total value, in thousand 
€/yr (COMEXT). The product requested for exclusion is oil cake (HS 230660). 

€-

€50.000 

€100.000 

€150.000 

€200.000 

€250.000 

€300.000 

Indonesia

Cô    ’I     

Malaysia

Nigeria

United Kingdom

Sierra Leone

Tunisia

Jordan

23 

 
 
 
 
 
 
 
 
 
3.4 OVERVIEW OF QUALITATIVE AND QUANTITATIVE ASSESSMENT 

An overview of the considerations and final analysis under both the qualitative and quantitative 
assessment  is  presented  below  in  Figure  17.  Vertically,  the  figure  lists  all  product  codes 
submitted  by  stakeholders  for  analysis,  with  those  currently  in  scope  on  top  and  the  codes 
currently  not  in  scope  below.  Horizontally,  it  presents  the  results  of  the  quantitative  and 
qualitative assessments. Within the quantitative assessment, the net benefit17 (environmental 
benefit  minus  recurring  compliance  cost)  is  shown  together  with  the  assessment  of  criteria 
under Path I and Path II of the quantitative approach. The colour scheme indicates the EUDR 
scope assessment: green denotes a positive test or inclusion assessment, red indicates a negative 
assessment, and grey signifies that the step is not applicable because a preceding step in the 
stepwise approach already yielded a negative assessment. 

Figure 17: Overview of proposed product codes and the results of quantitative and qualitative assessments. Vertically, 
codes currently in scope are presented on top, and those currently not in scope below. Horizontally, the figure shows 
the quantitative and qualitative assessments, with net benefit (environmental benefit minus compliance cost) shown 
under the qualitative assessment alongside Path I and II criteria from the quantitative approach. Colours indicate EUDR 
scope:  green  =  positive  assessment/inclusion,  red  =  negative/exclusion,  grey  =  step  not  applicable  due  to  a  prior 
negative assessment. The final column spells out the proposed change in Annex I of the EUDR.  

17 The bar with the net benefits for HS 4104 is truncated; computed net benefits are €1.750 million. 

24 

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             
 
 
 
 
 
 
4. CONCLUSIONS 

The  comprehensive  analysis  of  stakeholders’  proposals  for  inclusion/exclusion  of  derived 
products is based on first a quantitative assessment, which combines data on environmental 
footprint, costs of compliance and trade aspects. The insights of the quantitative assessment are 
then  complemented  with  qualitative  considerations  to  evaluate  stakeholders’  proposals 
concerning EUDR product scope.  

Based on the quantitative and qualitative considerations presented in section 3 and 4, seventeen 
product codes  are proposed for inclusion in Annex I of the EUDR,  three product  codes are 
proposed for exclusion from that Annex and one product code is proposed to be replaced with 
a more specific product code. 

The results of the analysis presented in this SWD is reflected in a draft Delegated Act amending 
Annex I of the EUDR accordingly. The draft Delegated Act, published alongside this working 
document, will now be subject to the 4-week public feedback after which the Commission will 
carefully  analyse  all  input  before  presenting  a  final  Delegated  Act.  Any  new  request  for 
inclusion/exclusion  from Annex  I  of  the  EUDR  that  might  be  presented  during  the  public 
feedback will be analysed according to the assessment methodology presented in this paper.   

Table 1: Product codes proposed for inclusion in Annex I of EUDR 

Commodity 

HS Code 

Description 

Cattle 

Coffee 

ex 0206 21 00  

Frozen cattle tongues 

ex 2101 11 00 

Extracts, essences, and concentrates of coffee 

Oil palm 

ex 1516 20 

Oil palm 

ex 1518 00 

Oil palm 

ex 1520 00 

Oil palm 

ex 2905 16 

Oil palm 

ex 2905 17 00 

Palm, palm kernel and babassu oils and their fractions, 
partly  or  wholly  hydrogenated,  inter-esterified,  re-
esterified or elaidinised, whether or not refined, but not 
further prepared 

Palm,  palm  kernel  and  babassu  oils  and  their  fractions 
boiled,  oxidised,  dehydrated,  sulphurised,  blown, 
polymerised  by  heat  in  vacuum  or  in  inert  gas  or 
otherwise  chemically  modified,  excluding  those  of 
heading  1516;  inedible  mixtures  or  preparations  of 
animal, vegetable or microbial fats or oils or of fractions 
of  different  fats  or  oils  of  this  chapter,  that  contain  or 
have been made using oil palm 

Crude glycerol, glycerol waters and lyes that have been 
produced using oil palm 

Octanol  (octyl  alcohol)  and  isomers  thereof,  that  have 
been synthesized using oil palm 

Dodecan-1-ol  (lauryl  alcohol),  hexadecan-1-ol  (cetyl 
alcohol) and octadecan-1-ol (stearyl alcohol), that have 
been synthesized using oil palm 

25 

 
 
Oil palm 

ex 2905 19 00 

Oil palm 

ex 2915 39 

Oil palm 

ex 2916 19 10 

Oil palm 

ex 2921 19 

Oil palm 

ex 2923 90 00 

Oil palm 

ex 2924 19 00 

Oil palm 

ex 3824 99 

Oil palm 

ex 3907 29 

Other  saturated  monohydric  alcohols,  not  elsewhere 
specified  or  included,  that  have  synthesized  using  oil 
palm 

Esters  of  acetic  acid,  other  than  ethyl  acetate,  vinyl 
acetate,  n-butyl acetate and dinoseb (ISO) acetate, that 
have been synthesized using oil palm 

Undecenoic  acids,  its  salts  and  esters  that  have  been 
synthesized using oil palm 

Acyclic monoamines and their derivatives; salts thereof, 
other than methylamine, di- or trimethylamine and their 
2-(N,N-dimethylamino)ethylchloride 
salts, 
2-(N,N-diethylamino)ethylchloride 
hydrochloride, 
hydrochloride 
2-(N,N-
diisopropylamino)ethylchloride hydrochloride, that have 
been synthesized using oil palm 

and 

Quaternary ammonium salts and hydroxides, other than 
tetraethylammonium 
salts, 
and 
choline 
perfluorooctane 
and 
didecyldimethylammonium perfluorooctane sulphonate, 
that have been synthesized using oil palm 

sulphonate 

its 

Acyclic  amides,  carbamates  and  their  salts,  other  than 
meprobamate 
(ISO), 
monocrotophos  (ISO)  and  phosphamidon  (ISO),  that 
have been synthesized using oil palm 

fluoroacetamide 

(INN), 

Other  chemical  products  and  preparations  of  the 
chemical or allied industries (including those consisting 
of mixtures of natural products), not elsewhere specified 
or  included,  that  contain  or  have  been  made  using  oil 
palm 

Other  polyethers 
bis(polyoxyethylene)  methylphosphonate, 
been made using oil palm 

in  primary 

forms,  other 

than 
that  have 

Oil palm  

ex 3401 11 00 

Oil palm  

ex 3401 20  

Soap  in  the  form  of  bars,  cakes,  moulded  pieces  or 
shapes for toilet use (including medicated products), that 
contain or have been made using oil palm 

Soap in forms other than bars, cakes, moulded pieces or 
shapes, that contain or have been made using oil palm 

Table 2: Products codes proposed for exclusion from Annex I of EUDR 

Commodity 

HS Code 

Cattle 

ex 4101 

Description 

Raw  hides  and  skins  of  cattle  (fresh,  or  salted,  dried, 
limed,  pickled  or  otherwise  preserved,  but  not  tanned, 

26 

 
 
 
Cattle 

ex 4104 

Cattle 

ex 4107  

parchment-dressed or further prepared), whether or not 
dehaired or split 

Tanned or crust hides and skins of cattle, without hair on, 
whether or not split, but not further prepared 

Leather  of  cattle,  further  prepared  after  tanning  or 
crusting,  including  parchment-dressed  leather,  without 
hair on, whether or not split, other than leather of heading 
4114 

Table 3: Product codes proposed for replacement in Annex I of EUDR 

Commodity 

HS Code 

To be replaced with 

Rubber 

ex  4012  Retreaded  or  used 
pneumatic  tyres  of  rubber;  solid 
or cushion tyres, tyre treads and 
tyre flaps, of rubber 

ex 4012 90 30 Tyre treads 

27 

 
 
 
 
 
 
 
ANNEX I - KEY VARIABLES AND DATA SOURCES 

The methodology presented in this SWD is based on a stepwise approach bringing together 
data  on  deforestation  footprint  of  derived  products,  costs  of  compliance  and  trade  aspects. 
Three sets of key variables underpin the inclusion and exclusion logic presented in Section 3 
and elaborated further below. These are:  

(i) 

The  estimated  embedded  deforestation  and  associated  emissions  in  derived 
products placed on the EU market by operators at product level which underpins 
the calculation of environmental benefits.  
The estimated recurring compliance costs. 

(ii) 
(iii)  Trade volumes and values. 

Embedded deforestation and associated emissions  

The  deforestation  Dp  embedded  in  the  import  of  product  p  is  the  summed  product  of  the 
deforestation intensity Ir,c,p of raw commodity r in country c, the volume of the derived product 
placed on the EU market by opeartors Mp,c, and the conversion factor fp over time period 2015-
202018: 

𝐷𝑝 = ∑ 𝐼𝑟,𝑐,𝑝 ∙ 𝑓𝑝 ∙ 𝑀𝑝,𝑐

𝑐

The conversion factor fp expresses the proportion of the relevant primary commodity contained 
in a given derived product. It translates trade volumes of derived goods into the corresponding 
quantity  of  primary  commodity  embedded  in  those  goods  for  the  purpose  of  estimating 
associated  deforestation  and  emissions.  The  conversion  ratio  therefore  accounts  only  for 
processing  losses  and  for  dilution  resulting  from  the  incorporation  of  other  ingredients  not 
derived from the same primary commodity. It does not reflect the generation of co-products or 
by-products during primary processing, as these outputs have their own economic value and 
associated deforestation impacts. 

This approach avoids overstating impacts by attributing the entire upstream production volume 
to  a  single  downstream  product.  Instead,  it  ensures  that  only  the  share  of  the  primary 
commodity physically embodied in the traded product is considered, while upstream impacts 
are  allocated  proportionally  across  all  economically  valuable  co-products.  In  this  way,  the 
methodology  maintains  internal  consistency  between  physical  trade  flows  and  impact 
accounting and prevents double counting or misallocation of deforestation risk. 

18 The DeDuCE dataset, which provides estimates of deforestation by country and commodity, is only available 
up to 2022. However, the model exhibits limitations for the years 2021–2022, making it difficult to accurately 
assess recent trends in the deforestation impact of derived products. In particular, delays in national reporting of 
agricultural land-use and harvested area data, which serve as inputs to the DeDuCE model, may distort 
deforestation signals. 

28 

 
 
 
 
 
 
 
Illustrative example of the conversion factor for soap 

To produce 1 tonne of soap, 400 kg of palm oil are required, while the remaining 600 kg 
consists of other oils, water, and salts. The conversion factor for palm oil in this soap is 
therefore 0.4. This factor accounts for processing losses during the soap production, but 
not for the refining from palm nuts. Co-products such as palm kernel cake, crude palm oil, 
or palm oil mill effluent (POME) have their own economic value and are allocated their 
own share of upstream deforestation and emission impacts. 

Conversion factors are assumed to be constant over time and geography and computed based 
on a combination of scientific literature and expert and stakeholder consultations, building on 
work delivered by the consultants under the review contract. 

The volume Mp of dervided product p placed on the EU market by operators is derived from 
COMEXT,  the  European  Commission’s  official  database  on  international  trade  in  goods19. 
COMEXT provides detailed, product-level import statistics reported by both EU member states 
and partner countries20. 

The deforestation intensity Ir,c,p indicates, on average, the amount of deforestation associated 
with the production of one unit of raw commodity r in country c. It reflects the area of forest 
converted  per  unit  of  commodity  produced,  considering  land-cover  changes  directly 
attributable  to  that  commodity.  A  distinction  is  made  between  the  computation  of  the 
deforestation intensity factor for raw commodities and derived products.  

For  raw  commodities,  the  deforestation  intensity  Iraw  is  computed  as  the  ratio  between  the 
reported forest land-cover loss Fc,r, in hectares, directly attributable to the cultivation of that 
commodity in country c and the total production of that commodity Qc,r, in tonnes, in the same 
country and period:  

𝐼𝑟𝑎𝑤,𝑟,𝑐 =

𝐹𝑐,𝑟
𝑄𝑐,𝑟

Annual deforestation data per commodity and country are sourced from DeDuCE17, a database 
of deforestation and emissions statistics linked to agricultural and forestry production, based 
on the scientific, peer-reviewed work of Singh and Persson, published in Nature Food (2026).  

19  Eurostat,  Comext  –  International  Trade  in  Goods  Database  (https://ec.europa.eu/eurostat/web/international-
trade-in-goods/database) 
20 Singh, C. and Persson, U.M. (2026). Global patterns of commodity-driven deforestation and associated carbon 
emissions (https://www.deforestationfootprint.earth/) 

29 

 
 
 
 
 
 
 
 
This work builds on the work of Pendrill and Persson (2019)21, used in the impact assessment 
of the EUDR, by applying a new comprehensive integrated modelling framework (DeDuCE) 
combining  spatial  tree-cover  loss  data,  statistical  land-use  data,  and  carbon  stock  maps  to 
directly attribute deforestation and its emissions to specific commodities. 

National production statistics for the commodities are extracted from FAOSTAT, the statistical 
database of the Food and Agriculture Organization of the United Nations22. As the reporting 
categories in the FAOSTAT and DeDuCE databases are not identical, a mapping was conducted 
between  the  commodities  in  DeDuCE  and  FAOSTAT  prior  to  calculating  the  deforestation 
intensity ratios for each relevant commodity (see Table 4). 

Table 4: Mapping between the commodities regulated under the EUDR and reporting categories in the DeDuCE and 
FAOSTAT databases 

EUDR commodity 

DeDuCe 

FAOSTAT 

Cattle 

Cattle meat 

Meat of cattle with bone, fresh or chilled 

Cocoa 

Coffee 

Oil palm 

Rubber 

Soya 

Wood 

Leather 

Cocoa beans 

Coffee, green 

Oil palm fruit 

Edible offal of cattle, fresh, chilled or frozen 

Cattle fat, unrendered 

Raw hides and skins of cattle 

Cocoa beans 

Coffee green 

Oil palm fruit 

Natural rubber in primary 
forms 

Natural rubber in primary forms 

Soya beans 

Soya beans 

Forest plantation 

Sawlogs and veneer logs, non-coniferous 
and non-coniferous 

Pulpwood, round and split, coniferous and 
non-coniferous 

Other industrial roundwood, coniferous and 
non-coniferous 

21 Pendrill, F., Persson, U. M., Godar, J., & Kastner, T. (2019). Deforestation displaced: trade in forest-risk 
commodities and the prospects for a global forest transition. Environmental Research Letters, 14(5), 055003. 
(https://iopscience.iop.org/article/10.1088/1748-9326/ab0d41) 
22 FAOSTAT – Food and Agriculture Organization of the United Nations (https://www.fao.org/faostat) 

30 

 
 
 
 
 
 
 
Whilst  this  deforestation  intensity  factor  can  be  safely  applied  when  computing  the 
deforestation  impact  of  raw  commodities,  it  is  only  valid  for  derived  products  under  the 
assumption that the country of origin is the same as the country of production. In reality, supply 
chains are often more complex: raw commodities are frequently traded and refined into derived 
products in a different country, resulting in a divergence between the country of production of 
the raw commodity and the country of o igin of the product. 

To account  for this and ensure that the deforestation impact  in  the country of production is 
appropriately reflected, even when the product passes through a third country for processing, a 
separate deforestation intensity factor is computed for derived products. This derived-product 
intensity  factor  Iderived  reflects  the  weighted  deforestation  per  unit  of  product  volume, 
combining the domestic deforestation occurring in the country where the product is processed, 
the imported deforestation embodied in the raw commodities sourced Vin from other countries, 
and  exported  deforestation  associated  with  raw  commodities  exported  Vout  for  further 
processing: 

𝐼𝑑𝑒𝑟𝑖𝑣𝑒𝑑,𝑟,𝑐 =

𝐹𝑐,𝑟 + ∑ (𝐼𝑟𝑎𝑤,𝑟,𝑏 ∙ 𝑉𝑖𝑛,𝑐,𝑏 − 𝐼𝑟𝑎𝑤,𝑟,𝑐 ∙ 𝑉𝑜𝑢𝑡,𝑐,𝑏)
𝑏
𝑄𝑐,𝑟 + ∑ (𝑉𝑖𝑛,𝑐,𝑏 − 𝑉𝑜𝑢𝑡,𝑐,𝑏)

𝑏

The volume of imports and exports is adopted from FAOSTAT’s detailed trade database, which 
provides country-level bilateral trade flows by commodity. The database compiles officially 
reported  national  trade  statistics  and  harmonises  them  using  internationally  comparable 
commodity classifications, ensuring consistency across reporting countries and over time. For 
leather  products,  limited  statistics  are  available  in  FAOSTAT.  Therefore,  bilateral  trade 
statistics from UN Comtrade were used to capture leather-related trade flows. 

Illustrative example of the intensity factor for derived cocoa products from Switzerland 

Consider derived cocoa products, such as chocolate, produced in Switzerland, a country 
that  does  not  cultivate  cocoa  domestically. All  cocoa  used  is  imported,  hence  the  entire 
deforestation  footprint  of  its  derived  cocoa  products  originates  from  the  producing 
countries. Assume for instance that 70% of the cocoa originates from Côte d’Ivoire and 
30%  from  Ghana  and  that  the  deforestation  intensities  of  cocoa  production  in  these 
countries are 2.5 ha per tonne for Côte d’Ivoire and 1.8 ha per tonne for Ghana. Based on 
these values, the weighted deforestation intensity of the cocoa embedded in Swiss chocolate 
is approximately 2.29 hectares per tonne of cocoa. 

31 

 
 
 
 
 
 
 
 
 
 
 
A similar approach can be applied to estimate the embedded greenhouse gas (GHG) emissions 
associated  with  the  import  of  raw  commodities  and  derived  products.  Just  as  deforestation 
intensities are expressed per unit of commodity produced in each country, emissions intensities 
can be calculated based on the total GHG emissions from and land cover or land-use change, 
divided by the total volume of the commodity produced. 

The computed embedded deforestation and emissions on a product level are converted into an 
environmental  benefit,  i.e.,  the  environmental  benefits  quantify  the  economic  value  of 
prevented forest loss and associated GHG emissions: 

𝐵𝑝 = 𝐷𝑝 ∙ 𝑃𝐸𝑇𝑆 + 𝐸𝑝 ∙ 𝑃𝑒𝑐𝑜𝑠𝑦𝑠𝑡𝑒𝑚 

The  economic  value  of  prevented  forest  loss  Bp  is  calculated  as  the  product  of  the  avoided 
deforestation (in hectares) and the monetary value of ecosystem services provided per hectare 
of  forest  Pecosystem.  The  value  of  ecosystem  services  varies  depending  on  several  factors, 
including  forest  type  (e.g.,  temperate  versus  tropical),  climatic  conditions,  cultural  and 
recreational use, and surrounding land-use patterns. For the purpose of this study, a uniform 
global value is applied across all forest types. An ecosystem services value23, of €10,000 per 
hectare per year is adopted from Brander et al. (2024)24 as a representative value for tropical, 
subtropical and temperature forests, while a carbon price of €100 per ton of CO₂ is adopted in 
line with the initial impact assessment25.   

The methodology incorporates only a cost per hectare of forest loss and, due to data limitations, 
does  not  quantify  the  cost  of  forest  degradation.  While  this  is  not  problematic  for  most 
commodities, where production is primarily associated with land cover change, it constitutes a 
limitation for the impact assessment of wood products, which are mainly associated with forest 
degradation  rather  than  land  use  change. As  a  result,  the  environmental  benefits  of  wood-
derived products are likely to be significantly underestimated, making this analysis insufficient 
fit to draw robust conclusions regarding wood derivatives 

23 An ecosystem service value is the quantified benefit that humans derive from natural ecosystems, such as 
clean water, food production, climate regulation, recreation, and the maintenance of genetic resources that 
support crop improvement, medicine development, and ecosystem resilience. 
24 Brander, L. M., De Groot, R., Schägner, J. P., Guisado-Goñi, V., Van't Hoff, V., Solomonides, S., ... & 
Thomas, R. (2024). Economic values for ecosystem services: A global synthesis and way forward. Ecosystem 
Services, 66, 101606. 
25 Commission Staff Working Document – Impact Assessment (2021) 

32 

 
 
 
 
 
 
 
Compliance costs 

Estimated  recurring  compliance  costs  for  operators  under  the  obligations  stipulated  in  the 
EUDR are calculated, in line with the methodology applied in the review study quantifying 
environmental  reporting  costs  across  the  EU  environmental  acquis26,  as  the  product  of  the 
number of unique operators placing a derived product p in a given year on the EU27 market 
with the compliance cost per operator: 

𝐶𝑝 = 𝑁𝑝 ∙ 𝐶𝑜𝑝𝑒𝑟𝑎𝑡𝑜𝑟,𝑝 

The number of unique operators Np for product p is derived from DG TAXUD’s Surveillance 
database. This database collects detailed customs data on goods imported into and exported 
from the European Union, based on customs declarations submitted by economic operators and 
national customs authorities.  

Since  operators  frequently  import  multiple  products  within  the  same  commodity  group, 
compliance  activities  (e.g.,  IT  system  maintenance,  due  diligence  systems,  and  reporting 
procedures) generate economies of scale. To avoid overestimating total compliance costs, the 
number of unique operators per product is therefore adjusted. Specifically, the count is scaled 
by the ratio between the sum of unique operators across all products within a commodity group 
and the total  number of unique importers for that commodity. This adjustment accounts for 
overlaps  between  product-level  importer  populations  and  reflects  cost  synergies  when 
operators handle multiple related products. 

For importing operators, the calculations apply the same unit compliance cost assumptions as 
used in the initial impact assessment. The impact assessment estimated annual due diligence 
compliance costs per company at €1,000 in the low scenario, €10,000 in the central scenario, 
and €15,000 in  a high  scenario when sourcing  from standard- or high-risk countries27. This 
study,  in  line  with  the  aforementioned  study,  focuses  exclusively  on  the  central  estimate  of 
€10,000 per company. For sourcing from low-risk countries, the compliance cost per company 
is assumed to be 50% of the standard cost, reflecting the reduced due diligence obligations. 
Companies  sourcing  exclusively  from  low-risk  countries  are  not  required  to  conduct  a  risk 
assessment  or  implement  a  risk  mitigation  plan,  thereby  lowering  administrative  and 
compliance burdens. The average recurring compliance cost per unique operator Coperator,p is 
for each product p calculated as the weighted average compliance costs, based on the value 
share of product volumes sourced from high-, standard-, and low-risk countries, in line with 
the country benchmarking set out in the Implementing Regulation published in May 202528. 

26 “Assessment of environmental reporting and the potential for simplification” study commissioned by the 
Commission and expected to be published in late 2026. 
27 Final report – Service contract on EU policy on forest products and deforestation – Task 3: impact assessment 
on demand side measure to address deforestation 
28 Commission Implementing Regulation laying down rules for the application of the Deforestation Regulation 

33 

 
 
 
 
 
 
Illustrative example of compliance cost for cocoa beans  

Cocoa beans imported into the EU originate predominantly from standard-risk countries 
(77%), while the remaining 23% are sourced from low-risk countries. Imports from high-
risk  countries  are  negligible  and  can  therefore  be  disregarded  for  the  purpose  of  this 
calculation. Operators sourcing from standard- or high-risk countries incur an annual due 
diligence  cost  of  €10,000  per  company.  For  sourcing  from  low-risk  countries,  the 
compliance cost is assumed to be half of that amount (€5,000). The average compliance 
cost per unique operator is calculated as a weighted average, using the respective import 
shares as weights. Applying the 77% share at €10,000 and the 23% share at €5,000 results 
in  an  estimated  average  compliance  cost  of  approximately  €8,600  per  cocoa-importing 
operator. With an assumed 1000 operators importing cocoa beans into the EU27, the total 
cost of compliance is €8.6 million per year.  

34 

 
 
ANNEX II – KEY INPUTS AND OUTPUTS 

Commodity 

HS code 

Conversion 
factor (-) 

Commodity 
share (-) 

Import 
(t/yr) 

Cattle 

Coffee 

Oil Palm 

4101 

4104 

4107 

210111 

1516 

1518 

152000 

230660 

2309 

290516 

290517 

290519 

291539 

291615 

29161910 

292119 

29212900 

292390 

292419 

340111 

340120 

382499 

38260010 

390729 

1.00 

2.33 

4.20 

2.60 

1.00 

1.00 

0.86 

1.00 

0.51 

1.07 

1.02 

1.02 

0.84 

0.84 

0.84 

0.96 

0.81 

0.71 

1.08 

0.50 

0.50 

0.97 

0.50 

0.54 

1.00 

1.00 

1.00 

1.00 

1.00 

1.00 

0.81 

1.00 

0.50 

0.99 

0.99 

0.99 

0.82 

0.82 

0.82 

0.93 

0.77 

0.63 

0.87 

0.50 

0.50 

0.97 

0.41 

0.48 

Intra-EU 
trade (t/yr) 
693.62 

79.94 

90.25 

107.90 

581.50 

144.20 

373.45 

47.99 

62.17 

123.55 

1,195.18 

1,948.22 

90.90 

1,754.96 

513.94 

646.33 

501,388 

1,093.50 

159,027 

667,340 

21,239 

206,319 

156.00 

647.00 

178.00 

40.00 

1,728.34 

10,782.57 

1,709,671 

5,010.50 

23.64 

27.26 

53.43 

74.05 

10.46 

36.57 

38.75 

10.38 

49.29 

61.88 

142.03 

79.12 

236.52 

49.93 

310.71 

153.38 

35.50 

0.31 

76.11 

74.83 

98.97 

135.14 

338.14 

255.49 

29,909 

33,830 

91,323 

153,797 

18,391 

21,361 

132,003 

37,225 

146,023 

104.50 

139.00 

416.00 

680.50 

351.50 

65.50 

649.50 

473.00 

933.00 

212,289 

1,529.00 

243,474 

4083.50 

97,701 

3198.00 

819.25 

5,922.74 

2,368,005 

2,656.50 

2,212.70 

7,806.59 

1,721,769 

95.00 

325.91 

1,559.24 

942,662 

471.00 

35 

Import value 
('000 €) 

Importers 
(#) 

Deforestation 
(ha) 

Emissions 
(MtCO2) 

Environmental 
benefits ('000 €/yr) 

Compliance costs 
('000 €/yr) 

283,996 

348.00 

283-565 

0.09-0.17 

11,278-22,557 

1,027,113 

1,291.00 

17,495-34,989 

7.0-14.0 

876,406-1,752,812 

740.63 

3,843.23 

731,531 

4,125.00 

1,726-3,451 

0.74-1.47 

90,784-181,567 

12,157.65 

1,864.88 

143.80 

1,455.39 

90.10 

1,824.37 

923.37 

26.65 

28.39 

65.18 

67.58 

9.88 

31.08 

39.07 

8.99 

36.67 

77.79 

 68.410  

 45.804  

903.44 

1,322.21 

183.87 

0.36 

0.07 

0.71 

0.03 

1.36 

0.42 

0.02 

0.01 

0.02 

0.04 

0.01 

0.03 

0.02 

0.01 

0.02 

0.04 

 0.034  

 0.021  

0.45 

0.54 

0.11 

54,242.89 

8,808.58 

85,711.68 

3,690.90 

154,468.16 

51,422.46 

1,806.46 

1,719.89 

2,229.61 

4,445.81 

658.80 

3,005.78 

2,745.98 

635.05 

2,679.80 

4,565.08 

 €4,035,633  

 €2,533,409  

53,840.70 

66,912.89 

13,026.92 

4,247.09 

543.58 

2,126.22 

629.57 

186.59 

12,377.05 

318.33 

441.85 

1,189.97 

1,651.39 

1,209.12 

304.20 

1,589.96 

1,131.86 

2,203.47 

3,657.57 

 10,905.84  

 9,693.85  

6,482.79 

352.65 

1,122.17 

 
 
 
 
Rubber 

40121100 

40121200 

40121300 

40121900 

40129020 

40129090 

0.04 

0.08 

0.11 

0.04 

0.11 

0.20 

0.14 

0.30 

0.43 

0.14 

0.43 

0.20 

1.21 

11.60 

2.21 

0.76 

56.93 

1.93 

8.62 

85.26 

2.22 

6.44 

54.95 

1.45 

2,974 

30,153 

6,376 

1,612 

133,253 

6,464 

45.00 

88.50 

52.00 

82.00 

473.50 

438.00 

0.14 

5.31 

1.41 

0.12 

26.69 

1.30 

0.00 

0.00 

0.00 

0.00 

0.01 

0.00 

5,554.98 

191,607.60 

51,391.87 

4,285.99 

850,947.16 

42,616.64 

86.79 

170.10 

100.02 

158.59 

913.50 

906.84 

36