What the EUDR covers: the seven commodities, and where coffee products fall

The regulation applies to seven commodities (Art. 2(1)): cattle, cocoa, coffee, oil palm, rubber, soya and wood. But the duty does not attach to the commodity in the abstract; it attaches to the relevant products listed in Annex I by HS code. If your product's code is in Annex I, the regulation applies to it. If not, it does not, even when the product plainly contains one of the seven.

Coffee in Annex I

Coffee sits under HS heading 0901, which covers coffee whether or not roasted or decaffeinated, together with coffee husks and skins. Green coffee (0901 11) and roasted coffee (0901 21) are both in scope. Soluble and instant coffee under heading 2101 is currently outside Annex I, which produces the counter-intuitive result that a jar of instant is out of scope while the beans it was made from were in scope on import.

The proposed changes

A draft Delegated Regulation from the May 2026 package proposes amending Annex I: adding soluble coffee and coffee extracts (ex 2101 11 00) along with palm-oil oleochemicals and certain cattle products, removing cattle hides and leather and most retreaded tyres, and introducing exemptions for samples of negligible value, products used for testing, waste, and second-hand goods.

The draft is not law. The public consultation closed on 1 June 2026 and the act has not been adopted, so the current Annex I remains authoritative. Treat the additions as something to prepare for, not something to comply with yet.

What this means in practice

• Check the HS code of what you actually place on the market, not the commodity it came from.
• If you trade green and roasted coffee, you are in scope today and the deadline that matters is your company-size date.
• If you produce soluble coffee, watch the Delegated Regulation: if adopted as drafted, your input changes from out-of-scope to in-scope with a transition period to plan for.