Does EUDR apply only to raw materials, or also to finished products made from them?

EUDR applies to both raw materials and certain products made from them. The regulation covers specific raw commodities, such as:

1. Cocoa
2. Coffee
3. Rubber
4. Wood
5. Cattle
6. Soya
7. Oil Palm

It then also applies to products made from these raw materials, which the regulation calls “derived products.” Simply put, derived products are finished or semi-finished goods that come from EUDR-listed raw materials. For example:

1. Cocoa → chocolate
2. Coffee beans → roasted coffee
3. Rubber → tyres
4. Wood → furniture
5. Cattle hide → leather

EUDR clearly lists which of these derived products are covered in Annex I of the regulation. Whether a product is in scope depends on its Combined Nomenclature (CN) code, not just on what it looks like or how it is marketed.

This means:

1. A raw material and certain finished products made from it can both be regulated
2. Two similar-looking products may be treated differently if their CN codes differ

To understand the compliance in detail you can go through our EUDR Guide:

EUDR Compliance Guide