EUDR quanitative and qualitative assessment: the Staff Working Document

EU Commission published the new Staff Working Document ( herainafter also “SWD”) which makes clear that 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 on the relevant commodities which are cattle, cocoa, coffee, oil palm, rubber, soya and wood.

The Staff Working Document reports 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”.

In this perspective, the SWD presents a comprehensive assessment, consisting of:

1. A quantitative as well as a qualitative component, building among others on stakeholders’ feedback concerning the EUDR product scope.
2. Evaluation of 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.

In particular, 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. Below, there are the main categories of commodities.

Firstly, the SWD analizes the suluble coffee (HS 2101 11 00) which  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

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.

Secondly, the 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.

It is interesting to recognize that most palm oil derivatives suggested for inclusion meet the quantitative cost-benefit criteria (See Annex II); 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.

For the frozen 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.

Soap, soap noodles and surfactants are downstream oleochemical products. In particular, 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.

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.

For the 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. In particular, 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

Finally, there are requested changes by stakeholder like: biodiesel, preparations used in animal feed, oilcake and other solid residues of palm nuts or kernels