WHAT – Which products fall within the scope?
Two criteria determine whether a product is in scope:
- the seven raw materials listed in the EUDR
- the CN codes of the derived products
Only goods that fall under the specified customs codes are subject to the EUDR.
(CN = Combined Nomenclature)
The 7 raw materials are:
- cattle
- cocoa
- coffee
- palm oil
- natural rubber (=latex)
- soy
- wood
In the PPE sector, cattle (bovine leather) and natural rubber are the most relevant.
However, not everything made from cattle or rubber automatically falls under the EUDR — the CN code is decisive.
Practical examples:
| in scope | not in scope |
| bovine leather (CN ex 4104, ex 4107) | leather gloves/leather shoes |
| goat leather | |
| latex gloves (CN ex 4015) | nitrile gloves/ nitrile soles |
“ex” refers to a specific sub‑part of a CN code.
WHO – Who has obligations under the EUDR?
The EUDR defines three roles: operator, trader and downstream operator .
1. You are an OPERATOR if …
you import or export an EUDR‑listed raw material.
examples
- You import bovine leather from outside the EU (CN ex 4104 / ex 4107)
- You process an EU raw material and export the resulting product outside the EU
consequences
- You have to perform due diligence analysis
- You have to submit a DDS (due diligence statement)
- You carry final responsibility
2. You are TRADER if …
You buy an EUDR-relevant product/raw material within the EU and sell it within the EU without processing.
examples
- You buy latex gloves from an EU supplier and distribute them further (CN ex 4015)
- You hold stock but do not alter the product
consequences
- No DDS
- You have to request information from suppliers
- You have to keep records
3. You are a DOWNSTREAM OPERATOR if …
you process an EUDR-listed raw material within the EU.
examples
- You buy relevant raw materials within the EU and transform them
- You manufacture components, semi‑finished goods, or finished products containing an EU‑origin raw material
consequences
- No DDS (as long as you remain within the EU)
- You have to request documentation
- You have to keep documentation
If you export the finished product later …
→ you become an operator again, provided the product falls under one of the CN codes.
4. You have NO EUDR ROLE if…
you only use the product internally.
examples
- You buy wooden pallets for internal use
- You buy office paper
consequences
- No role
- No obligations
summary
– Import or export = operator
– Resale within the EU = trader
– Processing within the EU = downstream operator
– Internal use = no role
WHERE – How does origin influence obligations?
Artikel 29 of the EUDR (EU 2023/1115) stipulates that countries are to be classified as high risk, standard risk or low risk.
When the Regulation was published, the list did not exist yet, but in the mean time the official country classification has been released during last year.
Only four countries fall into the high risk category
- Belarus,
- Myanmar,
- North Korea
- Russia.
This highest risk category comes with the most extended and detailed due diligence obligations.
Linked to relevant raw materials
- Myanmar is an important producer of natural rubber
- Belarus is a major exporter of wood
- Russia is known of export of wood and cattle (leather).
- North Korea mainly exports wood and soy and plays a smaller role in rubber and cattle.
What does this mean in practice?
Even if your company has no specific role under EUDR, it can still be useful to know whether there are raw materials from any of these four contries in your supply chain.
Why?
- Suppliers higher up the chain face stricter checks and more complex due diligence when sourcing from high-risk countries
- If they swith to other origins or producers because of this, it may affect your deliveries, prices or availability
In short: even without direct EUDR obligations, the country classification can indirectly affect your supply chain.