Your raw material is processed into another product: does that count too
You do not import raw cocoa beans, but chocolate bars. Not raw wood, but furniture. Not hides, but shoes. The question that almost always arises: does the European deforestation regulation (EUDR) still apply to me, or only to those who import the unprocessed raw material themselves?
The answer is that the regulation does not stop at the raw material. In addition to coffee, cocoa, wood, rubber, soya, palm oil and beef in their original form, the regulation also lists a series of derived products in which those raw materials are processed. Whether your specific product falls within this depends on a fixed list included in the regulation itself and which works with customs codes (HS codes). Not every product that contains wood, rubber or cocoa somewhere automatically falls under the rules; it concerns the products that are listed by name and customs code on that list.
Why a list of customs codes, and not a general description
The regulation could have said: everything that contains cocoa falls under it. That is not what happened. Instead, a closed list was chosen, linked to the customs codes that are also used for imports and declarations. This has a practical advantage: a customs code is objective, whereas "contains cocoa" raises all sorts of borderline cases. The disadvantage is that you as an importer or trader must check yourself whether the code of your product is on the list, and that is not always the first thing you think about when you declare a shipment.
For some product groups, the picture is clear: wooden furniture and certain wood products are on the list, paper and cardboard also under certain conditions, and chocolate and a number of cocoa-containing products too. For other products, the picture is more nuanced. A product that contains only a small proportion of rubber or leather may fall under a different customs code than the product that is specifically mentioned. This is precisely the type of question where a general impression ("it contains wood, so it must apply") is not sufficient and where the exact code is decisive.
Composite products and multiple raw materials at the same time
It becomes more complicated when a product is made up of more than one of the seven raw materials, or when a raw material is only one of the ingredients alongside other, non-regulated materials. Think of a piece of furniture with a wooden frame and rubber feet, or a chocolate bar with milk, sugar and cocoa. The regulation then looks at the product as it is imported or traded, and at the customs code that applies to it. This means that two products that look comparable to a layperson may be treated differently because they fall under a different code.
For an SME working with multiple product lines, it is therefore useful not to conclude once in general terms "we fall under it" or "we don't", but to check this per product stream and per customs code. This aligns with how the regulation itself is structured: the obligation does not attach to your company as a whole, but to the specific product that you import or place on the market.
What this means in addition to the question of what role you have
Whether a product falls under the regulation is a different question than what role you play in the chain and what obligation goes with it. Both questions must be answered yes before a concrete obligation arises: the product must be on the list, and you must qualify as an importer or trader. determine in a few questions what role applies to your situation provides a first direction in this regard, separate from the product question that is central to this article.
Because the product list with customs codes is technical in nature and varies by commodity group, it is advisable not to rely on hearsay from the sector, but to check the code of your own product against the official text. In the knowledge base with the seven commodities elaborated by topic each commodity is explained which product categories are typically mentioned, with a reference to the location in the regulation itself.
Uncertainty in a borderline case
For products that appear to fall just outside or just within the list, companies often use a combined approach: having their own customs code confirmed by an expert in that field, and placing the outcome alongside the text of the regulation. We structure and validate the data resulting from this in a file per product stream, but the assessment of whether a product legally falls under the regulation remains a question for the competent authority or a lawyer specialised in this subject; we do not make any statement on this ourselves. More on how that file building works and where the underlying information comes from, you can read on the page that explains where our information comes from.
Do you need an initial, non-binding picture of your situation before you investigate further? The free role check and the knowledge base are a logical starting point, and frequently asked borderline cases regarding specific products are collected on the page with frequently asked questions about the EUDR.