Is a product with a non-Annex I commodity outside regulation?
If a product contains a certain amount of a commodity reached by the regulation but it is not in Annex I, it is outside the regulation?
1 Answer
The Regulation applies solely to products listed in Annex I. Items not listed there aren’t bound by Regulation requirements, even if they contain relevant raw materials.
For instance, soap falls outside Regulation scope, even with palm oil content. Similarly, items with non-Annex I HS codes, potentially containing components from regulated materials like leather car seats or natural rubber tires, aren’t subject to Regulation.
Note: The Regulation allows the Commission to amend the list of products and descriptions via a delegated act. It also mandates the Commission to assess the necessity and feasibility of proposing legislative expansion to the European Parliament and Council, encompassing other commodities based on their deforestation and forest degradation impact. The first review of commodity scope will occur within two years of Regulation enforcement.