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European Heat Council · Position 10

Issued 2026-06-25

Under Council authority

EUDR and traceability

The Council’s position on the EU Deforestation Regulation, its current scope, and its indirect reach into small food producers who use listed commodities as secondary inputs.

Part I. Findings

The Council records three conditions affecting how Regulation (EU) 2023/1115 applies to small EU food producers. Each is supported by sources cited at the foot of this Position.

Finding 1. EUDR scope covers seven listed commodities and their derived products; chilli and other spices are not within current scope.

Regulation (EU) 2023/1115 sets due-diligence obligations on the placing on the Union market of cattle, cocoa, coffee, oil palm, rubber, soya, and wood, together with their derived products as listed in Annex I by CN code[1],[7]. The European Commission’s implementation page confirms the seven-commodity scope and the CN-code-driven listing[2]. Independent analysis of Annex I and the Commission’s draft Delegated Acts confirms that chilli, capsicum, and other spices are not in current scope and are not in proposed additions as of June 2026[8].

Finding 2. EUDR application has been postponed by one year and substantially simplified for small operators.

In December 2025 the European Parliament and Council agreed a targeted revision postponing EUDR application by one year and simplifying the obligations on small operators[4],[5]. The principal compliance deadlines now fall on 30 December 2026 for large and medium operators and on 30 June 2027 for natural persons and micro and small enterprises (defined as fewer than 50 employees and under EUR 10 million annual turnover related to in-scope products)[6]. Independent SME-focused compliance guidance records that, under the simplified regime, micro and small primary operators may submit a one-off simplified declaration and, in low-risk countries, may use postal codes in place of precise geolocation coordinates[9].

Finding 3. EUDR reaches small food producers indirectly through listed commodities used as secondary inputs.

Although chilli and other spices are not in scope, several ingredient categories common in EHC-relevant production are in scope: cocoa (used in chocolate-chilli blends and confectionery hot products), coffee (used in coffee-chipotle and similar flavoured sauces), oil palm derivatives (used in some emulsifying and processing inputs), and soya (used in soya-based sauces and condiments)[1],[7]. Independent SME compliance analysis records that a small producer placing a mixed-ingredient product on the EU market still requires due diligence statements covering each in-scope input, regardless of the producer’s own size[9]. The Commission’s implementation page confirms that obligations attach to the placing on the market, not to the size of the producer doing so[2].

Part II. Position

On the basis of these Findings the Council holds that:

  1. The Council supports the environmental objectives of EUDR. Deforestation and forest degradation are global concerns and EU-side instruments addressing import-driven exposure are legitimate.
  2. The Council welcomes the December 2025 postponement and the associated simplifications for small operators. The Commission’s recognition that the original compliance load was disproportionate for small producers is itself evidence that the burden was real.
  3. The Council notes that, while chilli is not directly in scope, small producers using cocoa, coffee, palm oil derivatives, or soya as secondary inputs continue to face EUDR due-diligence obligations on those inputs. Practical guidance from the Commission and Member States addressing mixed-ingredient products at small batch volumes would materially reduce uncertainty for producers in this position.

Part III. Commitments

The Council will:

  1. Track Commission Delegated Acts amending EUDR scope under Annex I, and publish summaries when changes materially affect inputs used by member producers.
  2. Submit comment in EU and Member State consultations on EUDR implementation, particularly where the practical reach of obligations on mixed-ingredient small-batch food production is being settled.
  3. Maintain a member-facing brief summarising EUDR obligations on the in-scope commodities most commonly used in EHC member products, updated when Commission guidance changes.

Revision

This Position will be reviewed annually, or sooner if EUDR compliance deadlines are amended, if Annex I is materially expanded to include spices or other ingredient categories used by members, or if the Commission publishes new SME-specific implementing guidance.

Sources

  1. [1]Regulation (EU) 2023/1115 of the European Parliament and of the Council on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation. https://eur-lex.europa.eu/eli/reg/2023/1115/oj/eng
  2. [2]European Commission, Implementing the EU Deforestation Regulation (EUDR) — official implementation page. https://green-forum.ec.europa.eu/nature-and-biodiversity/deforestation-regulation-implementation_en
  3. [3]World Resources Institute, What Is the EU Deforestation Regulation (EUDR)? — independent explainer. https://www.wri.org/insights/explain-eu-deforestation-regulation
  4. [4]European Parliament, Deforestation law: Parliament adopts changes to postpone and simplify measures, press release 11 December 2025. https://www.europarl.europa.eu/news/en/press-room/20251211IPR32168/deforestation-law-parliament-adopts-changes-to-postpone-and-simplify-measures
  5. [5]Council of the European Union, EU deforestation law: Council and Parliament reach a deal on targeted revision, 4 December 2025. https://www.consilium.europa.eu/en/press/press-releases/2025/12/04/eu-deforestation-law-council-and-parliament-reach-a-deal-on-targeted-revision/
  6. [6]European Commission, Delay until December 2026 and other developments in the implementation of the EUDR Regulation (Access to Markets news). https://trade.ec.europa.eu/access-to-markets/en/news/delay-until-december-2026-and-other-developments-implementation-eudr-regulation
  7. [7]Annex I to Regulation (EU) 2023/1115 — list of CN codes determining product scope, grouped by the seven listed commodities (cattle, cocoa, coffee, oil palm, rubber, soya, wood). https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32023R1115
  8. [8]EU Verify, EUDR Product Scope: New Exemptions, Additions and Removals (independent compliance analysis of Annex I and proposed Delegated Acts). https://euverify.com/resource/eudr-product-scope/
  9. [9]Coolset, EUDR reporting guide for SMEs — independent SME compliance analysis of post-simplification obligations. https://www.coolset.com/academy/eudr-reporting-guide-for-smes

Issued under Council authority. European Heat Council, 2026-06-25.

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