EUDR and coconut charcoal: the scope position, the 2025/2650 dates, and what EU importers should prepare
By Mohamad Sinno, Charcoal Expert · Reviewed by Budi Hartanto, shipping specialist · Updated
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EUDR scope for coconut shell charcoal is not settled: heading 4402 is listed in Annex I, and Article 2(2) narrows scope to products made using a relevant commodity
EUDR reaches coconut shell charcoal only if two provisions agree, and they do not. HS heading 4402 sits in Annex I with no qualifier, so a plain reading catches it today; Article 2(2) confines the Regulation to products made using a relevant commodity. As of August 2026, that is unresolved.
This is a position to verify, not a settled fact. The sharpest symptom sits in the filing: Article 9(1)(a) asks a due diligence statement for the species' full scientific name, and a coconut endocarp has none to give. Deforestation is one strand of importing shisha charcoal to Germany; EU customs entry, import VAT and the REACH Annex V position belong to that wider guide.
What Annex I lists, and what Article 2(2) requires
Annex I lists HS 4402 charcoal, shell and nut included under the Wood block with no qualifier, and Article 2 never defines the commodity term that would settle which side a coconut endocarp falls on.
| What Annex I lists | What Article 2(2) requires |
|---|---|
| HS 4402 charcoal, shell and nut included, in the Wood block — no “ex” prefix (Annex I) | Products listed in Annex I “that contain, have been fed with or have been made using relevant commodities” (Art. 2(2)) |
Article 2(1)'s seven commodities are cattle, cocoa, coffee, oil palm, rubber, soya and wood. The shell we carbonise is a coconut endocarp, the stone of a fruit. They pull opposite ways: a reading of the text, not a determination anyone has published.
“Coconut” appears in none of the four EU instruments checked
Coconut appears in none of the four: Regulation (EU) 2023/1115, Regulation (EU) 2025/2650, delegated act C(2026)4920 and its explanatory memorandum, on a case-insensitive full-text search, 11 August 2026. The act's own list of non-timber materials outside the Wood entry names bamboo, rattan, reeds, rushes, osier, raffia, cereal straw and lime bark. Not coconut.
Whether an endocarp is one of the “other materials of woody nature” that list gestures at is left open. The coconut out-of-scope position is held by parts of the market; it is not a finding of this page.
Application dates: 30 December 2026 for all other operators, 30 June 2027 only for natural persons and micro or small undertakings established by 31 December 2024
“SMEs” is the wrong shorthand for the later date. Under Article 38 as replaced by Regulation (EU) 2025/2650, 30 June 2027 is available only to natural persons and to micro or small undertakings established as such by 31 December 2024; medium-sized operators are on 30 December 2026 with everyone else, and they are most of this page's readership.
| Operator category | Applies from | Provision |
|---|---|---|
| All other operators and traders, medium-sized and large included | 30 December 2026 | Art. 38(2), as replaced by Reg. (EU) 2025/2650 Art. 1 point (25); OJ L series 2025/2650, 23.12.2025 |
| Natural persons, and micro or small undertakings established as such by 31 December 2024 | 30 June 2027 | Art. 38(3), same instrument — subject to its opening carve-out, checked below |
These dates have already moved twice; plan against them as a transition period, not a fixed deadline.
Why the June 2027 date survives Article 38(3)'s carve-out for heading 4402
Article 38(3) opens “Except as regards the products covered by the Annex to Regulation (EU) No 995/2010”, so that clause must clear first. We searched the whole instrument for “4402”: zero occurrences, and its Annex steps straight from 4401 to 4403 (checked 12 August 2026). The exception does not bite. It settles nothing about EUDR scope — only which heading sits in which annex.
The “ex 4402” amendment was adopted on 13 July 2026 and is not in force
A Commission delegated act adopted on 13 July 2026 would replace Annex I's plain 4402 entry with “ex 4402”, confining it to products produced using a relevant commodity. It is not in force: the Official Journal has not published it.
| Annex I today | Annex I if the adopted act publishes |
|---|---|
| HS 4402 charcoal, shell and nut included — listed bare, in scope on a plain reading | “ex 4402” — in scope only in so far as produced using a relevant commodity (Annex point (cc); recital 7) |
Status, checked 15 August 2026: the title still reads “COMMISSION DELEGATED REGULATION (EU) …/... of 13.7.2026”; the base Regulation's modifying instruments resolve to five corrigenda plus Regulations 2024/3234 and 2025/2650, without it; and it appears only under internal procedures, as a draft. 13.7.2026 is the adoption date, not a date anything applies from — the act's Article 2 gives entry into force the day after publication. “ex” is no novelty: “ex 4017” already sits in Annex I's Rubber block. Re-run the check on CELEX:32023R1115.
What an EU importer prepares: the due diligence statement sits with the importer as operator, not with the Indonesian exporter
The due diligence statement is the EU importer's filing, not the Indonesian exporter's:
- Collect the Article 9 information, assess the risk, mitigate it — Art. 8(2).
- Record the geolocation of the plots and the production date or time range — Art. 9(1)(d).
- Organise and keep all of it for five years — Art. 9(1).
- Submit the statement before placing or exporting — Art. 4(2) — into the information system the Commission maintains, Art. 33(1).
That makes geolocation data readiness a supplier-relationship question, not something an exporter files. Traders that are not SMEs are treated as operators (Art. 5(1)). We set out the mechanics; the compliance call is not ours to make.
Article 9(1)(a) asks for the species' scientific name, and a coconut endocarp has none to give
Article 9(1)(a) requires, for relevant products that contain or have been made using wood, “the common name of the species and their full scientific name” — a field an operator cannot complete for a coconut endocarp, since Cocos nucifera is a palm and no timber species is involved. That is an observation about a form field, not a legal conclusion about scope.
What the factory issues per shipment today, and what it does not
We issue a defined document set with every shipment, and no document in it is an EUDR compliance record — because no EUDR-specific document exists for this product today:
- PEB export declaration, commercial invoice, packing list, bill of lading.
- Certificate of origin through Indonesia's e-SKA system.
- SDS, dangerous goods declaration with UN-spec packaging documentation, and the SP 978 weathering and packing-temperature statement.
- Per-batch COA, and ISPM-15 pallet marking where wood pallets are used — a treatment mark on the pallet, not a certification we hold.
Origin data is not in that set, and there the honest answer is a gap. We do not today publish plot-level origin records for the shell feedstock — no record type, no geographic resolution, no collection date range — and we will not estimate one. Nor do we publish how many tiers sit between grower and factory gate, or what the first-tier counterparty is. An operator needing either builds it into the supplier traceability pack on their own side, supplier by supplier.
What this page does not settle
This page does not determine whether coconut shell charcoal is within EUDR scope; the readings above are of definitions written for other purposes. Our competent-authority guidance watch, searched 15 August 2026, found nothing resolving it: the Commission's EUDR FAQ (5th iteration, 4 May 2026) mentions heading 4402, charcoal, coconut, shell and nut nowhere, and neither does the EUDR FAQ of the Bundesanstalt für Landwirtschaft und Ernährung, Germany's competent authority (12 August 2026). BLE's own answer to a classification question is to send the reader to German customs for a binding tariff ruling.
The determination belongs to your competent authority and your customs broker; neither the market's yes nor its no is adopted here. We re-check quarterly.
Questions importers ask
What is the HS code for coconut shell charcoal?
Coconut shell charcoal sits in heading 4402 at subheading 4402 20, “Of shell or nut”, and not at 4402 90 — the nomenclature reading on the Commission's TARIC database, checked 11 August 2026. It is that heading, not the feedstock, that puts the product in front of the EUDR Annex I question at all.
Was heading 4402 covered by the old EU Timber Regulation?
No. The Annex to Regulation (EU) No 995/2010 lists 4401 and 4403 and steps straight from one to the other; 4402 appears nowhere in it. Charcoal sat outside the 2010 timber regime and was brought into deforestation due diligence for the first time by the EUDR. Checked 12 August 2026.