The EUDR for palm oil: what importers, refiners, oleochemicals and food manufacturers have to do now and from 2027

In brief

• Two stages. Twelve entries apply from 30 December 2026, sixteen more only from 30 December 2027, among them soaps, chemically defined fatty alcohols, amines and polyethers.
• New substances from 2027. The second stage adds soaps, further oleochemicals such as fatty alcohols, amines and quaternary ammonium compounds, and polyethers. Detergent, cleaning product and cosmetics manufacturers are affected to the extent they import these substances or make soap; detergents and cosmetics themselves are not in Annex I.
• Note 2 decides. Only what comes from the oil palm Elaeis is covered. Babassu oil sits in the same subheadings as palm kernel oil and falls outside.
• The CN code beats the commodity share. Margarine made from palm oil is not covered, because 1517 is not in Annex I.
• Every new CN code counts. Under FAQ 3.1.1 as revised in August 2026, the refinery is already a downstream operator, because crude oil (1511 10) becomes refined oil (1511 90).
• Standard risk at the main origins. Indonesia and Malaysia require full due diligence with risk assessment and mitigation.
• Certification is not enough. No RSPO model replaces due diligence. Any mixing with goods of unknown origin is prohibited; what counts is geodata of all plots and a segregated flow of goods.

Which entries are covered

Applies from 30 December 2026:

Applies from 30 December 2027:

The second table is the real shock. A detergent manufacturer importing quaternary ammonium compounds or fatty amines itself becomes an operator for that import from 30 December 2027, with the same obligations as a palm oil importer from 30 December 2026. Buying them in the EU and making detergents of heading 3402 leaves it without a role for the detergent; making soap makes it a downstream operator. There are a good fifteen months between publication of the Delegated Regulation on 17 September 2026 and application, and collecting data in oleochemicals is harder than in commodity trading, because several chemical steps sit between mill and surfactant.

Medicinal products are excluded. For ex 2905 45, ex 2915 70, ex 2915 90, ex 3823 11 00 and ex 3823 12 00 and for the new entries ex 1516 20, ex 2905 17 00, ex 2921 19, ex 2923 90 00, ex 2924 19 00, ex 3401 11 00, ex 3824 99 and ex 3907 29, products used in the manufacture of human or veterinary medicinal products are excluded. The customs declaration uses code Y191 for them.

Not covered are margarine and similar edible fats of heading 1517, bakery products of heading 1905, candles, biodiesel as a fuel of heading 3826, compound feed of heading 2309 and everything whose CN code is not in Annex I. Chocolate (1806) is covered, but as a cocoa product, not because of the palm fat. The Commission names margarine made from palm oil expressly as an example of a product outside the scope.

The note 2 trap

All palm entries carry an "ex" and the reservation in note 2: only what comes from the oil palm of the genus Elaeis is covered. For 1511, 1513 21, 1513 29, 1518 00 and 3823 19, waste within the meaning of the Waste Framework Directive is also excluded (customs code Y133). Three cases cause work in practice.

Subheadings 1513 21 and 1513 29 carry two commodities. They cover palm kernel oil and babassu oil. Babassu comes from a different palm and is not covered. Anyone importing babassu oil declares it under the same CN code, states with TARIC document code Y129 that it is not covered by the Regulation, and needs evidence that it contains no palm kernel oil.

Glycerol and fatty acids can come from many sources. CN codes 2905 45, 2915 70 and 3823 cover products regardless of feedstock. Annex I limits them to oil palm through the "ex" and the words "that have been synthesised using oil palm"; note 2 then restricts oil palm to the genus Elaeis. Coconut, rapeseed, soya and animal fats yield the same chemicals. Without a supplier statement about the feedstock, neither coverage nor exemption can be evidenced.

The catch-all headings are risk and opportunity at once. 3824 99 and 3907 29 from 2027 are broad residual headings. Here the link to the oil palm becomes the main question, and here it is decided whether a chemical company has to check twenty articles or two thousand.

In practice the scope assessment runs in two steps: first the CN code against Annex I, then the feedstock question for each hit. Both belong in the file, including the negative decisions. How to do that systematically is covered in EUDR Annex I and CN codes.

The CN rule in the palm chain

Whether processing creates a new product is decided, under FAQ 3.1.1 as revised in August 2026, by the full CN code: any change of the commodity code in the Combined Nomenclature makes the processor a downstream operator, provided the new product is listed in Annex I. The earlier version had counted only the digits listed in Annex I. Only reselling with an unchanged CN code makes you a trader. Six typical steps:

Refining changes the CN code. Crude palm oil (1511 10) becomes refined palm oil (1511 90). Refining crude oil bought in the EU and selling it therefore makes you a downstream operator, even though the four-digit heading 1511 stays the same. Fractionation into stearin and olein can change the CN code as well; what counts is the eight-digit classification in the tariff.

Palm kernels become palm kernel oil: 1207 10 to 1513. The CN code changes, so the crusher is a downstream operator for the oil.

Palm oil becomes hardened fat: 1511 to 1516 20. A change of CN code and therefore a downstream role, but only from 30 December 2027, when 1516 20 becomes covered.

Palm oil becomes soap: 1511 to 3401 11 00 or 3401 20. Downstream as well, from 30 December 2027. Other soap bars of subheading 3401 19 00 and liquid skin-washing products of subheading 3401 30 are not in Annex I.

Palm oil becomes margarine: 1511 to 1517. The product is not in Annex I. The manufacturer has no obligations for the margarine. For the purchased palm oil: importing it makes you an operator; buying it in the EU leaves you a customer without a role.

Fatty acids become surfactants: 3823 to 2921 or 3402. The first case is downstream from 2027, the second leaves the scope entirely, because 3402 is not in Annex I.

The roles along the chain

The importer is the operator. Anyone importing crude or refined palm oil, palm kernel oil, expeller or fatty acids submits the due diligence statement before release for free circulation and enters the reference number with document code C716 in the customs declaration. That also applies to processors importing solely for their own production.

Refining and fractionation are downstream. Refining crude palm oil bought in the EU changes the CN code and, under FAQ 3.1.1, makes you a downstream operator. Only reselling palm oil with an unchanged CN code makes you a trader. The obligations are equally slim for both roles: keep suppliers and customers that are themselves traders or downstream operators for five years, plus the reference numbers where the supplier is an operator. Non-SMEs also register in the information system and verify in the case of substantiated concerns.

Oleochemicals are usually downstream, food usually has no role. As soon as the CN code changes and the new product is listed in Annex I, the customer becomes a downstream operator. Food manufacturers, by contrast, mostly make products outside Annex I, such as margarine or bakery products, and have no role for them. They have obligations as importers and, from 30 December 2027, for hydrogenated or inter-esterified palm fats (1516 20). From 2027 the downstream role covers most of oleochemicals: soaps, fatty alcohols, amines, esters, polyethers.

The feed industry hangs on 2306 60 00. Palm kernel expeller is covered from 30 December 2026. Importing it makes you an operator. Buying it in the EU and processing it into compound feed of heading 2309 produces an uncovered product, so there is no role for it.

Nobody is a trader when exporting. Exporting goods bought in the EU makes you a downstream operator. The TARIC revision of 23 September 2026 provides code Y196 for non-SMEs and Y188 for SMEs; a reference number does not belong in the export declaration. The detail is in the glossary of EUDR TARIC codes and in the EUDR at export and re-import.

Certification is not a substitute

Hardly any commodity is as heavily certified as palm oil. That leads to a widespread misunderstanding: buying RSPO-certified material is said to make you EUDR-compliant automatically. It does not, for two reasons.

First, the role of certification. Under FAQ 5.7, certification schemes can support the risk assessment to the extent the certification covers the information the Regulation requires. Due diligence stays with the operator, who remains liable for any breach. A certificate is a building block of the risk assessment, not a replacement for geodata, statement and evidence of legality.

Second, the supply chain model. RSPO has four models. Identity Preserved and Segregated keep certified material physically separate. Mass Balance mixes certified and non-certified material and balances the volumes on paper. RSPO Credits, formerly Book and Claim, trades certificates only, without physical linkage.

The EUDR turns on the physical flow of goods. Under FAQ 1.4, mass balance models that mix deforestation-free goods with goods of unknown origin or non-deforestation-free goods at any stage are not allowed; full identity preservation is not required. What matters is therefore not whether goods are certified, but whether every volume can be traced back to its plots. If part of a batch is non-compliant and can no longer be separated, the whole batch cannot be placed on the market.

Anyone buying on mass balance today needs traceability of all volumes back to the plots and a flow of goods without material of unknown origin. Segregated or identity preserved material makes that easier because it already runs separately, but it does not replace geodata. That switch is the longest lead time in the entire project, so it belongs at the start, not at the end.

Geodata from the mill chain

Between the plot and the tank sit collectors, mills and refineries. The mill is the point where traceability either works or ends.

Point or polygon. For plots up to four hectares a point with at least six decimal places is enough; above four hectares a polygon is required. Estates are almost always above, smallholder plots almost always below. In Indonesia a substantial share of fresh fruit bunches comes from smallholders whose plots reach the mill through collectors.

The mill as an aggregation point. Many programmes work with a mill list and a supply shed. That is not enough for the Regulation: what is required are the plots of production, not the place of processing. A mill list is still the right first step, because it shows where the gaps are.

Period of production. Besides the place, the harvest period has to be stated, not the shipping date.

No names in the geodata. Geolocation means coordinates, not the names or ID numbers of farmers.

Responsibility stays with the importer. Whether the data come from a trader, a mill or a service provider makes no difference to responsibility for their accuracy. Contracts should cover audit rights and the consequences of false information.

File size. The geodata in a statement must not exceed 25 megabytes in total. Under FAQ 7.16 that is enough for more than one million points or polygon vertices; it only gets tight for large bulk shipments with many detailed polygons. Points instead of polygons for plots up to four hectares and simplified outlines keep the file small.

Plantation, forest and the cut-off date

Under the Regulation an oil palm plantation is an agricultural plantation and therefore not forest. Both consequences follow: where forest was converted into a plantation after 31 December 2020, that is deforestation, and oil from that land may not enter the EU market. Existing plantations, by contrast, are not forest; replanting on land that was already a plantation before 2021 does not trigger deforestation.

For checking, the Commission provides the global forest cover map for 2020 at ten-metre resolution. It is not legally binding, but it is the obvious first source for testing plots against the cut-off date. For palm oil, with its well documented conversions in the years 2019 to 2021, this is where risk assessments become concrete.

Alongside deforestation-free status comes legality under the law of the country of production (Article 2(40)): land use rights and concessions, environmental protection, third parties' rights, labour rights, human rights protected under international law, the principle of free, prior and informed consent (FPIC), and tax, anti-corruption, trade and customs regulations. In Indonesia the overlap of concessions with forest areas and the legality of individual plots is a known issue that belongs in the risk assessment.

Country risk

Implementing Regulation (EU) 2025/1093 governs. It lists only low-risk and high-risk countries; everything else is standard risk. Inspection rates follow the classification: one per cent for low risk, three per cent for standard risk, nine per cent for high risk.

Because both main origins are standard risk, simplified due diligence is irrelevant for most palm chains. Risk assessment and mitigation are the normal case, with annual review and documentation.

Roadmap

1. Check the article master in two steps: CN code against Annex I, then feedstock for each hit. Flag the entries that only apply from 2027 separately.
2. Obtain supplier declarations stating per article whether oil palm is present. Without that statement neither coverage nor exemption can be evidenced.
3. Determine the role per sourcing route. Look at import, EU purchasing, processing with and without a new CN code, trade and export separately.
4. Clarify the supply chain model. Anyone buying on mass balance should now agree a segregated flow with geodata for all plots with suppliers, for example based on segregated material.
5. Request the mill list and plot data, with a deadline and a format. The template is in the compass.
6. Test plots against the cut-off date, with the 2020 forest cover map as the first source.
7. Prepare customs. C716 and the reference number on import, Y129 for goods from other feedstocks under "ex" entries, Y191 for products used to make medicinal products, Y141 for micro and small enterprises established by 31 December 2024 until 29 June 2027, Y196 or Y188 on export, Y132 for goods produced before 29 June 2023.
8. Put 2027 in the calendar. The sixteen new entries need the same preparation as the first wave, only with more suppliers.

Which role you hold per product is what the EUDR check settles. The overall picture is in the EUDR guide.

Download the compass: EUDR Palm Oil Compass 2026 with both code lists, the roles, the template for requesting data and the country overview.

Frequently asked questions

Is margarine made from palm oil covered?

No. Margarine falls under heading 1517, which is not in Annex I. The Commission names it expressly as an example. The palm oil purchased for it, heading 1511, remains covered.

Is RSPO-certified palm oil enough for the EUDR?

No. Under FAQ 5.7 certification can support the risk assessment to the extent it covers the necessary information. Due diligence stays with the operator. On top of that comes the supply chain model: under FAQ 1.4 any mixing with goods of unknown origin is prohibited, and RSPO Credits have no physical link to the goods. What is needed is the geodata of all plots.

What about babassu oil?

Babassu oil sits in the same subheadings 1513 21 and 1513 29 as palm kernel oil but does not come from the oil palm. Under note 2 it is not covered; the customs declaration carries code Y129. You have to be able to evidence the difference, because the CN code is identical.

From when do the obligations apply to soaps, amines and quaternary ammonium compounds?

From 30 December 2027. Entries 3401 11 00, 3401 20, 2921 19, 2923 90 00 and others were added by Delegated Regulation (EU) 2026/2102 and apply to all size classes only from that date. Detergents and surface-active preparations of heading 3402 remain outside the scope.

We buy palm kernel expeller as feed. Are we affected?

If you import it yourself, yes. Palm kernel expeller of heading 2306 60 00 is covered from 30 December 2026. Importing it makes you an operator. Buying it in the EU and processing it into compound feed of heading 2309 leaves you with no obligations for the feed, because 2309 is not in Annex I.

Does the deferral to June 2027 apply to us?

Only to operators that were established as a natural person, micro or small enterprise on 31 December 2024. Traders and downstream operators of any size are bound from 30 December 2026. On import, code Y141 can reflect the exemption until 29 June 2027.

How deep does traceability have to go?

To the plot of production. A mill list alone is not enough, because the Regulation requires geolocation of the plots where the fruit was grown. The mill list is still the sensible entry point, because it shows where data are missing.

What happens to material already in the tank?

Palm oil released for free circulation before 30 December 2026 needs no due diligence statement. If it was imported by a micro or small enterprise established as such on 31 December 2024, the same applies to imports until 29 June 2027. Traders and downstream operators then only have to be able to show that the goods were placed on the market before that date; for imported goods the customs declaration is sufficient (FAQ 9.1 and 9.2). Goods in a customs warehouse that are only released from 30 December 2026 need a statement. For tank farms with continuous inflow and outflow, clean stock records pay off, because otherwise the batches can no longer be separated.

Sources and status: Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650, Articles 2, 3, 4, 5, 13, 16, 26 and 38, Annex I including note 2 as amended by Delegated Regulation (EU) 2026/2102. Implementing Regulation (EU) 2025/1093 (country benchmarking). Commission guidelines C/2026/3896. Commission FAQ, 5th edition, with the August 2026 update of FAQ 3.1.1. DG TAXUD TARIC document, revision 1 of 23 September 2026. As at 29 September 2026. This article is not legal advice.

Photo: Nazarizal Mohammad via Unsplash.