EUDR guide for importers
EUDR for palm oil
Importers, refiners and oleochemicals: trace the origin of palm and palm kernel oil and their affected derivatives.
Palm has one step that complicates everything: fresh fruit bunches go from the plantation to the mill, and the crude oil then moves on to refineries and oleochemical plants. The geolocation the EUDR asks for is that of the plantations, not the mill or the refinery.
If a company in Rotterdam imports crude palm oil from Sumatra (Indonesia), it needs to know which plantations supplied the mills that produced its oil. Many mills buy from independent smallholders as well as their own estates, and those smallholders are the ones usually missing from the lists.
Products affected
- Palm oil
- Palm kernel oil
- Industrial and chemical derivatives
What information you need
- Suppliers and plantations of origin
- Geolocation of the plots
- Batches linked to origin
- Evidence of legality
CN codes in scope
| CN code | Product |
|---|---|
| 1207 10 | Palm nuts and kernels |
| 1511 | Palm oil and its fractions, whether or not refined, but not chemically modified |
| 1513 21 | Crude palm kernel and babassu oil and fractions thereof, whether or not refined, but not chemically modified |
| 1513 29 | Palm kernel and babassu oil and their fractions, whether or not refined, but not chemically modified (excluding crude oil) |
| 2306 60 | Oilcake and other solid residues of palm nuts or kernels, resulting from the extraction of palm nut or kernel fats or oils |
Annex I also covers palm nuts and kernels (1207 10) and several oleochemical derivatives (glycerol, fatty acids and fatty alcohols). Delegated Regulation (EU) 2026/2102 added more derivatives, including certain soaps, which apply from 30 December 2027. Check the exact subheading: the rest of 1513 (coconut) and 2306 is not palm.
What to ask your supplier
- Mill list. Which mills produced the oil in your shipment, with their location. It is the first filter but not enough: the mill is not the plot.
- Plantations supplying each mill. Polygons for own estates and for outside growers who delivered fruit. For smallholders under 4 ha, one point per plot.
- Chain of custody model. Ask whether the oil is segregated or mass balance. RSPO Mass Balance does not let you link your oil to specific plots; for the EUDR you need a segregated or identity-preserved model.
- Legality of the concession. Land use rights (in Indonesia, the plantation's HGU licence), environmental permits and labour compliance.
- Production period. Oil palms fruit all year round, so you normally declare a range: the dates the mill received the fruit that went into the oil in your shipment.
Deadlines
| December 30, 2026 | Large and medium-sized companies importing palm oil, palm kernel oil or Annex I derivatives, plus all downstream operators and traders. |
| June 30, 2027 | Micro and small enterprises (and natural persons). |
| December 30, 2027 | Palm derivatives added by Delegated Regulation (EU) 2026/2102 come into scope. |
Dates under Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650.
Frequently asked questions
Is RSPO certification enough?
It helps you gather information, especially under the segregated or identity-preserved models, but it does not replace due diligence or plantation geolocation. With mass balance you cannot link your oil to specific plots.
I buy refined oil in Rotterdam. Do I file a DDS?
If the oil already entered the EU under a DDS, you are a downstream operator and keep the reference numbers. If you buy it in a customs warehouse and clear it yourself, you are the importer and the DDS is yours.
What risk level do Indonesia and Malaysia have?
Both are standard risk under Implementing Regulation (EU) 2025/1093. That means full due diligence, with risk assessment and mitigation.
Is a shampoo with palm derivatives in scope?
It depends on the CN code of what you import. Finished cosmetics are not in Annex I. Some oleochemical derivatives used to make them are, and more come in from 30-12-2027.
What about margarine or biscuits made with palm oil?
Foods made with palm oil are classified under headings that are not in Annex I, so they need no DDS. Whoever imports the oil to make them does.