EUDR guide for importers
EUDR for soy and animal feed
Soy importers, feed makers and crushers: handle large volumes and international chains with plot-level traceability.
For soy the DDS is filed by the importer who clears the beans, meal or oil. Feed mills buying meal from an importer or an EU crusher do not file a DDS: they are downstream operators. So the burden sits with a few players moving very large volumes.
A 60,000 t vessel of beans from Mato Grosso (Brazil) can load from a silo that takes grain from hundreds of farms. Every one has to be geolocated, and soy farms are usually above 4 ha, so almost everything goes in as polygons. The bottleneck is traceability at the silo, where grain from different farms is mixed in storage.
Products affected
- Soybeans (except for sowing)
- Meal and cake
- Soybean oil
What information you need
- Suppliers and farms of origin
- Geolocation of the plots
- Batches linked to origin
- Evidence of legality
CN codes in scope
| CN code | Product |
|---|---|
| 1201 | Soya beans, whether or not broken (excluding seed for sowing) |
| 1208 10 | Soya bean flour and meal |
| 2304 | Oilcake and other solid residues, whether or not ground or in the form of pellets, resulting from the extraction of soya-bean oil |
| 1507 | Soya-bean oil and its fractions, whether or not refined, but not chemically modified |
Soya flour and meal (1208 10) is also in Annex I. Soy for sowing left the scope. Compound feed containing soy is classified in 2309 and is not in Annex I, although the meal the feed mill buys is.
What to ask your supplier
- A polygon for every farm. Most soy farms exceed 4 ha, so polygons are the norm. In Brazil the farm's CAR (Cadastro Ambiental Rural) is usually the starting point for the perimeter.
- Which farms delivered to the silo and when. The exporter has to link the cargo to farm deliveries. Ask for the delivery list per period and how traced grain is segregated.
- Harvest period. The season the grain comes from. It feeds the production date field and is cross-checked against satellite imagery.
- Legality and land use. Environmental permits for the farm, no embargoes and compliance with the country's forest law. In Brazil soy coexists with the Forest Code, which allows some legal clearing; that does not help under the EUDR if it happened after 2020.
Deadlines
| December 30, 2026 | Large and medium-sized companies importing soy, meal or oil, plus all downstream operators and traders. |
| June 30, 2027 | Micro and small enterprises (and natural persons) importing soy or derivatives. |
Dates under Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650.
Frequently asked questions
I make feed with meal bought at the port. Do I file a DDS?
No, if someone else already imported the meal under a DDS. You are a downstream operator: you keep the reference numbers for 5 years and, if you are not an SME, register in the information system.
My supplier's soy is legal in Brazil. Is that enough?
No. The EUDR asks for two things at once: legal production under the law of the country of origin and land not deforested after 31-12-2020. Clearing authorised in 2022 complies with Brazilian law and still keeps that soy out of the EU market.
Is US soy less paperwork?
The United States is classified low risk. Simplified due diligence applies (Art. 13): no risk assessment or mitigation, but geolocation of the plots is still mandatory.
How do you declare a whole vessel?
It can be split across several DDS if needed, for example by exporter or by silo, each with its polygons. What you cannot do is declare the volume without the geolocation of everything in it.
Are soy lecithin or soy protein in scope?
No. Annex I covers beans (1201), soya flour (1208 10), oil (1507) and oil-cake (2304). Lecithin and protein concentrates are classified under other headings that are not in the annex.