EUDR for palm oil
Importers, refiners and oleochemicals: trace the origin of palm and palm kernel oil and their affected derivatives.
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
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.
CN codes in scope
| CN code | Product |
|---|---|
| 1511 | Palm oil and its fractions |
| 1513 21, 1513 29 | Palm kernel oil and its fractions (1513 21 and 1513 29) |
| 2306 60 | Palm nut or kernel oil-cake (2306 60) |
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.
Check another codeWhat 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
- Large and medium-sized companies importing palm oil, palm kernel oil or Annex I derivatives, plus all downstream operators and traders.
- Micro and small enterprises (and natural persons).
- 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.
Related guides
From origin to customs, without the last manual step.
Sourevo brings together suppliers, plots and batches, prepares the due diligence and submits your statements straight into TRACES.
Try it free for 14 days