EUDR and oil palm: what importers must collect
Palm oil and its derivatives, common as an ingredient far from the visible label.
EUDR · Regulation (EU) 2023/1115
Oil palm is one of the seven commodities covered by the EU Deforestation Regulation. Placing oil palm on the EU market needs a Due Diligence Statement filed before customs clearance.
Oil palm is one of the seven commodities covered by the EU Deforestation Regulation, so oil palm and the products derived from it cannot enter the EU market unless it is deforestation-free after 31 December 2020, legally produced in its country of origin, and covered by a Due Diligence Statement. Annex I lists it under 1207 10, 1511, 1513, 2306 60, 2905 45, 2915, 3823.
Is oil palm covered by the EUDR?
Yes. Oil palm is on the list of seven commodities, alongside cattle, cocoa, coffee, oil palm, rubber, soya and wood. Scope extends to the derived products in Annex I, so a finished good containing oil palm can be in scope too. The exact boundary is the CN code: for oil palm the relevant headings are 1207 10, 1511, 1513, 2306 60, 2905 45, 2915, 3823. Several Annex I rows carry an ex prefix, meaning only the described subset of that heading is caught, and the Annex itself is versioned. Article 34 lets the Commission update the codes by delegated act, so check the current text rather than a cached list.
What oil palm importers have to collect
The same three things every covered commodity needs: plot geolocation for the ground it came from, evidence that it was produced legally and is deforestation-free, and a Due Diligence Statement filed before customs. There is no de minimis: the obligation applies whatever the quantity, including where oil palm is a minor ingredient inside a processed product.
Palm-oil derivatives turn up in food, cosmetics, and chemicals, so a product can be in scope without palm oil appearing on the front label. Trace the ingredient list and its CN classification.
What is not in scope for oil palm
The boundary sits mid-chain. Oleochemicals and glycerol are in, but margarine under 1517 and finished cosmetics in chapter 33 are not listed in Annex I, so a palm-derived lipstick is outside scope while the oleochemical it was made from was inside it.
When does this apply, and what next?
From 30 December 2026 for large and medium operators and 30 June 2027 for natural persons and micro and small undertakings established by 31 December 2024. The deadlines page sets out the four separate dates the Regulation keeps and why they are not interchangeable. Start by confirming which oil palm products you handle are in scope, then ask suppliers for geolocation and statement reference numbers now. EUDR for SMEs covers the reliefs for smaller importers, and the EUDR overview walks the full flow.
Sources
Collect the plots once. File every shipment after.
Bindu holds the geolocation, the legality evidence, and the audit trail in one record, and assembles the statement from it when a shipment moves.