Indonesia, Palm Oil and the EUDR: Why Processed Imports Are the Real Exposure
Most EUDR palm oil advice starts with crude palm oil. Trade figures presented at a major industry conference suggest the bigger exposure for Indonesia sits one step downstream, in processed products. For the general rules, see our palm oil compliance guide; for the Malaysian picture, see MSPO and EUDR. This post looks at Indonesia specifically.
The numbers behind the exposure
At the OFI Commercial/Technical conference in Amsterdam (21 to 23 September 2026, 350+ attendees from 30+ countries), Frans Claassen, managing director of MVO, reported that Indonesia accounted for:
- 10% of EU crude palm oil imports, or 1.68 million tonnes in 2025
- 51% of EU processed palm oil imports, or 1.46 million tonnes
Source: OFI Magazine, 1 October 2026.
The takeaway: a buyer who thinks of Indonesia as a minor crude supplier may be badly underestimating how much of their refined or fractionated product traces back there. Under the EUDR, each of those consignments needs a due diligence statement backed by plot-level geolocation, and mass balance does not satisfy the regulation (see our mass balance guide).
Supply outlook: forecasts, not facts
Speakers at the same event offered projections that matter for contract planning. These are forecasts by the named individuals, not confirmed data:
- Dr Fadhil Hasan of the Indonesian Palm Oil Association predicted a 4 to 5 million tonne production decline in 2027 due to El Niño effects.
- Artem Hammerschmidt of Cefetra Analytics forecast global oils demand rising from 58.9 million tonnes in 2025 to 72.5 million tonnes in 2027.
If both projections hold, buyers face tighter supply just as compliance work peaks. A shortage is exactly when the temptation to accept thin traceability data is strongest.
The smallholder question
Marieke Leegwater, senior policy adviser at Solidaridad, warned that for palm oil, smallholders are being pushed out of value chains to Europe. That echoes the dilemma in our post on keeping smallholders in or cutting them out. Rubén Brunsveld of RSPO named three implementation challenges: data sharing, Annex I revisions and divergent national approaches.
On Annex I, Delegated Regulation (EU) 2026/2102 adds further palm oil derivatives from 30 December 2027, so exposure in processed products will grow (details).
What refiners and buyers should do
- Trace processed volumes back to origin. Map every refined and fractionated product to its mills and plots, not just your crude purchases.
- Quantify Indonesia dependence. Use your own import data. The 51% figure is an EU-wide share, not yours.
- Secure plot-level data early. If supply tightens in 2027, suppliers with clean data will be rationed first to compliant buyers.
- Do not let certificates stand in for data. See certification and EUDR.
- Build contract flexibility. Include data-delivery obligations and substitution rights, see contract clauses.
Large and medium operators must comply from 30 December 2026, micro and small operators from 30 June 2027.
Related reading
EUDR Compliance Costs After Simplification: What the 75% Figure Actually Means for Your Budget
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EUDR Risk Assessment and Mitigation: How to Show 'No Risk or Only Negligible Risk' (Articles 10 and 11)
Between collecting supplier data and filing a due diligence statement sits the step most teams under-document: risk assessment and mitigation. Here is how the two stages work and how to evidence them.
Same Regulation, Different Penalties: How Ireland and Germany Are Implementing the EUDR
The EUDR is an EU regulation, but penalties and enforcement are national. Ireland's draft bill and Germany's implementing act show how exposure can differ depending on where you place goods on the market.