EUDR by commodity
EUDR for Palm Oil
Oil palm is one of the seven EUDR commodities, so palm oil and many products made from it must be proven deforestation-free and legally produced before sale in or export from the EU. The hard part for palm oil is the long list of derivatives, from food ingredients to oleochemicals, that can hide palm content deep in a product. This page explains what is covered and what to do.
TL;DR
- Oil palm is in scope, covering palm oil and its fractions, palm kernel and a range of palm-based derivatives in Annex I.
- Products must be deforestation-free (no clearing after 31 December 2020) and legally produced, backed by a Due Diligence Statement.
- Deadlines: 30 December 2026 for large and medium companies, 30 June 2027 for micro and small ones.
- The hard part is the many derivatives and oleochemicals where palm content is hard to see and trace.
In scope
What the EUDR covers for palm oil
- Palm oil and its fractions, whether or not refined (heading 1511).
- Palm kernels (heading 1207 99) and palm-kernel or babassu oil where listed (heading 1513).
- Palm-based derivatives such as certain oilcake (2306), glycerol and oleochemicals (for example headings 2905 and 3823), where listed in Annex I.
Annex I lists each product by its CN/HS customs code, so palm content can fall in scope through derivatives and oleochemicals, not just the named oils. Confirm each product by its code.
These products are listed in Annex I of Regulation (EU) 2023/1115 by their CN/HS customs code, so you confirm scope by matching your product code, not the product name alone.
The hard part
The hard part for palm oil
- Derivative traceability: palm appears in a wide range of food ingredients, oleochemicals and other derivatives, so palm content can be buried deep in a product.
- Large, fragmented plantation and smallholder base feeding into mills, with frequent mixing at the mill and refinery.
- Long industrial chains for refined oils and derivatives that pass through many processors before the EU operator.
- Matching geolocation and quantities back to the right plots once oils are blended and refined.
The dual test applies throughout: an in-scope product must be both deforestation-free, meaning no clearing after 31 December 2020, and legally produced. Art. 3
Origins and risk
Where it comes from and the risk tiers
Common origins for palm oil and their current EUDR risk tier. The tier decides how much due diligence applies, with low-risk origins allowing simplified due diligence. Country benchmarking (2025/1093)
- IndonesiaStandard risk
- MalaysiaStandard risk
- ThailandStandard risk
- ColombiaLow risk
- GuatemalaStandard risk
The country tier sets how much due diligence applies. Low-risk origins allow simplified due diligence; standard-risk origins, including the largest palm producers, need the full process. Tiers can change, as the list is reviewed in 2026.
What to do
What to do for palm oil
- Confirm scope by matching your palm products and derivatives against the CN/HS codes in Annex I.
- Establish where palm content sits in each product, including derivatives and oleochemicals, and trace it back through mills to plots.
- Collect geolocation for every plot, plus country of production, quantities and supplier details.
- Check each origin country’s risk tier and run risk assessment and mitigation for standard and high-risk origins.
- File a Due Diligence Statement in the EU Information System and pass the reference number down the chain.
For the full obligations and the due-diligence process, see the EUDR obligations guide, and for collecting data from suppliers see the supplier data guide.
Proposed Annex I changes for palm oil, not yet law
FAQ
Palm Oil and the EUDR: common questions
- Is palm kernel oil covered by the EUDR?
- Palm kernels are in scope under heading 1207 99, and palm-kernel oil is addressed in Annex I where listed under the relevant code. Confirm your specific product by its CN/HS code.
- Are palm-oil derivatives and oleochemicals in scope?
- Several palm-based derivatives, including certain oilcake, glycerol and oleochemicals, are listed in Annex I. Because palm content can be buried in these products, you confirm scope by matching the exact CN/HS code rather than the product name.
- When does the EUDR apply to palm oil?
- Large and medium operators and traders must comply from 30 December 2026, and micro and small enterprises from 30 June 2027, where they were established as micro or small by 31 December 2024.
- Why is palm oil traceability difficult?
- Palm is grown across many plantations and smallholders that feed into mills where lots are mixed, then refined and turned into a wide range of derivatives. Establishing palm content and tracing it back to the right plots through that chain is the main challenge.
- Is palm oil in food products covered?
- The regulated items are the palm oil, palm kernel and palm-based derivatives listed in Annex I by CN/HS code. Whether a particular food product is the regulated item depends on its code, so always check against Annex I.
Get ready for the EUDR
Work through the EUDR Readiness Checklist, then explore the tools and guides built for your role.
This is guidance, not legal advice
Sources
- [1]Regulation (EU) 2023/1115, consolidated text including Annex I (EUR-Lex)retrieved 4 Jun 2026
- [2]European Commission: Regulation on deforestation-free productsretrieved 4 Jun 2026
- [3]European Commission Green Forum: EUDR implementationretrieved 4 Jun 2026
- [4]First country benchmarking list under the EUDR (2025/1093)retrieved 4 Jun 2026
- [5]Council of the EU: targeted revision (second delay and simplification)retrieved 4 Jun 2026
- [6]Commission simplification review of 4 May 2026 (draft Annex I changes)retrieved 4 Jun 2026
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