EUDR and Oil Palm: Covered Products, HS Codes, Supply-Chain Risks and Due Diligence

Yes: oil palm is a relevant commodity of the EU Deforestation Regulation (EUDR, Regulation (EU) 2023/1115), and 12 of its Annex I lines apply from 30 December 2026, the other 16 from 30 December 2027.

Under the EU Deforestation Regulation, oil palm is the commodity and palm oil, kernels, oilcake and oleochemicals are its products.

Which Oil Palm Products Does the EUDR Cover?

Annex I lists oil palm in 28 of its 89 entries since 18 September 2026, when Delegated Regulation (EU) 2026/2102 replaced the 12 palm lines of 2023. No volume threshold applies (FAQ 2.3).

The Five Core Oil Palm Lines in EUDR Annex I: Kernels, Palm Oil, Palm Kernel Oil and Oilcake

Five lines cover the oil palm itself from 30 December 2026: ex 1207 10 00, ex 1511, ex 1513 21, ex 1513 29 and ex 2306 60 00. "Ex" limits each line to oil palm, so babassu oil stays out although heading 1513 names it. The delegated act added the "ex" and the waste exclusions in 2026. All codes are in EUDR Annex I.

From 30 June 2027 for operators that are natural persons or micro or small undertakings established as such by 31 December 2024 (Art. 38(3)). EU imports under the heading (Eurostat Comext), not scope.

Which Palm Oil Derivatives Are Covered, and From When?

Seven derivative lines apply from 30 December 2026 and 16 from 30 December 2027, palm soap included. The same CN code made from tallow, soya, rapeseed, coconut or tall oil is out (Guidance, section 7(b) Q7).

Qualifiers and carve-outs are explained under EUDR and palm oil derivatives.

Waste, By-Products and Palm Kernel Shell Pellets

Five palm lines exclude waste under Article 3(1) of Directive 2008/98/EC, while by-products of processes involving non-waste material stay covered (Annex I, introduction).

• Waste exclusion: ex 1511, ex 1513 21, ex 1513 29, ex 1518 00, ex 3823 19.
• PFAD and POME oil: waste or by-product status follows Directive 2008/98/EC; no Commission EUDR text addresses it.
• Kernel shell and empty fruit bunch pellets: covered under HS 2306 60 where classified as solid residue by-products of oil extraction, out if made entirely from waste (Guidance, section 7(b) Q4, non-binding).

Further EUDR exemptions are listed under EUDR exemptions.

Which Palm Products Are Not Covered?

Not listed means not covered: fresh fruit bunches, babassu oil, margarine, coconut oil and biodiesel need no palm due diligence; chocolate needs cocoa due diligence only.

EUDR Timeline for Oil Palm: When Do the Obligations Apply?

The 12 original lines apply from 30 December 2026, and from 30 June 2027 for operators that are natural persons or micro or small undertakings established as such by 31 December 2024 (Article 38(3)); the 16 added lines apply from 30 December 2027.

Every other date sits on the EUDR timeline.

Is Palm Oil Produced Before 29 June 2023 Covered?

No: palm products produced before 29 June 2023 are outside (Article 1(2)), a limit distinct from the 31 December 2020 cut-off. Products already on the market are covered under EUDR transitional stock.

Who Carries Which EUDR Role and Obligation in the Palm Oil Supply Chain?

Only the operator that first places or exports palm products does due diligence and files a statement; refiners and distributors are downstream operators or traders (Article 5).

The same tests define all EUDR roles.

Importers of Crude Palm Oil, Kernels and Oilcake: Operators

The EU company releasing crude palm oil, kernels or oilcake for free circulation is the operator (Article 2(15)). EU exporters of palm products are operators too, as set out for EUDR operators.

Are Palm Oil Refiners Downstream Operators?

Yes, if every input is covered: refining crude palm oil (1511 10) covered by a statement into refined oil (1511 90) or fatty acids makes a downstream operator (Article 2(15b); Guidance, section 9). An uncovered input makes the refiner the operator for that input. This non-binding Commission view (Article 15(5)) is explained for downstream operators under the EUDR.

Traders and Distributors of Palm Products

A distributor reselling placed palm products unchanged is a trader (Article 2(17)) and files no statement. Under Article 5 a non-SME trader registers, as set out for EUDR traders.

Can Palm Smallholders Use the Simplified Declaration?

No, not in Indonesia or Malaysia: the micro or small primary operator regime (Article 4a) needs a low-risk country, and both are standard risk. In Malaysia, MSPO also means Malaysian Sustainable Palm Oil certification, not this role. The regime is set out for EUDR micro or small primary operators.

How Does EUDR Country Benchmarking Apply to Palm Oil Origins?

The main palm origins are standard risk under Implementing Regulation (EU) 2025/1093 (140 low-risk, 4 high-risk countries): at least 3 % of operators, non-SME downstream operators and non-SME traders are checked yearly (Article 16(8)). About 80 % of 2025 extra-EU import value under heading 1511 came from standard-risk partners (approximation: trade data record the partner country, not the country of production).

Belarus, North Korea, Myanmar and Russia (high risk): at least 9 % of actors and 9 % of quantity (Art. 16(9)). All classes are listed under EUDR country benchmarking.

Refining or Fractionating in Another Country Does Not Change the Origin

The class follows the country of production (Article 2(24)), not customs origin (Article 2(23)): oil refined in a low-risk country from Indonesian fruit stays standard risk. Article 13(3) names such processing as a circumvention risk on which authorities act.

What Does EUDR Due Diligence Require for Palm Oil?

Palm due diligence has 3 steps: information (Article 9), risk assessment against 14 criteria (Article 10(2)) and mitigation (Article 11), under Article 8(2). The system is covered under EUDR due diligence.

EUDR Geolocation of Palm Plantations and Smallholder Plots

Every supplying plot needs geolocation with six decimal digits: a point up to 4 hectares (about 9.88 acres), a polygon above (Article 2(28)). Article 9(1)(d) requires all plots, so mill coordinates are insufficient; a point with a radius is not accepted (FAQ 1.16). Formats are explained under EUDR geolocation; files can be tested with the EUDR GeoJSON checker.

Oil Palm Plantations: What Counts as Deforestation-Free?

Palm oil is deforestation-free when grown on land not deforested after 31 December 2020 (Article 2(13)(a)); an oil palm plantation is an agricultural plantation, not forest (Article 2(6)). The degradation test of Article 2(13)(b) applies to wood only. Terms are defined under EUDR definitions.

Forest planted with oil palm after the cut-off fails: forest means more than 0.5 hectares (about 1.24 acres), trees above 5 metres, canopy above 10 % (Article 2(4)). The test is set out under deforestation-free under the EUDR.

Legality in the Palm-Producing Country

Palm products must meet the relevant legislation of the country of production, 8 headings (Article 2(40)), from land use rights to free, prior and informed consent; forest-related rules count only where directly related to wood harvesting. The EUDR legality requirement sets out all eight.

Segregation at the Mill, Crusher and Refinery: Why Mass Balance Is Not Compliant

Verified oil stays segregated: mass balance is not compliant, full identity preservation not required (FAQ 1.4; Guidance, footnote 18). Segregation holds at each stage.

• Mill: crude palm oil (1511 10), kernels (1207 10).
• Crusher: palm kernel oil (1513 21), oilcake (2306 60).
• Refinery: refined oil (1511 90), fatty acid distillate (3823 19).

Plot links continue under EUDR traceability.

The Due Diligence Statement for Palm Oil

The operator files one statement in the EUDR Information System before placing or export, free of charge (Implementing Regulation (EU) 2024/3084, Article 18(1)). Amendment or withdrawal is possible within 72 hours (Article 5(1) of that regulation). The EUDR due diligence statement follows Annex II; records are kept 5 years (Article 4(3)). Release checks are explained under EUDR at customs.

Can Certification Prove EUDR Compliance for Palm Oil?

No: a certificate is complementary information under Article 10(2)(n) and never replaces due diligence; mass-balance certified oil is not compliant (FAQ 1.4). No "EUDR certificate" and no EU list of approved schemes exist as of 24 October 2026. What schemes prove is set out under certification and the EUDR.

Two schemes used in palm chains have their own pages: RSPO and the EUDR and ISCC and the EUDR.

Find Independent Providers and Suppliers for Palm Oil Under the EUDR

Palm importers, refiners, non-EU mills and exporters can request mapping, risk assessment, audits, software or palm products with EUDR information.

Facts are checked against EUR-Lex and the Commission sources named; see our methodology and fact-checking.

This guide explains the rules; it is not legal advice for an individual case.

How Does Oil Palm Connect to the Other EUDR Commodities, Checks and Dates?

Oil palm is one of 7 relevant commodities and shares its plot rules with the other crops. The EUDR commodities hub compares all seven. Rubber applies from the same 30 December 2026 (EUDR and rubber).

Cocoa shares the smallholder rules (EUDR and cocoa). Coffee also gained a 2027 line (EUDR and coffee).

Wood alone faces the degradation test of Article 2(13)(b) (EUDR and wood).

Why Is Oil Palm One of the Seven Relevant Commodities?

The research behind recital 38 attributed 34.0 % of EU-driven deforestation to oil palm, a historical figure. Marketing claims fall under green-claims rules (greenwashingdirective.com).

Checks and Penalties for Palm Oil Operators

For standard-risk palm origins, authorities check at least 3 % of operators, non-SME downstream operators and non-SME traders yearly (Article 16(8)). Selection rules sit under EUDR checks. For legal persons, the maximum fine must be at least 4 % of total annual Union-wide turnover (Article 25(2)(a)), detailed under EUDR penalties.

Is the EUDR Postponed or Simplified Again?

No further postponement is proposed as of 24 October 2026. The review COM(2026) 191 of 4 May 2026 made no legislative proposal (EUDR simplification). Earlier steps sit under EUDR postponement.