How EUDR due diligence works for palm oil imports

By Moril Trading Enterprise Inc.. Last updated .

Crude palm oil placed on the EU market must be deforestation-free after 31 December 2020, produced legally in the country of origin and covered by a due diligence statement filed by the operator. The hard part for palm oil is geolocation: you need the plots where the fruit was grown, not only the mill that pressed it. For large and medium operators the rules apply from 30 December 2026.

This guide covers what is different about palm oil. For our own progress, see our EUDR status.

Palm products in scope

Annex I lists oil palm and a range of derived products. The main ones for importers and refiners are:

HS codeProduct
1207 10Palm nuts and kernels
1511Palm oil and its fractions, including crude palm oil (1511 10)
1513 21, 1513 29Palm kernel oil
2306 60Palm kernel cake

A number of oleochemical derivatives, such as certain fatty acids and glycerol, are also listed.

Why palm oil traceability is harder than it looks

A mill can process fresh fruit bunches from its own estate, from outgrowers and from independent smallholders who sell through dealers. A single tank of CPO may therefore contain oil from hundreds or thousands of plots.

The EUDR does not accept "traceable to mill" as enough. The due diligence statement needs the geolocation of the plots of land where the fruit was produced. Mill coordinates alone do not meet the requirement.

The due diligence steps for palm oil

Collect information

For each consignment you need the product description, HS code and quantity, Liberia as country of production, the production period, supplier details, and the geolocation of every plot that supplied fruit. Plots over 4 hectares need polygons. Smaller plots can be a single point with at least six decimal places. Our guide to geolocation and traceability data covers formats.

You also need evidence of legal production: land use rights, environmental permits, labour and human rights, and tax and anti-corruption rules in the country of production.

Assess the risk

Key risk factors for palm oil are:

  • Fruit from unknown sources entering the mill through dealers
  • Mixing of traced and untraced oil in mill or port storage
  • Recent planting on land that was forest in 2020
  • Land conflicts where customary land rights are disputed

Mitigate

Mitigation can include mapping and registering suppliers, excluding fruit from unmapped plots, satellite monitoring, independent verification and physical segregation of EU-bound oil. If the risk cannot be made negligible, the oil cannot go to the EU.

Segregation: the practical test

The simplest question to ask a palm oil seller is: how is the oil for my contract kept separate? If traced and untraced oil share a tank at the mill or the port, the geolocation in your statement no longer describes the oil you bought.

Flexitank shipments help here, because each container is filled from a known tank at a known time. Ask for the tank and fill records to be linked to the data package.

Certification and the EUDR

RSPO or other certification can support your risk assessment, but it does not replace EUDR due diligence. Certification schemes have different cut-off dates and may use mass balance, which mixes certified and uncertified oil. The EUDR requires that the actual oil comes from compliant plots. Treat certification as one input.

What to ask your palm oil supplier

  • Is the geolocation at plot level for all fruit, including smallholder and dealer fruit?
  • Has each plot been checked against forest cover at 31 December 2020?
  • How is the oil kept separate from untraced oil?
  • What legality evidence comes with the shipment?
  • Will the data match the bill of lading, invoice and tank or flexitank numbers?

Refiners new to West African supply can also read Liberian palm oil for refiners.

Dates and records

The EUDR applies to large and medium operators from 30 December 2026, and to micro and small operators from 30 June 2027. Keep due diligence records for five years. Our EUDR timeline is updated when dates or rules change.

Frequently asked questions

Is mill-level traceability enough for the EUDR?

No. The due diligence statement needs the geolocation of the plots where the fruit was grown, not only the location of the mill.

Does RSPO certification mean palm oil is EUDR compliant?

Not on its own. Certification can support a risk assessment, but the EUDR requires plot geolocation and legality evidence for the actual oil supplied.

Which palm products are covered by the EUDR?

Palm nuts and kernels, palm oil, palm kernel oil, palm kernel cake and a number of oleochemical derivatives listed in Annex I.

When does the EUDR apply to palm oil imports?

From 30 December 2026 for large and medium operators, and from 30 June 2027 for micro and small operators.

Why does segregation matter?

If traced and untraced oil are mixed in storage, the geolocation in the statement no longer describes the oil shipped.

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