Palm Oil and the EUDR: Compliance Guide for EU Importers

Palm oil is the most widely traded vegetable oil on the planet. It's in roughly half of all packaged goods sold in European supermarkets, in cosmetics, in biodiesel, and in an enormous variety of food ingredients. It's also one of the seven commodities at the center of the EUDR, and for importers sourcing from Southeast Asia, it represents one of the more technically demanding compliance problems the regulation creates.

This guide covers what palm oil products are in scope, what makes the supply chain hard to trace, why RSPO certification doesn't solve your EUDR problem, and what you actually need to do before placing palm oil on the EU market.

Palm oil under EUDR: what products are in scope

The EUDR covers palm oil itself and a long list of derived products. If you import crude palm oil (CPO), refined palm oil, or palm kernel oil, you're squarely in scope. The regulation also pulls in:

• Margarine and fat spreads
• Biscuits, wafers, crackers, and other baked goods containing palm oil
• Cosmetics and personal care products (soaps, shampoos, lipstick)
• Biodiesel and biofuel blends
• Industrial oleochemicals derived from palm

The HS codes in Annex I of Regulation (EU) 2023/1115 are the authoritative reference. If you import anything under heading 1511 (palm oil) or 1513 (palm kernel oil), start there and work outward to any processed products that list palm oil derivatives as inputs. The scope is wider than most food ingredient importers expect on first review.

A Dutch food manufacturer importing palm-based emulsifiers for bakery products is an operator under the EUDR, even if they've never thought of themselves as a commodity importer. The Netherlands processes roughly 40% of EU palm oil imports, so a large share of the EU's exposure runs through Dutch ports and logistics infrastructure.

Malaysia and Indonesia: the two dominant origins and their risk classifications

Malaysia and Indonesia together account for approximately 85% of global palm oil production. If you're importing palm oil into the EU, the odds are strong that your supply chain runs through one or both of them.

Under the EUDR country benchmarking system (which the Commission has not yet finalized as of April 2026), both Malaysia and Indonesia are expected to be classified as standard risk. That means you're not in simplified due diligence territory (reserved for low-risk countries), but you're also not in the enhanced scrutiny zone that a high-risk classification would trigger. Standard risk requires full due diligence: geolocation data, a documented risk assessment, and a Due Diligence Statement filed before customs clearance.

The standard risk label doesn't mean the compliance work is straightforward. Both countries have had significant forest conversion activity. Indonesia in particular saw substantial deforestation between 2018 and 2020, a period that sits just before the EUDR's December 31, 2020 cut-off date. Plots brought into palm production during that window may show a clean status under the cut-off, while plots converted in early 2021 would be non-compliant. The cut-off date matters a lot for Indonesian supply chains specifically.

The smallholder complexity: why palm oil is harder to trace than plantation crops

Large plantation operators in Malaysia and Indonesia — companies like Sime Darby and Wilmar — have sophisticated supply chain management systems. They can, in principle, provide plot-level data to their buyers. The problem is that they don't represent the whole market.

Independent smallholders grow roughly 40% of Indonesian palm oil and close to 35% of Malaysian palm oil. These are farms typically ranging from 2 to 10 hectares, operated by families who deliver their fresh fruit bunches to local mills. A single mill may collect from hundreds or thousands of smallholders. The mill has no systematic record of every plot's boundaries. The smallholders themselves have often never had their land surveyed with GPS precision.

This creates a structural data gap. You may know your direct supplier (a trading house or refinery). The refinery knows which mills supplied it. But the mill's records of individual grower plots are often paper-based, incomplete, or non-existent. Tracing back from your shipment to the actual production plots is a multi-tier problem.

For plantations larger than 4 hectares, the EUDR requires polygon coordinates tracing the boundary of the plot. A point coordinate (a single lat/long) is only acceptable for plots of 4 hectares or smaller. Most smallholder farms in Indonesia and Malaysia are right at this threshold, which means you can't assume a single GPS point per supplier is sufficient. Some will need full polygons.

RSPO certification: what it covers and where it falls short for EUDR

The Roundtable on Sustainable Palm Oil (RSPO) is the main voluntary sustainability standard for palm oil. It covers roughly 19% of global palm oil production. If you're already buying RSPO-certified supply, you have some infrastructure to build on. But RSPO certification does not satisfy your EUDR obligation.

Research from Coolset puts RSPO's alignment with EUDR requirements at approximately 37.5%. That number matters because it tells you where the gaps are. RSPO's standard focuses on sustainable land management, labor practices, and chemical use. It does not require plot-level GPS polygon data in WGS84 decimal-degree format at six decimal places. It doesn't run a Sentinel-2 satellite deforestation check against the December 31, 2020 cut-off. It doesn't produce a document formatted for TRACES NT submission.

RSPO certification can support your due diligence process. A certified supplier is more likely to have organized plot records and may already collect some geolocation data. Some RSPO supply chain models, like the Identity Preserved model, offer better traceability than mass balance. But for EUDR compliance, RSPO documentation is supplementary evidence, not a substitute for the geolocation data and deforestation verification the regulation actually requires.

If your procurement team is under the impression that RSPO-certified supply is EUDR-ready, that's a gap worth closing now.

How to collect plot-level coordinates for palm oil supply chains

Collecting polygon coordinates from a dispersed network of smallholders in Sumatra or Sabah is a real logistical challenge. There's no shortcut that makes this easy, but there's a practical sequence that works.

Start with your direct supplier. Ask whether they have GPS data for the plots in their supply chain, and in what format. Large refineries and trading houses increasingly have this data or are actively collecting it. If they supply it in a format other than WGS84 decimal degrees, you'll need to convert it. The six-decimal-place precision requirement (roughly 11 centimetres on the ground) must be met regardless of the source format.

For supply chains that run through mills with incomplete smallholder records, the next step is working with the mill to collect data at the grower level. This can be done with mobile GPS apps or dedicated field data collection tools. Some tools send structured data collection requests directly to farmers via SMS or WhatsApp and guide them through capturing coordinates. This is slow and requires coordination on the ground, but it's the only way to get compliant data from a smallholder-heavy supply chain.

One practical threshold to keep in mind: for any plot larger than 4 hectares, a single GPS point won't satisfy the regulation. You need a closed polygon with matching first and last coordinate pairs. For smallholder plots between 2 and 5 hectares, you'll often need to make a judgment call based on plot size estimates and, where necessary, work with satellite imagery to construct a polygon from visible field boundaries.

What your due diligence looks like for a palm oil shipment

By the time you're ready to submit a Due Diligence Statement for a palm oil shipment, you should have the following documentation in order.

Supply chain mapping: Know your direct supplier and, as far as possible, which mills and farms are in the upstream chain. For a commodity as widely traded as palm oil, complete traceability to every plot isn't always achievable in the first compliance cycle. Document the extent of your mapping and the steps you took to get further upstream.

Geolocation data: Plot coordinates for the production areas in your supply chain, either point coordinates (plots 4 ha or smaller) or polygons (plots larger than 4 ha), in WGS84 decimal degrees with six decimal places. Group the plots by country of production.

Deforestation check: Run each set of coordinates against satellite data to confirm no forest cover loss occurred on or adjacent to those plots after December 31, 2020. For Indonesian origins, pay particular attention to the 2018-2020 period and whether any plots sit near conversion boundaries that are close to the cut-off date. A result from this check needs to be documented and retained for five years.

Risk assessment: A written record of how you assessed the deforestation risk for this shipment, referencing the country classification (standard risk for Malaysia and Indonesia), the geolocation data collected, the satellite check results, and any other factors that affected your assessment.

DDS in TRACES NT: The Due Diligence Statement submitted before the goods are presented to customs. The DDS reference number must appear on your customs declaration. Without it, your shipment can be held at the border.

For more detail on what the DDS must contain field by field, see our EUDR Due Diligence Statement requirements guide.

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