EUDR for palm oil: scope, obligations, and how oil palm plots are screened

Oil palm is one of the seven commodities of Regulation (EU) 2023/1115 (Art. 2(1)). Annex I covers palm oil and palm kernel oil and their fractions, oil-cake, palmitic and stearic acids and industrial fatty acids and alcohols. Delegated Regulation (EU) 2026/2102, in force since 18 September 2026, adds sixteen derivative codes, from hydrogenated fats and glycerol to fatty alcohols, amines and soap, each binding from 30 December 2027 and each only insofar as made using oil palm. It also confines the commodity to Elaeis: babassu oil is not covered.

In scope: Annex I codes for oil palm

Commission Delegated Regulation (EU) 2026/2102, in force since 18 September 2026, adds 16 entries for this commodity, each binding from 30 December 2027.

What the regulation asks of a palm-oil importer

The obligations apply from 30 December 2026. An operator that is a micro or small undertaking, established as such by 31 December 2024, has until 30 June 2027, except for products that were already covered by the EU Timber Regulation. The amendment is Regulation (EU) 2025/2650.

For every consignment the operator must hold, and the statement must rest on:

• The geolocation of every plot of production, as a polygon where the plot is above four hectares, with the production period (Art. 9(1)(d)).
• Evidence that the products are deforestation-free against the 31 December 2020 cutoff (Art. 9(1)(g)) and were produced in accordance with the country's laws in the eight areas of Art. 2(40) (Art. 9(1)(h)).
• The product description with its HS code, the quantity, the country of production, and who supplied and who bought (Art. 9(1)(a) to (f)).
• A risk assessment on that information (Art. 10), and before placing, a due-diligence statement filed in the Information System, whose reference number goes into the customs declaration (Arts. 4, 26 and 33). Everything is kept for five years (Art. 12).

What is specific about oil palm

Two things. The chain is industrial: fruit from estates and smallholders goes to a mill within a day, and the mill's oil is blended with other mills' oil at the refinery, so the plots behind a tanker are the plots behind every mill it draws on, which is why mill lists and estate polygons are the unit of supplier data here. And the plantation is agricultural land: the Commission's FAQ lists oil palm among the plantations outside the definition of forest (Art. 2(6)). The regulation's question is whether forest standing on 31 December 2020 was cleared for a new planting, which is exactly what the loss datasets see well on a plantation frontier.

How Konstata screens oil palm plots

Every plot is screened in more than one pass. The first runs the plot through WHISP, the open analysis developed under FAO's Open Foris, against the EU's own 2020 forest map, the global loss datasets and the alert layers, joined by national records where a country publishes them. Where that finds loss after the cutoff, a second pass locates it on the ground against the forest map, so a reading on land that was not forest in 2020 is not mistaken for the conversion of forest. Where the plot is still unclear, a third pass reads ten years of monthly satellite greenness for the pattern of an established crop. Each plot ends with a verdict and a written reason, never milder than WHISP's own headline, and a plot the data cannot settle is held for a person, with what to check written next to it.

Oil palm's canopy is evergreen, so the greenness pass applies: an established estate holds its reading across the cutoff. A new planting after 2020 on land that was forest reads as loss followed by a rising canopy, and that sequence is what the screening flags. Mill and estate lists import as a batch, and duplicates and overlaps between estates are caught on the way in.

Where to start

• Check your own product codes in the HS code lookup and the Annex I browser under /eudr/tools.
• Settle which date binds you with the company size test, and read the benchmark for each country of production in the country risk tool.
• Open a free Konstata workspace with room for three plots, import them, and read the screening on your own data. No card and no sales call.