EUDR for soya: scope, obligations, and how soya plots are screened

Soya is one of the seven commodities of Regulation (EU) 2023/1115 (Art. 2(1)). Annex I lists soya beans (1201 90 00), soya flour and meal (1208 10), soya-bean oil and its fractions (1507), and oil-cake and other residues (2304). Feed is where most EU soya goes, so feed producers and their importers are the operators. Since 18 September 2026, under Delegated Regulation (EU) 2026/2102, the entry is 1201 90 00: soya beans other than seed for sowing.

In scope: Annex I codes for soya

The same regulation took one entry for this commodity out of Annex I on 18 September 2026. Products under these codes are no longer relevant products.

What the regulation asks of a soya 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 soya

Soya is the annual crop among the seven. A field is bare, planted, green and harvested within one year, so a satellite series that expects a standing canopy reads every field as changing. The plots are also large: a farm in Mato Grosso or the Chaco is thousands of hectares in a few polygons, and the conversion the regulation is written for, forest or savanna woodland cleared for cropping, is exactly the frontier those regions are known for. Bulk soya is blended at the crusher and the port, so the plot list behind a cargo is the union of the farms the elevator bought from.

How Konstata screens soya 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.

For soya the first pass reads the annual-crop verdict as well as the perennial one, and the more cautious of the two stands. The greenness pass built for evergreen crops is not applied, because an annual field is expected to change every year. What settles a soya plot is the forest question at the cutoff: whether the field, or part of it, was forest or other wooded land on 31 December 2020, which the loss datasets and the 2020 forest map answer well at the scale of these polygons.

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.