The European Union Deforestation Regulation (EUDR) has introduced strict new compliance rules for the palm oil industry. With the inclusion of new HSN codes for palm oil derivatives, everyone in the supply chain—from the independent farmer to the large-scale exporter—must adapt to maintain access to the European market.
Here is what the new rules mean for you, answering the most critical unspoken questions at every stage of the supply chain.
FOR THE FARMERS: “WILL I LOSE MY BUYERS IF I CAN’T AFFORD EXPENSIVE MAPPING TECH?”
You do not need to buy expensive software. The responsibility for compliance often falls on the first buyer or cooperative. However, you must be able to provide the geolocation coordinates of your farm. If your plot is larger than 4 hectares, you will need polygon mapping; if it is under 4 hectares, a single GPS point is enough. The key is proving your land was not deforested after December 31, 2020.
FOR THE CRUSHERS: “HOW DO I HANDLE MIXED BATCHES FROM HUNDREDS OF DIFFERENT FARMS?”
Traceability is your biggest hurdle. Under the EUDR, you cannot mix compliant and non-compliant Fresh Fruit Bunches (FFB) if the final product is destined for the EU. You must implement a segregated supply chain or mass balance system that tracks exactly which farms contributed to each batch of Crude Palm Oil (CPO).
FOR THE EXPORTERS: “WHAT EXACTLY CHANGED WITH THE NEW HSN CODES?”
The EU has expanded its scope beyond raw palm oil. You are now responsible for the traceability of downstream derivatives, including:
Partially hydrogenated oils (CN ex 1516 20)
Industrial fatty alcohols (CN ex 3823 70 00)
Soaps and oleochemicals used in cosmetics and lubricants
If your product contains these, you must file a Due Diligence Statement before the shipment leaves the port.
SECURING YOUR SUPPLY CHAIN
The deadline for large operators is December 30, 2026. Whether you are a smallholder cooperative in Kerala or a massive refinery in the UAE, the time to digitize your supply chain is now.
Visit Detroit Consultancy to learn how we can help you map your supply chain and ensure full EUDR compliance before the deadline.