EUDR guide for exporters
EUDR guide for palm oil exporters
Under the EU Deforestation Regulation (Regulation (EU) 2023/1115), the company that brings your palm oil into the EU has to collect your plot data before the goods reach customs. This guide sums up what it will ask you for. Print it or save it as a PDF and share it with your team.
Which products are covered
Palm oil and palm kernel oil, palm nuts and kernels (1207 10) and several oleochemical derivatives. Further derivatives, including certain soaps, only from 30 December 2027.
What is specific to palm oil
- The location that counts is that of the plantations, not the mill or the refinery: polygons for estates and one point per smallholder plot of up to 4 ha.
- Buyers ask which mills produced the oil and which plantations, independent smallholders included, delivered fruit to each mill.
- The oil has to be segregated or identity preserved: mass balance does not link the oil to specific plots. Land use rights, such as the HGU licence in Indonesia, support legality.
What a palm oil buyer will ask you for
Mill location
Coordinates of every mill that processed the fruit. Buyers use them as a first filter, but a mill is not a place of production.
Fruit intake records
Which estates, dealers and smallholders delivered fresh fruit bunches to the mill, with dates and weights, for the period the oil was produced.
Estate polygons
The boundary of each own or third-party estate that delivered fruit, as GeoJSON polygons.
Smallholder plots
Name and one point per plot for independent smallholders with plots up to 4 ha, a polygon for larger ones. Fruit bought through dealers needs the same data from the plots behind it.
Chain of custody
How the oil was kept segregated or identity preserved from the mill to the port tank.
Land use rights
Concession or plantation rights, such as the HGU in Indonesia, and environmental permits. Your buyer decides what it needs.
Production period
The dates the mill received the fruit that went into the oil you ship.
Example: crude palm oil from one mill
A mill processes fruit bunches from its own estate and from independent smallholders who deliver through local dealers. It sells crude palm oil to a refinery in the EU, which imports it and files the statement.
For the oil shipped, the mill takes the intake records of the production period and lists every supplier of fruit. The estate goes into the GeoJSON as polygons. Each smallholder plot goes in as a point with its Area, or as a polygon if it is above 4 ha, with the smallholder’s name in ProducerName. The mill coordinates are sent separately, not as a plot.
The oil travels segregated from the oil of other mills. The buyer receives the file, the mill details, the intake period and the land use documents. Fruit from a dealer who cannot say where it came from has to stay out of this oil.
Mistakes that get palm oil data sent back
- Only the mill coordinates, or a radius around the mill, instead of the plantations.
- Smallholders who deliver through dealers left out. They are part of the supply and need their plots.
- Area written in quotes in the GeoJSON (“2.5” instead of 2.5). TRACES does not read it as a number and the area becomes 0.
- Polygons with holes for villages or conservation areas inside the estate. TRACES does not accept holes: split the polygon instead.
Key dates
- 31 December 2020: cut-off date. Land deforested after this date cannot supply the EU market. It does not move with the postponements.
- 30 December 2026: large and medium-sized EU companies must comply, and so must every company for timber products that were under the old EU Timber Regulation.
- 30 June 2027: micro and small EU companies.
Questions from palm oil exporters
We sell palm kernels or palm kernel oil. Is the data the same?
Yes. Kernels and palm kernel oil are in Annex I, and the plots that count are the plantations that delivered the fruit, the same as for crude palm oil.
Indonesia and Malaysia are standard risk. What does that change for us?
Your buyer has to carry out full due diligence: collect the information, assess the risk and mitigate it when it is not negligible. Expect more questions on legality and chain of custody than a buyer sourcing from a low-risk country would ask.
Do glycerol or fatty acids made from palm need plot data?
Several oleochemical derivatives, such as glycerol, fatty acids and fatty alcohols, are in Annex I, and more derivatives come in from 30 December 2027. Check the exact code with your buyer. The plot data still goes back to the plantations.
A smallholder sells fruit to several dealers. Do we map the plot every time?
No. The plot is mapped once. What changes is the delivery record that ties it to each production period. Keep the same plot name or code so it matches across files.
The basics, for every product
Whatever the product, the EU buyer needs the same base data: where each plot is (a point up to 4 ha, a polygon above, six decimals), who produced there and in which country, when it was harvested, and information showing that the land was not deforested after 31 December 2020 and that production followed the law of your country.
How to prepare this data and share it with all your buyers