EUDR basics for palm oil importers The EU Deforestation Regulation (EUDR) applies to palm oil and many derived products placed on the EU market or exported from it. Importers, as operators, must ensure that each consignment is deforestation-free and legally produced in the country of origin. This means the palm fruit was not grown on land that was forest before a cut-off date defined by the regulation, and that production complied with relevant local laws.
Core due diligence obligations Before placing products on the market, importers must run a due diligence process. The key steps are:
- Collect information: product description, quantity, supplier details, country of production, and geolocation coordinates for every plot of land that contributed palm fruit.
- Assess risk: evaluate the likelihood that the product is non-compliant, considering factors such as country-level governance, forest cover, presence of indigenous peoples, and corruption indicators.
- Mitigate risk: if risk is not negligible, take additional measures such as independent audits, satellite monitoring checks, or supplier declarations, and document them.
Geolocation is mandatory. For larger plots, polygon data covering the entire production area is required; for smaller plots, a single point may be acceptable depending on plot size thresholds. Importers should collect this data from suppliers, not infer it from mill or district locations.
Practical steps for procurement managers - Map your supply chain early to plot level. Identify all mills, intermediaries, and fresh fruit bunch sources. This often takes longer than expected. - Request geolocation data now, not at shipment time. Suppliers may need months to gather coordinates from thousands of smallholders. - Do not rely only on certifications. RSPO or other schemes can support risk assessment, but EUDR compliance still requires geolocation, legality evidence, and a due diligence statement. - Digitize records. Use traceability software that stores polygons, supplier questionnaires, audit reports, and risk assessments. - Ask suppliers about their own monitoring: satellite-based deforestation alerts, grievance mechanisms, and procedures for non-compliant plots.
What first-time buyers should watch for First-time palm product buyers should be aware that blended or aggregated supply chains require combining geolocation data for all contributing plots. If traceability is weak, consider segregated supply chains or suppliers who can provide complete plot lists. Be prepared for supplier pushback; explain that EUDR due diligence is a legal requirement for market access, not a preference.
Preparing your internal workflow Appoint a responsible person or team. Integrate due diligence into procurement contracts: specify information requirements, deadlines, and consequences for incomplete data. Keep all documentation for the retention period required by the regulation. Prepare a due diligence statement template that references the consignment and confirms compliance.
EUDR compliance is an ongoing process, not a one-off check. Importers who start supply chain mapping early, communicate clearly with suppliers, and use risk-based verification will be better positioned to maintain uninterrupted access to the EU market.