The EU Deforestation Regulation (EUDR) applies from 30 December 2026 for large and medium operators, and from 30 June 2027 for micro and small ones. It covers cattle, cocoa, coffee, oil palm, rubber, soya and wood, and a long list of derived products. For our markets the practical question is palm: palm oil and products made directly from it, such as PFAD, are in scope, while genuine waste and residue streams such as used cooking oil are not. The cut-off date is 31 December 2020: material from land deforested after that date cannot enter the EU at all, whatever the paperwork says. If you trade palm-derived feedstocks, you need the geolocation of the plots and a due diligence statement in the chain; if you trade UCO or tallow, you mainly need to be able to show the material is what it claims to be.
- 1Origin of the material
- 2Chain of custody
- 3Mass balance bookkeeping
- 4Scheme certificate
- 5Claim on the invoice
A claim is only as good as the weakest box to its left.
The dates, and why they moved twice
The regulation was adopted in 2023 and was originally meant to apply from the end of 2024. It has been postponed twice: first to 30 December 2025, then by a second delay to the dates that now stand. The reason both times was readiness, of the EU's own systems and of operator chains. The dates as they stand now:
- 30 December 2026 -- the EUDR applies to large and medium operators and traders.
- 30 June 2027 -- application for micro and small operators.
- 31 December 2020 -- the deforestation cut-off date. Land deforested after this date produces material that is not deforestation-free, no matter who certified it.
- In May 2026 the Commission published a simplification package easing parts of the compliance burden. The core obligations, geolocation and due diligence, are unchanged.
What is actually in scope for feedstock traders
The EUDR attaches to commodities and to derived products listed by CN code in its annex. For the oils and fats market that creates a line that matters commercially, because two feedstocks that look similar in a tank are treated completely differently.
| Palm oil, palm kernel oil | In scope. Needs plot-level geolocation and a due diligence statement. |
|---|---|
| PFAD and palm-derived acid oils | In scope: produced directly from the regulated commodity. This is the one that surprises people, because the material itself is a processing residue. |
| Soapstock and acid oils from other regulated oils (soy) | In scope where produced from a regulated commodity. |
| Used cooking oil (UCO) | Out of scope. Waste and used products are excluded from the regulation's product scope. |
| Animal fats and tallow (categories 1, 2, 3) | Out of scope. Not derived from a regulated commodity. |
| POME | Out of scope as palm oil mill effluent, a waste stream. The classification paperwork still needs to be watertight, because 'derived from palm' is exactly what a customs officer sees at first glance. |
What in-scope actually requires
In-scope material needs three things, and all three have to come from the supply side, which is why buyers push them down the chain early.
Geolocation: latitude and longitude of every plot the material came from, plus the date or time range of production. Aggregated claims do not satisfy this for plots over four hectares.
A due diligence statement: filed in the EU's TRACES system, referenced down the chain. Whoever places the product on the EU market carries the obligation, and reference numbers follow the cargo.
Country classification: the Commission grades source countries by risk (low, standard, high), which sets how deep the diligence has to go. Simplified checks only exist for low-risk origins.
The enforcement side has teeth: penalties can run to at least 4% of total annual EU turnover for the worst violations, plus confiscation. That is why buyers treat EUDR paperwork as a condition of the deal, not an afterthought.
The trap: material that straddles the line
The commercial risk in our markets is not usually the clearly in-scope palm cargo. It is the stream whose paperwork describes it as a residue while its chemistry says otherwise, or the UCO collector whose intake is not documented well enough to rebut a palm assumption. The May 2026 Commission clarifications confirm the principle: only products produced directly from the regulated commodity fall in scope, which helps genuine waste streams, but the burden of showing that sits with the chain.
Practically: if you sell acid oils, soapstock or PFAD, get the origin and CN story straight before the cargo is nominated, because retrofitting geolocation after a deal is agreed is close to impossible. If you sell UCO or tallow into the same buyers, expect them to ask anyway, and have the intake documentation ready.
Frequently asked questions
Does the EUDR apply to used cooking oil?
No. Waste and used products sit outside the regulation's product scope, so UCO does not need geolocation or a due diligence statement. The practical catch is that buyers and customs see a vegetable-type oil and may ask; documented intake (when it became waste, from what sources) answers that without drama.
Is PFAD in scope of the EUDR?
Yes. PFAD is produced directly from palm oil, which is a regulated commodity, and it is listed among the derived products. Being a processing residue does not take it out of scope. PFAD deals need plot geolocation and a due diligence statement from 30 December 2026.
We are a small company. Do we get the 2027 date?
Company size is measured by the EU's standard definitions (staff headcount, turnover, balance sheet), not by cargo size. A small trader placing in-scope product on the EU market gets 30 June 2027, but the material still has to be deforestation-free against the 2020 cut-off, so the supply-side data cannot wait.
What happens if the paperwork is missing at the border?
In-scope product without a valid due diligence statement reference cannot be placed on the market, and the consequences scale from confiscation to fines of at least 4% of EU turnover for serious breaches. In practice the cargo sits, demurrage runs, and the deal turns into a claims file.
Does ISCC certification cover EUDR?
No, they are separate regimes. An ISCC document says something about sustainability claims and chain of custody; the EUDR due diligence statement is a legal filing with geolocation behind it. Some of the same field data feeds both, which is why buyers like collecting it once, properly.
Market news
Recent headlines from across the feedstock and renewable fuel sector. Nothing specific to this market has come through the wires lately, so this is the wider view. The links go to the publisher; we do not host or edit their reporting, and a headline here is not our endorsement of it. Scroll for more.
- Singapore, Brazil move to build green fuel shipping corridor
- Auramarine builds business on marine fuel flexibility
- Stargate Hydrogen Strengthens Nordic Expansion with Petri Sarnes, Former Siemens Power Sector Director of FinBaltic region
- Econetix Adds New Biochar And Bamboo Project To Its Portfolio
- Open call for the second Circular Economy Awards for the Western Balkan region
- TFG Marine installs ISO-certified mass flow meters on two US Gulf bunker barges
- DNV flags ‘strong summer’ for alternative-fuelled vessel orders
- Everllence launches engine-supported air lubrication tech
- Continental Develops Tyre with More Than 40% Recycled Materials for EU Project
- Evaluating the Health Impact Assessment on the UK’s Tyre Recycling Sector
- Oiltraining’s Visser joins IBIA as new Training & Technical Advisor
- Global hydrogen fuel cell market to reach $13.1 billion by 2031, research finds
- OMV Petrom expands Its green hydrogen production capacity at the Petrobrazi refinery to 55 MW
- Innovation funding awarded for next phase of Northern Gas Networks hydrogen storage project
- Haffner targets deal for 12 biomass-to-hydrogen units in western US
- Alfa Laval selected as technology provider for electrolyzer cooling in one of Europe’s largest renewable hydrogen projects
- ABO Energy and the City of Oulu sign agreement to advance hydrogen plant zoning
- SK Innovation E&S and Deokyang Energen to build five combined hydrogen refueling stations in South Korea
18 headlines, updated automatically. Last refreshed .
Sources and further reading
Primary sources for the rules and figures on this page, so you can check them yourself. Legislation is amended: always read the consolidated text on the date that matters to you.
Who to ask about EUDR
Just ask. Not sure whether your feedstock is in EUDR scope? Send the CN code and the origin paperwork and we will give you a straight read before it becomes a customs problem. You get Bart van den Brug on the other end, same working day, in English or Dutch, and across the team also in French, Portuguese, Polish, Czech and Russian.
On how we work: on the feedstocks and fuels on this site we are a broker. We never take title, we do not trade our own book, and we are paid a commission on business that concludes. Additives are the one exception: those we also buy and sell for our own account, and we say in which capacity we are acting before you commit to anything. Either way you will hear it from us when the answer is no, or when your parcel is not ready for the conversation you want to have. A market read or a second opinion on a specification costs nothing and commits you to nothing.
Happy to look at whatever you have, even if it is half an analysis and a question.
+31 6 115 83 448
bart@sustainablecommodities.eu
Sustainable Commodities 3 B.V., Lemmer, the Netherlands
Ask about EUDR
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Last reviewed 03 September 2026. Regulatory references are given for orientation and are not legal advice: verify against the current Official Journal text before contracting.