What EUDR requires for palm oil
In-scope products. EUDR Annex I covers cattle, cocoa, coffee, oil palm, rubber, soya, and wood — plus derived products like leather, chocolate, and palm oil derivatives. Palm Oil falls within scope; HS codes covered for this commodity include 1511.10.00, 1511.90.10, 1511.90.20.
Geolocation requirement. Every plot of land where the palm oil was produced must have GPS coordinates submitted with the Due Diligence Statement. For smallholder origins this is operationally hard — many farms have never been geo-tagged. Aggregators must collect coordinates from every supplier in their chain.
Cut-off date: December 31, 2020. Production on land deforested after that date is non-compliant. Land cleared before December 31, 2020 is grandfathered. Satellite imagery from Sentinel-2, Landsat, and proprietary monitoring services (Trase, Earthsight, World Resources Institute) is being used to verify claims at scale.
Due Diligence Statement (DDS). Every shipment requires a DDS submitted through the EU Commission's TRACES.NT system before goods clear EU customs. The statement covers product origin, quantity, supplier identity, geolocation data, and a risk assessment. The operator placing the goods on the market is legally responsible — penalties cannot be passed to the supplier.
Penalties. Non-compliance carries penalties of up to 4% of the operator's annual EU turnover, full confiscation of the shipment, and exclusion from public procurement and EU funding for up to 12 months. Repeat offenses compound.
Origin compliance landscape
Top 10 palm oil-producing countries by share of global production, with the EU's published or anticipated EUDR risk classification. High-risk classifications trigger enhanced due diligence requirements; standard and low classifications follow the baseline DDS process.
| Rank | Country | Share % | EUDR risk tier | Compliance notes |
|---|---|---|---|---|
| 1 | Indonesia | 61 | standard | RSPO + ISPO frameworks established but distinct from EUDR; smallholder mills under scrutiny |
| 2 | Malaysia | 24 | standard | MSPO + RSPO infrastructure; estate-level traceability strong |
| 3 | Thailand | 3.8 | low | |
| 4 | Colombia | 2 | low | |
| 5 | Nigeria | 1.5 | standard | |
| 6 | Guatemala | 1 | low | |
| 7 | Papua New Guinea | 0.8 | standard | |
| 8 | Ecuador | 0.6 | low | |
| 9 | Honduras | 0.6 | low | |
| 10 | Brazil | 0.6 | standard |
Compliant alternative origins
Origins where producers and exporters are already filing compliant Due Diligence Statements, with structured geolocation data and verified deforestation-free supply chains. If your current sourcing is exposed, these are starting points.
| Origin | Capacity (MT/yr) | Compliance posture | Notes |
|---|---|---|---|
| Colombia | 1,900,000 | Active DDS filings | Fedepalma traceability; deforestation-free commitments |
| Guatemala | 900,000 | Active DDS filings | GREPALMA estate model; strong compliance posture |
| Thailand | 3,500,000 | Filing capability | Smallholder model but strong national traceability |
Atlas Tradex pre-qualifies suppliers against EUDR criteria — geolocation data, post-2020 land-use verification, DDS-ready documentation. Filter the directory to compliant counterparties only.
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