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Which of your inputs are in scope

Soybean meal is the workhorse protein of European compound feed, and it is squarely inside Annex I. The codes that matter to a feed mill are:

• Oil-cake and other solid residues from extracting soya-bean oil — HS 2304. This is soybean meal, the main feed input, and it is in scope. [Reg. 2023/1115, Annex I]
• Soya beans — HS 1201, whether or not broken.
• Soya-bean oil and its fractions — HS 1507, refined or not.

The other six commodities can reach a feed formulation too — palm-based fats, for instance — but for most mills soya is the input that decides the workload. If your soy comes as full-fat beans, expeller cake or solvent-extracted meal, treat all of it as caught. [Reg. 2023/1115, Annex I]

The obligation attaches to the soy, not the animals

This is where feed manufacturers most often trip. The regulation covers commodities and the products “made using”, “containing” or fed with them as listed in Annex I — and the Annex I list for soya stops at the soy products themselves. [Reg. 2023/1115, Art. 2(1) & Annex I] The due-diligence trail for soya ends once the soy has been consumed as feed. Poultry, pig meat and eggs are not pulled into scope simply because the animals ate in-scope soy.

The exception is cattle: live cattle and beef appear in Annex I in their own right, so they carry their own obligation regardless of what they were fed. [Reg. 2023/1115, Annex I] That is a cattle rule, not a feed rule. For your feed business, the line to hold is simple: the soybean meal you handle is the in-scope product, and your job is the documentary chain on that soy.

Which role are you?

Everything turns on where you sit in the chain. [Reg. 2023/1115, Art. 5 (as amended by Reg. 2025/2650)]

• You import soymeal or soybeans into the EU yourself. You are the first operator. You run due diligence and file the DDS before the goods are placed on the market or clear customs. [Reg. 2023/1115, Art. 4(2)]
• You buy soymeal that an EU importer or crusher already placed on the market. You are downstream. You collect and keep the DDS reference numbers, and you may not place feed you know contains non-compliant soy. A non-SME downstream operator must also register in the information system; an SME simply keeps the references. [Reg. 2023/1115, Art. 5 (as amended by Reg. 2025/2650)]
• You are a micro or small operator. Soy is not timber, so if you meet the size test you may use the 30 June 2027 date rather than 30 December 2026. [Reg. 2023/1115, Art. 38 (as amended by Reg. 2025/2650)]

Origin risk tiers for feed soy

Where your soy is grown sets the effort. Under Implementing Regulation (EU) 2025/1093, Brazil — the EU’s largest soy supplier — is standard risk, which means full due diligence. The United States is classified low risk, which unlocks simplified due diligence: you still collect the Article 9 information, including plot geolocation, but you are not required to run the full risk assessment and mitigation steps unless something points to a problem. [Impl. Reg. 2025/1093] [Reg. 2023/1115, Art. 13] Argentina and Paraguay are further common origins — confirm each against the current benchmarking list, because the tiers are reviewed and can move.

What to ask your soy supplier for

Whatever your role, you want the origin data moving up the chain. For each consignment, request: [Reg. 2023/1115, Art. 9 & Art. 2(28)]

• Plot geolocation — coordinates, and polygons for plots larger than 4 hectares.
• Harvest/production dates.
• Country of production, which sets the risk tier.
• Legality evidence for the country of origin.
• The DDS reference number, where the supplier is the operator that filed it.

What this determines — and what it doesn't

Screening your feed inputs tells you scope, role, deadline and the documentary obligations you owe on the soy. It does not verify that any soy field is deforestation-free — that depends on the geolocation-plus-evidence your suppliers provide and any satellite check. You don’t need a traceability platform to begin; you need to know your position and exactly what to ask your soy supplier for.

General information about Regulation (EU) 2023/1115, not legal advice — and not a deforestation assessment. This kind of screening determines your scope, role, deadline and documentary obligations; it does not verify that any plot of land is deforestation-free. Confirm your classification with counsel before relying on it for a market-access decision.

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