EUDR for cosmetics brands

The scope test is the CN code, not the word "palm". A product is caught only if it falls under a heading listed in Annex I. That cuts both ways: some palm-derived cosmetic ingredients sit under a heading that is not listed and are therefore out, while an ingredient you would not think of as "palm" — a fatty alcohol, say — can be squarely in. Work from the customs classification of each raw material, not the marketing name.

Soap is out today — but a draft act would pull it in

Here is the piece most cosmetics teams miss. Finished soap (CN 3401) is not in Annex I as it stands, so a bar of palm-based soap or a syndet cleanser classified as soap is out of scope right now, even though it is built on palm material. [Reg. 2023/1115, Annex I] That is not a permanent answer. A draft delegated act published on 4 May 2026 proposes adding soap (CN 3401 11 00 and 3401 20), along with other palm-oil derivatives, to Annex I. [Commission EUDR implementation page] As at 10 July 2026 that draft is still going through adoption and Parliament and Council scrutiny — it is not adopted, not in the Official Journal, and not in force, and the final text can still change. Read it as an early warning, not a rule: don't classify soap as permanently out, and don't act as if it is already in.

Which role are you? Importer, or downstream brand?

This is the question that decides your workload. The EUDR splits the chain into operators and downstream operators or traders. [Reg. 2023/1115, Art. 5 (as amended by Reg. 2025/2650)]

• You import the palm oil or a listed derivative into the EU yourself. You are the first operator. You run full due diligence and file the DDS before the material is placed on the market or cleared through customs. [Reg. 2023/1115, Art. 4(2)]
• You buy the ingredient from an EU supplier who already placed it on the market. You are downstream. You collect and keep the DDS reference number that came with the material, keep records, and must not place a product you know is non-compliant. A non-SME downstream operator no longer runs full due diligence on every batch; an SME has the lightest touch of all. [Reg. 2023/1115, Art. 5 (as amended by Reg. 2025/2650)]
• You compound or fill in the EU using bought-in derivatives. You are still downstream on those inputs — but the moment you import any relevant material directly, you become the operator for that line and pick up the DDS.

Most brands sit downstream, buying EU-placed ingredients from a distributor. The point to watch is the one specialty raw material you source direct from outside the EU: that single import can make you the operator, with the full due diligence and DDS that follow.

Coconut is not palm — and it matters

Cosmetics chemistry is full of ingredients that come from either palm or coconut — fatty alcohols, glycerin, fatty acids. The EUDR covers only the oil-palm version. Several of the relevant Annex I codes carry an "ex" prefix, and a pending clarification confirms that only the commodity-derived form is caught, so a coconut-sourced or synthetic equivalent under the same heading is not in scope. [Commission EUDR implementation page] The practical job is knowing the botanical origin of each raw material, because two drums with the same INCI name can have opposite EUDR answers.

Origin risk and what to ask your supplier

Palm origin drives the due diligence load. Under Implementing Regulation (EU) 2025/1093, the major palm producers Indonesia and Malaysia are standard risk, which means full due diligence where you are the operator. [Impl. Reg. 2025/1093] Whatever your role, you will want the origin data in the chain. For each relevant ingredient, ask your supplier for: the botanical source (palm or not); plot geolocation — coordinates, and polygons for plots over 4 hectares; harvest or production dates; country of production; legality evidence; and the DDS reference number where the supplier is the operator that filed it. [Reg. 2023/1115, Art. 9 & Art. 2(28)]

What this determines — and what it doesn't

Screening your formulations tells you which ingredients are in scope, your role, your deadline and the documentary obligations you owe. It does not verify that any plantation 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 an ingredient-by-ingredient map of what is palm-derived and in scope, who imported it, and exactly what to ask each 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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