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Palm oil is the one to watch

Palm oil turns up in a huge share of processed food — spreads, biscuits, chocolate, margarine, fried snacks, bakery fats — and it is squarely in Annex I. Crude and refined palm oil sit under HS 1511, palm kernel oil under 1513, and palm oilcake under 2306. [Reg. 2023/1115, Annex I] If palm oil is in your recipe, that ingredient is a relevant product and it carries the full origin and due-diligence chain, regardless of how small the percentage in the finished item is.

One product, several commodities

The point manufacturers need to grasp is that the EUDR is scoped by ingredient, not by finished product. A single item can carry more than one relevant commodity, and each one is assessed on its own origin data. [Reg. 2023/1115, Annex I] A chocolate spread is the classic case: cocoa (1806), palm oil (1511) and soy lecithin from soya all appear in one jar, so three commodities travel with one SKU. The commodities that show up most in food are:

• Palm oil — crude/refined (1511), palm kernel oil (1513).
• Soya — beans (1201), soybean oil (1507) and soy meal/oilcake (2304); soy lecithin and soy-derived ingredients trace back to these lines.
• Cocoa — paste, butter, powder and chocolate (1803–1806).
• Coffee — green and roasted (0901), used as an ingredient or flavouring.

Do you file the DDS, or reference it?

Most food manufacturers buy processed ingredients rather than importing raw commodities, and that usually puts them downstream. The line runs like this:

• You import the raw commodity into the EU. If you bring palm oil, cocoa or soy into the EU yourself, you are the operator: you run full due diligence and file the DDS before the goods are placed on the market. [Reg. 2023/1115, Art. 4(1)–(2)]
• You buy EU-placed ingredients and manufacture. You buy refined palm oil, cocoa powder or lecithin from an EU supplier who already placed it on the market — you are downstream. A non-SME collects the upstream DDS reference numbers, registers in the information system and keeps records; an SME only collects and keeps the reference numbers. [Reg. 2023/1115, Art. 5 (as amended by Reg. 2025/2650)]
• You export finished food out of the EU. Export is also an operator act, so a product you make and ship outside the EU can carry its own due-diligence obligation. [Reg. 2023/1115, Art. 2(19) & Art. 4]

Which deadline applies

None of these food commodities is timber, so your date follows the size test. Medium and large businesses apply the rules from 30 December 2026; micro and small manufacturers meeting the SME thresholds — broadly under 50 employees and no more than €10m turnover or balance sheet, with status set by 31 December 2024 — have until 30 June 2027. [Reg. 2025/2650]

What to ask your ingredient suppliers for

For every in-scope ingredient, you need origin data per commodity. For each one, request: [Reg. 2023/1115, Art. 9 & Art. 2(28)]

• Plot geolocation — coordinates, and polygons for plots larger than four hectares.
• Harvest or production dates and country of production, which sets the origin risk tier under Implementing Regulation (EU) 2025/1093. [Impl. Reg. 2025/1093]
• The DDS reference number for each commodity, where an upstream operator has already filed.

The pending change to watch: palm-oil derivatives

Palm oil in food is in scope today, but a draft delegated act published on 4 May 2026 proposes widening the palm-oil lines to catch more derivatives — including palm-oil soap (CN 3401) and some hydrogenated and chemically modified palm oils. [Commission EUDR implementation page] As at 10 July 2026 that draft is not adopted and not in force, the consultation has closed but the text still has to clear formal adoption and scrutiny, and it may change. So if you make oleochemical or soap-adjacent products, treat those as an imminent addition — but do not stand down your compliance work on food-grade palm oil on the strength of a draft.

What this determines — and what it doesn't

Screening your recipes tells you which ingredients are caught, your role, your deadline and the documentary obligations you owe on each commodity. It does not verify that any plantation or farm 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 which ingredients are in scope and exactly what to demand from each supplier.

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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