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Which soy products are in scope

All the forms an importer or crusher handles are inside Annex I:

• Soya beans — HS 1201, whether or not broken. [Reg. 2023/1115, Annex I]
• Soya-bean oil and its fractions — HS 1507, refined or crude.
• Oil-cake and other solid residues from extracting soya-bean oil — HS 2304 (soybean meal).

Crushing does not take the product out of scope: if you import beans and press them, the oil and the meal you produce are themselves Annex I goods. The regulation follows the commodity through those first transformations rather than dropping it once the bean is processed. [Reg. 2023/1115, Art. 2(1) & Annex I]

You are the first operator

The operator is the first person to place a relevant product on the EU market, or to export it. [Reg. 2023/1115, Art. 2(15)] For soy landing in the EU, that is you. Before the beans, oil or meal are placed on the market or cleared through customs, you must: [Reg. 2023/1115, Art. 4]

• Collect the information for every plot the soy came from — geolocation, harvest/production dates, country of production and legality evidence. [Reg. 2023/1115, Art. 9 & Art. 2(28)]
• Assess and mitigate risk, unless a simplified route applies (see below). [Reg. 2023/1115, Art. 10 & Art. 11]
• File the Due Diligence Statement in the EU Information System and obtain a reference number that then travels with the goods to your buyers. [Reg. 2023/1115, Art. 4(2)]

Origin risk tiers — and the US simplification

Under Implementing Regulation (EU) 2025/1093, each producing country is benchmarked low, standard or high risk, and that tier sets how much due diligence you run. [Impl. Reg. 2025/1093] For the main soy origins:

• Brazil — standard risk. The EU’s largest soy supplier. Full due diligence: collect the information, then assess and mitigate risk before you file.
• United States — low risk. Soy of confirmed US origin qualifies for simplified due diligence under Article 13 — you still collect the Article 9 information, including geolocation, but you are not required to run the full risk assessment and mitigation, provided you have ruled out mixing and have no information pointing to a problem. [Reg. 2023/1115, Art. 13]
• Argentina and Paraguay are further major origins — check each against the current benchmarking list. Tiers are reviewed periodically and can change, so re-confirm before you rely on a simplified route.

Which deadline applies to you

Soy is not timber, so the SME extension is available. Medium and large operators apply from 30 December 2026; a micro or small operator meeting the size test (under 50 employees and ≤€10m turnover, SME status established by 31 December 2024) may use 30 June 2027. [Reg. 2023/1115, Art. 38 (as amended by Reg. 2025/2650)] Most soy importers and crushers are well above the SME thresholds, so the December 2026 date is the realistic one to plan against.

What this determines — and what it doesn't

Screening your soy tells you scope, role, deadline and the documentary obligations you owe as the operator. It does not verify that any farm is deforestation-free — that depends on the geolocation-plus-evidence your origin suppliers provide and any satellite check. The report tells you exactly what to demand and file; the traceability work on the plots is separate.

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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