These two commodities are where Southeast Asia meets EUDR head-on: Indonesia, Thailand, Malaysia and Vietnam supply most of the world's natural rubber and palm oil. The EU is a major buyer — and from 30 December 2026, it buys only deforestation-free, plot-traceable product.
| Commodity | In-scope products (Annex I, HS codes) |
|---|---|
| Rubber | Natural rubber, balata, gutta-percha (HS 4001); rubber in primary forms (HS 4002–4006 — the mixed/exempted forms were narrowed by the 2026 simplification) |
| New pneumatic tyres (HS 4011); rubber apparel, gloves, footwear with rubber components and derived products placed on the EU market | |
| Palm oil | Crude and refined palm oil and fractions (HS 1511); palm kernel oil, babassu oil (HS 1513) |
| Margarine, glycerol, soaps and many downstream preparations containing palm derivatives — check your exact HS code against Annex I |
Both crops are long-cycle plantations. The question EUDR asks is not "is this a forest today?" but "was this land forest after 31 December 2020?" Historical conversion on the plantation block matters — as does any new planting or replanting that expanded into forest.
In Thailand and Indonesia, the majority of natural rubber and much palm fruit comes from smallholders. Collecting plot polygons from thousands of family farms — and keeping them linked to intermediate traders and collection points — is the core operational challenge.
Latex → concentrated latex → gloves; FFB → CPO → refinery → oleochemicals → soaps. Each transformation multiplies the number of origin plots hiding inside one export container. Robust traceability bookkeeping (segregation or documented mixing with full plot lists) is mandatory.
Deadlines: 30 Dec 2026 (large/medium operators), 30 Jun 2027 (micro/small). EU buyers' supplier questionnaires are arriving now.
| Service | What you get |
|---|---|
| Scope & gap analysis | HS screening, readiness score, prioritised plan |
| Plot geolocation programme | Templates, SOPs, quality control, smallholder data strategy |
| Due diligence system build | Complete documentation set aligned with Articles 8–12 |
| Training | Management, sustainability and procurement teams — remote, English/Chinese |
| Buyer response support | Answer EU customers' EUDR questionnaires, audits and contract clauses |
Send us your HS codes and buyer requirements — receive a solution proposal within three business days.
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