EUDR Compliance for Rubber & Palm Oil Exporters

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.

1. What exactly is in scope

CommodityIn-scope products (Annex I, HS codes)
RubberNatural 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 oilCrude 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
The 2026 simplification package narrowed some downstream/derived rubber products out of scope. Verify your HS codes against the current annex — or send us your product list and we will screen it.

2. Why rubber and palm oil are the hardest cases

1) Plantations, not forests — but planted on ex-forest land

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.

2) Smallholder dominance

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.

3) Deep processing chains

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.

If you already run ISPO/RSPO or FSC systems: excellent groundwork — many plantation records and satellite systems exist. But EUDR adds its own legal duties: DDS submission, WGS-84 format, cut-off evidence and 5-year retention. We convert existing sustainability systems into EUDR-ready ones.

3. Your practical roadmap

  1. HS-code screening of every product line exported to the EU (or sold to an EU-bound customer).
  2. Plantation/plot data programme: geolocation in WGS-84, polygons >4 ha, smallholder collection SOPs, trader reporting obligations.
  3. Cut-off verification: satellite-based screening of plantation blocks against post-2020 deforestation.
  4. Legality evidence: land titles (HGU/Hak Guna Usaha in Indonesia, title deeds in Thailand), environmental permits, labour compliance.
  5. Due diligence system + DDS workflow: SOPs, risk assessment per batch, DDS submission responsibility, 5-year record keeping.

Deadlines: 30 Dec 2026 (large/medium operators), 30 Jun 2027 (micro/small). EU buyers' supplier questionnaires are arriving now.

4. How we help producers and processors

ServiceWhat you get
Scope & gap analysisHS screening, readiness score, prioritised plan
Plot geolocation programmeTemplates, SOPs, quality control, smallholder data strategy
Due diligence system buildComplete documentation set aligned with Articles 8–12
TrainingManagement, sustainability and procurement teams — remote, English/Chinese
Buyer response supportAnswer EU customers' EUDR questionnaires, audits and contract clauses

Get your products screened

Send us your HS codes and buyer requirements — receive a solution proposal within three business days.

Apply Online →