The European Union (EU) has formally updated the product scope of the EU Deforestation Regulation (EUDR), following the conclusion of the public consultation on the draft Delegated Act proposing changes to Annex I of the Regulation.
Commission Delegated Regulation (EU) 2026/2102 was published in the Official Journal of the European Union on 17 September 2026 and entered into force on 18 September 20261,2. This update forms part of the simplification package intended to provide greater clarity for businesses and authorities ahead of the EUDR implementation in December 2026.
Additional Palm-Based Products Brought into Scope
For the palm oil industry, the update extends EUDR product coverage to include additional palm-based downstream products, particularly those used in the oleochemical industry. The newly added categories include:
- hydrogenated, inter-esterified, re-esterified or elaidinised palm and palm kernel oils and their fractions
- chemically modified palm and palm kernel oils
- crude glycerol and related palm-derived products
- saturated and unsaturated fatty alcohols
- fatty acids, salts, esters, amines, amides, and other oleochemical derivatives
- soaps containing or manufactured using oil palm
- chemical products and preparations containing or manufactured using oil palm
- certain polyethers manufactured using oil palm
These products fall under a range of Combined Nomenclature (CN) and Harmonised System (HS) classifications specified in the amended Annex I.
The amendment also provides greater clarity on certain palm-derived products already listed under the EUDR, including glycerol, palmitic and stearic acids, industrial fatty acids, and industrial fatty alcohols.
New Products to Be Covered from 30 December 2027
The newly added palm-based downstream products will be subject to EUDR requirements from 30 December 2027. This is separate from the existing implementation timetable for products already covered under Annex I, which is 30 December 2026 for large and medium-sized operators and 30 June 2027 for micro and small operators.
Targeted Exemptions and Clarifications
The Delegated Regulation also introduces several targeted exemptions and clarifications. These include certain waste, used and second-hand products, packing materials, samples, and products used solely for analysis, examination or testing. Specific exclusions also apply to certain products used in the manufacture of medicinal products for human or veterinary use.
For oil palm, the Regulation further clarifies that the relevant commodity covers Elaeis species, including Elaeis guineensis, while excluding babassu oil from Attalea species and vegetable oils derived from other palm species.
Implications for Malaysian Exporters
The expansion of the EUDR product scope is particularly relevant to Malaysian exporters of downstream palm oil and oleochemical products. However, the additional transition period provides exporters with time to review their supply chains, identify potential information or traceability gaps, and engage with EU customers on compliance requirements ahead of the December 2027 application date.
Malaysia’s existing sustainability and traceability frameworks, including the Malaysian Sustainable Palm Oil (MSPO) certification scheme and the Sistem Kebolehjejakan Nasional (SKN), will continue to play an important role in supporting the Malaysian palm oil industry’s preparedness for the EUDR. In its 4 May 2026 simplification review, the European Commission highlighted that Malaysia’s national sustainability standards for palm oil, rubber and timber have been upgraded and aligned with EUDR information requirements3.
List of Palm Oil-related HS/CN Codes under the EUDR as of 17 September 2026
The EUDR identifies relevant products according to the EU Combined Nomenclature (CN), which is based on the international Harmonised System (HS). Some entries are specified at the EU eight-digit CN level. Table 1 summarises the palm oil-related HS/CN codes covered under the EUDR and highlights the changes introduced by Commission Delegated Regulation (EU) 2026/2102, including newly added products and clarifications to existing entries.
Table 1. Palm Oil-Related HS/CN Codes under the EUDR as of 17 September 2026
|
HS/CN Code |
Palm Oil Product / Derivative |
Pre-amendment Annex I |
Amended Annex I (Commission Delegated Regulation (EU) 2026/2102) |
Remarks |
|
ex 1207 10 00 |
Palm nuts and kernels |
Covered |
Covered |
Clarified at eight-digit level and limited through the use of “ex”. |
|
ex 1511 |
Palm oil and its fractions, whether or not refined, but not chemically modified
|
Covered |
Covered |
“ex” added. Waste is excluded from scope. |
|
ex 1513 21 |
Crude palm kernel oil and fractions
|
Covered |
Covered |
“ex” added. Waste is excluded from scope. |
|
ex 1513 29 |
Palm kernel oil and fractions, other than crude
|
Covered |
Covered |
“ex” added. Waste is excluded from scope.
|
|
ex 1516 20 |
Hydrogenated, inter-esterified, re-esterified or elaidinised palm and palm kernel oils and fractions
|
Not covered |
Added |
Medicinal-product manufacturing exclusion applies. Applicable from 30 December 2027. |
|
ex 1518 00 |
Chemically modified palm and palm kernel oils and certain inedible preparations
|
Not covered |
Added |
Waste is excluded. Applicable from 30 December 2027. |
|
ex 1520 00 |
Crude glycerol, glycerol waters and lyes produced using oil palm
|
Not covered |
Added |
Applicable from 30 December 2027. |
|
ex 2306 60 00 |
Oilcake and other solid residues from palm nut or kernel oil extraction
|
Covered |
Covered |
Technical clarification, including the use of “ex” and the eight-digit code. |
|
ex 2905 16 |
Octanol and its isomers synthesised using oil palm
|
Not covered |
Added |
Applicable from 30 December 2027. |
|
ex 2905 17 00 |
Lauryl, cetyl and stearyl alcohols synthesised using oil palm |
Not covered |
Added |
Medicinal-product manufacturing exclusion applies. Applicable from 30 December 2027.
|
|
ex 2905 19 00 |
Other saturated monohydric alcohols synthesised using oil palm
|
Not covered |
Added |
Applicable from 30 December 2027. |
|
ex 2905 45 |
Glycerol with a purity of 95% or more, synthesised using oil palm
|
Covered |
Covered |
Oil-palm origin clarified. Medicinal-product manufacturing exclusion applies. |
|
ex 2915 39 |
Specified esters of acetic acid synthesised using oil palm
|
Not covered |
Added |
Certain named acetate products are excluded. Applicable from 30 December 2027. |
|
ex 2915 70 |
Palmitic acid, stearic acid, and their salts and esters synthesised using oil palm
|
Covered |
Covered |
Oil-palm origin clarified. Medicinal-product manufacturing exclusion applies. |
|
ex 2915 90 |
Specified saturated acyclic monocarboxylic acids and derivatives synthesised using oil palm
|
Covered |
Covered |
Scope refined with specified exclusions. Medicinal-product manufacturing exclusion applies. |
|
ex 2916 15 |
Oleic, linoleic and linolenic acids, and their salts and esters synthesised using oil palm
|
Not covered |
Added |
Applicable from 30 December 2027. |
|
ex 2916 19 10 |
Undecenoic acids, and their salts and esters synthesised using oil palm
|
Not covered |
Added |
Applicable from 30 December 2027. |
|
ex 2921 19 |
Specified acyclic monoamines and their derivatives and salts synthesised using oil palm |
Not covered |
Added |
Certain named amines are excluded. Medicinal-product manufacturing exclusion applies. Applicable from 30 December 2027.
|
|
ex 2923 90 00 |
Specified quaternary ammonium salts and hydroxides synthesised using oil palm |
Not covered |
Added |
Certain named compounds are excluded. Medicinal-product manufacturing exclusion applies. Applicable from 30 December 2027.
|
|
ex 2924 19 00 |
Specified acyclic amides, carbamates, and their salts synthesised using oil palm |
Not covered |
Added |
Certain named substances are excluded. Medicinal-product manufacturing exclusion applies. Applicable from 30 December 2027.
|
|
ex 3401 11 00 |
Soap in bars, cakes, moulded pieces or shapes for toilet use containing or made using oil palm
|
Not covered |
Added |
Medicinal-product manufacturing exclusion applies. Applicable from 30 December 2027. |
|
ex 3401 20 |
Soap in forms other than bars, cakes, moulded pieces or shapes containing or made using oil palm
|
Not covered |
Added |
Applicable from 30 December 2027. |
|
ex 3823 11 00 |
Industrial stearic acid synthesised using oil palm |
Covered |
Covered |
Oil-palm origin clarified. Medicinal-product manufacturing exclusion applies.
|
|
ex 3823 12 00 |
Industrial oleic acid synthesised using oil palm |
Covered |
Covered |
Oil-palm origin clarified. Medicinal-product manufacturing exclusion applies.
|
|
ex 3823 19 |
Other industrial monocarboxylic fatty acids and acid oils from refining synthesised using oil palm
|
Covered |
Covered |
Waste is excluded from scope. |
|
ex 3823 70 00 |
Industrial fatty alcohols synthesised using oil palm
|
Covered |
Covered |
Technical clarification, including oil-palm origin and the eight-digit code. |
|
ex 3824 99 |
Other specified chemical products and preparations containing or made using oil palm
|
Not covered |
Added |
Medicinal-product manufacturing exclusion applies. Applicable from 30 December 2027. |
|
ex 3907 29 |
Other specified polyethers in primary forms made using oil palm |
Not covered |
Added |
Excludes bis(polyoxyethylene) methylphosphonate. Medicinal-product manufacturing exclusion applies. Applicable from 30 December 2027.
|
Notes:
- The prefix “ex” means that only the products specifically described in Annex I within the relevant CN heading or subheading fall within the scope of the EUDR; it does not mean that every product classified under that code is covered.
- CN heading 3402 (surfactants) is not added to Annex I by Commission Delegated Regulation (EU) 2026/2102.
References:
- Commission Delegated Regulation (EU) 2026/2102: https://op.europa.eu/en/publication-detail/-/publication/42f36e5a-b230-11f1-b9e5-01aa75ed71a1/language-en
- European Commission (EC) Announcement on Commission Delegated Regulation: https://environment.ec.europa.eu/news/commission-updates-product-scope-and-tools-support-eudr-2026-07-13_en
- EC EUDR Simplification Review Report: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52026DC0191