EUDR: what EU buyers will ask soybean meal and palm oil suppliers from 30 December 2026
By the Vanguard Verify desk · Published 2026-11-04 · Updated 2026-11-04
Short answer: from 30 December 2026, large and medium EU operators that place soya or palm oil products on the EU market (or export them) must prove under the EU Deforestation Regulation (EUDR, Regulation (EU) 2023/1115, as amended by Regulation (EU) 2025/2650) that each lot is deforestation-free after 31 December 2020, legally produced in its country of origin, and covered by a due diligence statement. If you sell soybean meal or palm oil to them, expect to be asked for plot geolocation, production dates, legality evidence and proof of segregation. If you cannot supply it, the EU Commission's own FAQ says the operator must not place the product on the market.
Who must comply, and when
| Who | Applies from |
|---|---|
| Large and medium operators; downstream operators and traders of all sizes | 30 December 2026 |
| Micro and small enterprises (for products covered by the old EU Timber Regulation) | 30 December 2026 |
| Micro-enterprises and operators who are natural persons (all other EUDR products) | 30 June 2027 |
The Commission's simplification review of 4 May 2026 kept the 30 December 2026 date. The regulation places no direct duty on a non-EU producer unless it places products on the EU market itself. In practice the duty reaches you through your EU buyer's contract and questionnaire. Soya products (including soybean oilcake/meal, HS 2304) and palm oil (HS 1511) are in Annex I. Check the amended Annex I, in force since 18 September 2026, for your exact HS code.
What an EU buyer will ask you for
- Geolocation of every plot. Latitude/longitude to six decimal places. Plots over 4 hectares need a polygon. Plots of 4 hectares or less can use a single point. Circles are not accepted. A shipment that blends many farms needs every contributing plot.
- Date or time range of production. Where exact harvest dates are not known, the crop year or harvest season can be used.
- Deforestation-free evidence. Proof that no plot was deforested or degraded after 31 December 2020. Any deforestation on a declared plot disqualifies the commodity from it.
- Legality evidence. Proof the crop was produced under the laws of the country of production, including land use rights, environmental protection, labour and human rights, tax, anti-corruption, and trade and customs rules.
- Segregation. The FAQ says mass balance is not allowed. Compliant material must be kept separate at every step. If non-compliant material is mixed in and cannot be separated, the whole batch is non-compliant. This matters for crushers and refineries.
- Supplier identity. Your legal name, address and email, the product description, quantity and country of production. All operators must keep supplier and customer records for five years.
- Reference numbers. Only the operator who first places the product on the market files the due diligence statement in the EU Information System. Downstream operators and traders collect and pass on its reference number.
Does country risk change anything?
The Commission's 2025 benchmarking sorts countries into low, standard and high risk. Russia, Belarus, Myanmar and North Korea are high risk. Brazil is standard risk. Buyers sourcing from low-risk countries may use simplified due diligence (no risk assessment or mitigation unless there is credible information of a problem). The FAQ says there is no exception to geolocation for low-risk countries. Check the current list, because the benchmarking is reviewed.
Red flags in an "EUDR-compliant" offer
- "EUDR compliant" on an offer sheet, with no plot data, polygons or production dates.
- A certificate (RSPO, MSPO, ISCC, RTRS or similar) presented as a substitute for due diligence. Certification can support a risk assessment, but the operator stays responsible.
- Mass balance or "book and claim" volumes offered as EUDR-ready.
- A seller who refuses to name the mill, crusher or origin, or whose company does not appear in the official registry of its country.
- A due diligence statement "reference number" sent by a party who is not the EU operator that filed it.
- Pressure to pay before any documents, with the usual ICPO/FCO/advance-fee pattern. In a real deal the buyer shows proof of funds (POF) and the seller shows proof of product (POP).
How to prepare as a supplier
- Map your supply base to farm or plantation level and capture polygons for plots over 4 ha.
- Check each plot against a deforestation baseline from 31 December 2020.
- Collect legality documents per plot or supplier, and keep them for five years.
- Set up physical segregation for EUDR-bound lots from the field to the vessel.
- Agree in the contract which party is the "operator" and who files the due diligence statement.
Related: How to verify a soybean meal supplier · How to verify an edible oil supplier.
This page is general information, not legal advice. EUDR compliance is the operator's own legal duty, and a company check does not replace it.
Check a company now with Vanguard Verify — first check free.
Type the company name. We show its public registry record (Global LEI Index), free.
Public registry data. By searching you accept our Terms.
FAQ
When does the EUDR apply to soybean meal and palm oil?
From 30 December 2026 for large and medium operators and for downstream operators and traders. Micro-enterprises and natural persons have until 30 June 2027 for most products.
Does a non-EU supplier have a direct EUDR obligation?
Not unless it places products on the EU market itself. But EU buyers must collect plot geolocation, production dates and legality evidence from suppliers, so the duty reaches you through the contract.
Is mass balance allowed under the EUDR?
No. The Commission FAQ says compliant material must be segregated at every step; a batch mixed with non-compliant material that cannot be separated is non-compliant.
Is a sustainability certificate enough for EUDR?
No. Certification can support a risk assessment, but the operator remains responsible for due diligence and the due diligence statement.
What is the EUDR cut-off date?
31 December 2020. Products must not come from land deforested or degraded after that date.
Vanguard Verify is run by Vanguard Trade Capital Goods Wholesalers DWC-LLC, Dubai South, Licence 14282. This answer is general information, not legal or financial advice.