EUDR for cosmetics and personal care: which palm oil derivatives are in scope

Yes, if the fatty acid, fatty alcohol, glycerol or soap in your formulation was made from oil palm. The EUDR classifies palm oil as one of its seven regulated commodities, and Annex I lists a specific set of downstream oleochemicals derived from it as "relevant products" in their own right — not just crude and refined palm oil, but industrial fatty acids, fatty alcohols, glycerol and certain soaps, provided oil palm is the feedstock. A further, wider list of palm oleochemicals was added to Annex I in September 2026 and applies a year later than everything else. Cosmetics and personal care manufacturers are one of the least prepared sectors for this, because the ingredient rarely arrives labelled as palm.

Which palm derivatives are already in scope

Annex I to Regulation (EU) 2023/1115 has always covered more than crude and refined palm oil and palm kernel oil. It also lists a set of downstream chemicals under an "ex" classification, meaning the CN code only counts as a relevant product when the goods it covers were actually made from oil palm. The same chemical made from coconut, rapeseed or tallow sits outside EUDR scope under this entry, however similar the finished ingredient looks on a certificate of analysis.

What this catches in a cosmetics formulation:

• Glycerol — a near-universal humectant, when made from palm.
• Industrial monocarboxylic fatty acids, including palmitic and stearic acid, used across cleansers, soap bars and emulsifiers.
• Industrial fatty alcohols — cetyl, stearyl and related C12–C18 alcohols used as emulsifiers and thickeners.
• Soap, in the industrial sense the CN classification uses, not only a finished retail bar.

These are indicative CN headings, not a substitute for checking your own products against the current Annex I text and your supplier's customs classification. Two batches of what a supplier calls "vegetable glycerine" can carry different CN codes depending on feedstock, and only one of them is a relevant product under this entry. This is the same principle covered in more general terms in what changed under the December 2025 amendment: EUDR scope runs on customs classification, not on how an ingredient is marketed.

These already-listed derivatives are due on the same schedule as palm oil itself — the main application dates, not a later one.

The further derivatives added from 30 December 2027

Commission Delegated Regulation (EU) 2026/2102, in force since 18 September 2026, widened Annex I again. Alongside removing several leather and rubber products and adding soluble coffee, it brought in a further tranche of palm oleochemicals that the original 2023 text did not reach: hydrogenated, inter-esterified or re-esterified palm and palm kernel oils, chemically modified palm oils and inedible fat mixtures made with palm, crude glycerol and glycerol waters and lyes from palm processing, further palm-based fatty alcohols including octanol and other saturated monohydric alcohols, and additional soap forms.

Palm derivative category	Annex I status	Applies from
Crude and refined palm oil, palm kernel oil	Original scope	Main date for your size
Glycerol, fatty acids, fatty alcohols, soap (as originally listed)	Original scope	Main date for your size
Hydrogenated / inter-esterified / re-esterified palm oils, chemically modified palm oils	Added by (EU) 2026/2102	30 December 2027
Crude glycerol, glycerol waters and lyes; octanol and further fatty alcohols; additional soap forms	Added by (EU) 2026/2102	30 December 2027

The practical effect for a formulator buying a broad palm oleochemical range is that you can be running two dates against the same supplier relationship: refined palm oil and standard glycerol due against your main date, a specific inter-esterified palm fraction or a crude glycerol by-product due more than a year later. The full Annex I changes cover the removals and additions across all seven commodities, not only palm; this page stays with what matters for a cosmetics or personal care formulation.

Chemical transformation does not take you out of scope

The most common misunderstanding in this sector is that once palm oil has been split, hydrogenated, esterified or saponified into an oleochemical, it has left the regulation behind because the product no longer resembles a plant. It has not. If the finished ingredient falls under one of the CN codes Annex I lists as palm-derived, the due diligence obligation follows it however many processing steps sit between the plantation and your goods-in door. A cosmetics brand buying a finished emulsifier from a specialty chemicals distributor is still buying a relevant product; the distance from the plantation changes how hard traceability is, not whether the obligation applies.

This is what makes palm oleochemicals harder to manage than a commodity like green coffee or cocoa butter, where the supply chain from farm to import is comparatively short. A stearyl alcohol blend can pass through a crushing mill, a refinery and an oleochemical plant before it reaches a formulator, and each of those steps needs to be able to show where the palm content came from — down to plot-level geolocation for production units above four hectares, in line with the geolocation requirements that apply to every relevant product regardless of how processed it is.

Who owes the due diligence statement

Regulation (EU) 2025/2650 concentrated the due diligence statement on whoever first places the product on the EU market, rather than requiring every business in the chain to file its own. For a cosmetics supply chain, that is usually one of:

• An EU-based formulator or contract manufacturer importing palm derivatives directly from a non-EU refiner or oleochemical producer — this is the primary operator, and the statement is theirs to file.
• An EU ingredient distributor who imports in bulk and resells to formulators — also a primary operator on the volumes it imports itself.
• A cosmetics brand that buys a finished, EU-sourced base or premix from a distributor who already filed a statement — this is a downstream operator or trader, and the obligation is to record and pass on the reference number, not file a fresh statement for the same goods.

Getting this wrong in either direction causes real problems: a downstream buyer who assumes someone upstream has filed, when in fact they are the first EU importer, has simply not complied. A formulator who re-files unnecessarily for goods someone else already covered is doing avoidable work. Work out which role applies to each ingredient line separately, because a single formulation can combine palm derivatives bought at different points in the chain.

Deadlines for a cosmetics or personal care business

Your business	Deadline for already-listed palm derivatives	Deadline for the 2026/2102 additions
Large or medium operator or trader	30 December 2026	30 December 2027
Micro or small operator, product previously under the EU Timber Regulation	30 December 2026	30 December 2027
Micro or small operator, otherwise	30 June 2027	30 December 2027

Size is set by Directive 2013/34/EU thresholds: broadly, micro is up to 10 staff and €900,000 turnover, small up to 50 staff and €10 million turnover, medium up to 250 staff and €50 million turnover, and large above that. Most independent cosmetics formulators and small-batch skincare brands fall into micro or small; contract manufacturers and ingredient distributors serving multiple brands are more often medium or large. The full deadline breakdown covers how the two dates interact with role and product history in more detail.

Origin and risk tier

Most palm oil and its derivatives placed on the EU market originate in Indonesia and Malaysia. Neither appears on the Commission's benchmarked low-risk list under Implementing Regulation (EU) 2025/1093, so both sit in the default standard risk tier — a 3% checking rate for competent authority scrutiny, rather than the reduced simplified due diligence available for low-risk origins. If any part of your palm supply passes through a mill or refinery sourcing from multiple plantations across different countries, you need country-of-production data at the level your supplier can actually provide it, not an assumed single origin. Country benchmarking explained covers what the risk tier changes about your due diligence obligations.

Does RSPO or ISCC certification satisfy due diligence?

No. Certification schemes such as RSPO and ISCC are useful risk-mitigation evidence — they can support the risk assessment a due diligence statement is built on — but they do not substitute for it. The distinction that matters is the certification's chain-of-custody model. RSPO "identity preserved" and "segregated" grades keep physical traceability back to specific mills and plantations, which is compatible with what EUDR geolocation needs. "Mass balance" grades pool certified and conventional material administratively and do not, on their own, give you plot-level origin for the specific batch you bought. A certificate on file is not the same as being able to produce geolocation coordinates for the plantations behind your derivative if a competent authority asks.

What to ask your ingredient suppliers now

• Which CN code does this ingredient carry, and does your classification reflect the palm content specifically, or a blend?
• Can you provide plot-level geolocation for the palm oil behind this batch, not just a mill or country of processing?
• If you supply both palm and non-palm versions of the same chemical (a stearyl alcohol from palm and from rapeseed, for instance), how do you keep the two traceable separately through your own processing?
• Are you the first business placing this ingredient on the EU market, or has someone upstream of you already filed a due diligence statement I should be referencing instead?

Check what the EUDR requires of your specific ingredients and role rather than assuming a palm-adjacent product is covered, or that a certificate closes the question.