EUDR for soap and candle makers: is your palm wax in scope

Soap made from palm oil is already an EUDR relevant product, and more soap forms join it on 30 December 2027. Palm wax sold for candle-making mostly is not, because the specialty wax most suppliers sell is classified under a customs heading Annex I does not list. Which applies to you depends on your supplier's CN code, not on the fact that the feedstock was palm.

Why soap and candle wax get different answers

The EUDR does not ask what a product is made from in the abstract. It asks whether the goods you place on the market fall under one of the Combined Nomenclature (CN) codes listed in Annex I to Regulation (EU) 2023/1115, and several of the oil palm entries are marked "ex" — meaning the code only counts as a relevant product when the specific goods were made using oil palm. The same chemical structure made from a different feedstock sits outside the entry entirely.

Soap has always had an "ex" entry of its own under CN heading 3401. Candle wax does not, and that gap is not an oversight. Heading 1521 (vegetable waxes) and heading 3404 (other artificial and prepared waxes) — the two headings most commercial candle waxes are actually classified under — have never appeared in Annex I's oil palm list, before or after the 2026 amendment. A customs classification ruling on a palm-stearin-based candle wax made this explicit: fractionating and partly hydrogenating palm stearin, then adding an optical brightener, took the product out of heading 1521 (because by then it was no longer the triglyceride the heading describes) and into heading 3404, "other artificial waxes and prepared waxes" — a heading the EUDR does not touch at all. The feedstock was entirely palm. The product was outside scope regardless.

This is the same CN-driven logic covered for cosmetics ingredients in EUDR for cosmetics and personal care: scope runs on customs classification, not on what the label says the product is made from.

Soap: where you stand now, and what changes in 2027

Annex I already lists soap under an "ex" entry against CN heading 3401, where the soap was made using oil palm. That has applied since the EUDR's original product scope and runs to the main application dates — it is not something the 2026 amendment introduced. If you make or import palm-based soap today, in bar, cake or other form, for the industrial or cosmetic trade, you are already within scope on the ordinary schedule.

Commission Delegated Regulation (EU) 2026/2102 — adopted 13 July 2026, published in the Official Journal on 17 September 2026, in force from 18 September 2026 — widened that soap entry rather than creating it. It added further palm-derived soap forms under ex 3401 11 00 (bars, cakes and shaped forms for toilet use) and ex 3401 20 (other forms), alongside a wider set of palm oleochemicals: further hydrogenated and chemically modified palm oil fractions, crude glycerol and glycerol residues, additional fatty alcohols, and several fatty-acid esters and amines used in surfactant and detergent manufacture. Every one of those newly added entries applies from 30 December 2027, a year after the main EUDR dates, because the Commission had to bring them into Annex I before it could set a compliance date for them at all.

Soap-related entry	Annex I status	Applies from
Soap made with oil palm (original "ex" 3401 entry)	Already in scope	Your main date (below)
Glycerol ≥95% purity, synthesised using oil palm (ex 2905 45)	Already in scope	Your main date (below)
Industrial fatty acids and fatty alcohols synthesised using oil palm (ex 2915/3823 entries)	Already in scope	Your main date (below)
Further soap forms — bars, cakes, shapes, other forms (ex 3401 11 00, ex 3401 20)	Added by (EU) 2026/2102	30 December 2027
Further fatty alcohols, esters and amines (ex 2905 16/17/19, ex 2916 15/19, ex 2921 19, ex 2923 90, ex 2924 19)	Added by (EU) 2026/2102	30 December 2027
Crude glycerol, glycerol waters and lyes from palm processing (ex 1520 00)	Added by (EU) 2026/2102	30 December 2027

A soap manufacturer buying a broad palm oleochemical range can be running two dates against the same supplier: a standard saponified palm base due on the main date, a newer surfactant intermediate from the same refinery due more than a year later. The full Annex I changes cover every addition and removal the delegated act made, across all seven commodities, not just palm.

Palm wax for candles: the classification question that decides it

Ask your wax supplier one question before anything else: what CN code do they declare the wax under. The answer splits into three practical cases.

Classified under heading 3404 (other artificial and prepared waxes). This is where most wax marketed specifically for candle-making sits — it has typically been fractionated, hydrogenated, blended or otherwise processed past the point of being recognisably palm oil or a simple vegetable wax. Heading 3404 does not appear anywhere in Annex I's oil palm list. A wax genuinely classified here is not an EUDR relevant product, whatever the feedstock, and buying it does not make you an operator for that purchase.

Classified under heading 1521 (vegetable waxes). Also not in Annex I's oil palm list. A less-processed palm wax that customs still treats as a vegetable wax in its own right, rather than as palm oil, palm stearin or a palm oil fraction, sits outside scope on the same basis as the 3404 case — the heading itself was never brought in, in either the original regulation or the 2026 amendment.

Classified under a palm oil heading that is in Annex I — crude or refined palm oil fractions (1511), hydrogenated, inter-esterified or chemically modified palm oil (1516, newly in scope from 30 December 2027), or declared as the underlying palm stearin rather than a finished wax. This happens when a candle-wax producer buys hydrogenated palm stearin as a raw material and does the final wax processing itself, rather than buying an already-finished "candle wax" product. Here the purchase is a relevant product, and whoever first places it on the EU market owes the due diligence statement for it.

The practical upshot: if you buy finished palm candle wax from a wax supplier under its own product name, check the CN code on the commercial invoice or customs declaration rather than assuming the word "palm" settles it. If you buy palm stearin or hydrogenated palm oil as a feedstock and process it into wax yourself, you are very likely the primary operator for that input, and the obligation sits with you.

Nothing published on Annex I to date — not the original 2023 text, not Regulation (EU) 2025/2650, not Delegated Regulation (EU) 2026/2102 — adds a dedicated wax heading to the oil palm entries. If that changes at a future Annex I review, it would need a further delegated act, in the same way soap and the other palm oleochemicals were added in 2026. Treat the current position as settled, not as a gap likely to close soon, but re-check Annex I before assuming it still holds a year from now.

If you sell finished candles rather than buying wax as a feedstock

Finished candles fall under HS heading 3406, which has never appeared in Annex I in any form. A candle retailer or brand that buys finished candles from a manufacturer, rather than wax, is not placing an Annex I product on the market and has no EUDR obligation on that line, regardless of what the wax inside was made from. This is consistent with how the September 2026 amendment treated other finished goods — vehicle and aircraft seats and vulcanised-rubber articles came out of scope in the same act, on the principle that Annex I targets commodities and specific intermediate derivatives, not every consumer product downstream of them.

The obligation, where one exists, sits with whoever first places the relevant raw material — the wax or oleochemical itself — on the EU market, typically the wax producer or an importer bringing in palm stearin or hydrogenated palm oil from outside the EU. A candle brand several steps downstream of that import is a downstream operator at most, with a record-keeping obligation to pass on a reference number it was given, not a due diligence statement to file itself.

Who owes the due diligence statement

Regulation (EU) 2025/2650 concentrated the due diligence statement on the first business to place a relevant product on the EU market, rather than requiring everyone in the chain to file separately. In a soap or palm-wax supply chain that is usually one of:

• An EU-based soap manufacturer or oleochemical formulator importing palm derivatives directly from a non-EU refinery — the primary operator, filing for what it imports.
• An EU distributor importing palm stearin, hydrogenated palm oil, or palm-derived glycerol in bulk and reselling it to formulators — also a primary operator on its own import volumes.
• A soap or candle brand buying an already-processed, EU-sourced base from a distributor who has already filed — a downstream operator, recording and passing on the reference rather than filing again for the same goods.

Work this out ingredient by ingredient rather than for the business as a whole. A single soap formulation can combine a palm-derived fatty acid bought directly from an importer with a fragrance base bought from an EU distributor who already filed, and the two lines sit in different roles.

Deadlines by size

Your business	Already-listed palm derivatives (soap, glycerol, fatty acids/alcohols as originally scoped)	2026/2102 additions (further soap forms, fatty alcohols, crude glycerol)
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 follows the Directive 2013/34/EU thresholds: broadly micro 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, large above that. Most independent soap makers and candle businesses sit in micro or small; the refineries and bulk oleochemical distributors that supply them are more often medium or large. The full deadline breakdown covers how role and product history interact with the two dates in more detail, and the micro and small operator simplifications cover what a smaller soap or candle business can skip.

Origin and risk tier

Most palm oil, palm stearin and their derivatives placed on the EU market originate in Indonesia and Malaysia. Neither is on the Commission's benchmarked low-risk list under Implementing Regulation (EU) 2025/1093, so palm-derived soap and wax inputs sit in the default standard risk tier, with the ordinary checking rate for competent authority scrutiny rather than the reduced simplified due diligence available for low-risk origins. Country benchmarking explained covers what the risk tier changes about what your due diligence file needs to show.

What to ask your wax and oleochemical suppliers now

• What CN code is declared for this specific product on your customs paperwork — not the product's marketing name?
• If it's palm stearin, hydrogenated palm oil, or a fatty alcohol or glycerol byproduct, can you provide geolocation for the plantations behind it, down to plot level for production units above four hectares?
• If you sell both a finished "candle wax" product and the hydrogenated palm stearin it's made from, are these genuinely different CN codes, or the same classification under different names?
• Are you the first business placing this ingredient on the EU market, or has an earlier link in the chain already filed a due diligence statement?

Check what the EUDR requires of your specific products rather than assuming "made from palm" is the test — the CN code is.