EUDR for soya and animal feed businesses: what's actually in scope

Soya beans, soya bean flour and meal, soya-bean oil and soya oilcake are all in Annex I of the EUDR, which covers the raw and intermediate soya materials a feed mill buys. Compound and mixed animal feed itself — the finished product, classified under CN 2309 — is not in Annex I and carries no EUDR obligation of its own. The obligation sits with whoever first places the Annex I material on the EU market, typically before it is blended into feed.

Which soya products are actually in Annex I

The EUDR applies only to products whose CN code appears in Annex I of Regulation (EU) 2023/1115. For soya, that list is short and specific:

Product	CN code	In scope
Soya beans, whether or not broken	1201	Yes
Soya bean flour and meal	1208 10	Yes
Soya-bean oil and its fractions, not chemically modified	1507	Yes
Oilcake and other solid residues from soya-bean oil extraction (soybean meal)	2304	Yes
Soya beans for sowing (seed use)	ex 1201	No, since September 2026
Compound and mixed animal feed preparations	2309	No

The product most feed businesses actually handle in volume is CN 2304 — the high-protein oilcake left over after oil extraction, universally called soybean meal in the feed trade. That is squarely in Annex I. So is CN 1208 10, a separate, lower-volume soya flour and meal product that is not the same material as 2304 despite the similar name.

Why the finished feed itself isn't the regulated product

This is the detail that catches compounders out. The Commission considered adding compound feed preparations (CN 2309) to Annex I during drafting and decided against it, so a bag of finished cattle, pig or poultry feed is not itself a relevant product under the regulation, however much Annex I soya or palm material it contains. FEFAC, the EU compound feed manufacturers' federation, has issued a professional recommendation to its members on exactly this point, covering the two feed materials it affects most directly: soybean meal and palm oil co-products.

That does not mean compounders are outside the regulation's reach. It means the due diligence statement has already had to be filed, further up the chain, by whoever first introduced the soybean meal, flour or oil onto the EU market as an Annex I product. A feed mill that imports crude soybean meal directly from a non-EU crusher is that first operator itself. A feed mill that buys meal from an EU-based trader or crusher who has already filed the statement is not — but it still has to be able to show that the material it bought was covered by one, because EUDR record-keeping rules require operators to be able to trace what they placed on the market, or relied on having been placed, for at least five years.

Who is the operator in a soya-to-feed chain

The regulation's operator/trader split, set out in Article 2, decides who actually has to file:

• The first operator is whoever first makes the Annex I soya product available on the EU market or uses it for their own commercial activity — usually an EU-based importer, crusher or trading house bringing soybeans, meal or oil in from a non-EU country.
• Downstream traders, including most feed compounders buying already-placed meal from an EU supplier, do not need to file their own due diligence statement for that material. Do downstream operators and traders still need a due diligence statement? covers this distinction in full — it is one of the points the 2025 amendment changed.
• An EU farmer growing soya and selling it as a raw material inside the EU is not placing an imported product on the market in the sense Annex I is aimed at, but EU-grown soya is a small share of what EU feed uses; most tonnage is imported.

Get this wrong in either direction and you either file a statement nobody asked you to duplicate, or assume someone upstream filed one when they did not.

Soya beans for sowing: now explicitly out

Commission Delegated Regulation (EU) 2026/2102, in force since September 2026, removed soya beans intended for sowing from Annex I. This matters only to seed suppliers, not to feed businesses — soya bought for crushing into meal or oil, or fed whole, was never affected by this change and remains in scope on the same terms as before. What changed in Annex I under Delegated Regulation 2026/2102 covers the full set of additions and removals the act made, including changes to cattle and rubber products that have nothing to do with soya.

Where the soya actually comes from changes how much due diligence you do

Country benchmarking under Implementing Regulation (EU) 2025/1093 sets one risk tier per country, applied across all seven EUDR commodities — it does not set a separate tier for soya specifically, but the tier a soya-exporting country sits in still decides how much work your due diligence is.

Origin	Risk tier	What it means for a soya importer
United States	Low	Simplified due diligence: no risk assessment or mitigation step required by default
Brazil	Standard	Full due diligence, including risk assessment and mitigation
Argentina	Standard	Full due diligence, including risk assessment and mitigation
Paraguay	Standard	Full due diligence, including risk assessment and mitigation

This is not a minor detail for soya specifically: Brazil is the EU's largest single supplier of soybean meal, with roughly 56% market share as of late 2025 according to USDA Foreign Agricultural Service trade data, and the EU imports around 19–20 million tonnes of soybean meal a year. Most of that tonnage therefore sits in the standard-risk tier, not the low tier, which means the simplified route available under Article 13 is the exception for soya sourcing, not the rule. EUDR country benchmarking explained sets out what standard risk actually requires in practice and how the 1%, 3% and 9% competent authority check rates apply.

Geolocation: still plot-level, whatever the final product looks like

Soya does not get a commodity-specific geolocation simplification the way cattle does. Every plot the soya was grown on needs a geolocation point if it is 4 hectares or smaller, or a polygon if larger, under the standard rule set out in EUDR geolocation requirements. For a crusher or trader blending soya from many smallholder farms into one shipment of meal, that means the geolocation data has to survive aggregation — a single due diligence statement covering a mixed-origin shipment still has to reference every plot of origin, not an averaged or representative one.

When you actually have to file

Operator type	Deadline
Large and medium operators and traders	30 December 2026
Micro and small operators whose products were already under the EU Timber Regulation	30 December 2026
Other micro and small operators (most soya-handling feed businesses)	30 June 2027

Soya was never a timber-regulation product, so the size test that matters for most feed mills and compounders is the general one, not a timber carve-out. Which EUDR deadline applies to you walks through the staff, turnover and balance-sheet thresholds under Directive 2013/34/EU that decide your size band. The European Commission's May 2026 simplification review (COM(2026) 191) confirmed both dates are holding and did not reopen them — the review's changes were to process and guidance, not to the timeline.

What to collect from a soya supplier

A request for "your EUDR paperwork" gets a shrug. A request for this gets a usable answer:

1. Confirmation of which Annex I CN code the shipment is sold under (1201, 1208 10, 1507 or 2304), since that is what determines whether it is in scope at all.
2. Geolocation points or polygons for every plot of origin, not an aggregate region.
3. Confirmation the soya was produced on land that was not deforested or degraded after 31 December 2020.
4. Evidence of lawful production in the country of origin — land use permits, land tenure, and compliance with local environmental and labour law.
5. If your supplier is not the first operator, confirmation that a due diligence statement was already filed for that specific shipment, with a reference you can hold against your own five-year record-keeping obligation.

Where a trader cannot produce plot-level geolocation because the shipment has already been pooled across multiple farms with no record kept of which, that is a sourcing risk to address now, not a gap to paper over with a country-level assurance.

Check what the EUDR requires for your soya or feed business and get a dated list of what to ask suppliers for, rather than working it out shipment by shipment.