Are Palm Derivatives in Detergents in EUDR Scope, and What Do You Collect?

The oil-palm commodity boundary

The amended Annex is not a generic “palm” list. Its commodity treatment is tied to oil palm, Elaeis spp., and excludes other palm species where the legal text says so.

That matters for substances whose commercial name says “palm” but whose botanical origin may not be Elaeis.

Current and amended pathways

The amended Annex retains or revises pathways including codes such as:

• ex 1207 10 00
• ex 1511
• ex 1513 21 and ex 1513 29
• ex 2306 60 00
• ex 2905 45
• ex 2915 70
• ex 2915 90
• ex 3823 11, ex 3823 12, ex 3823 19 and ex 3823 70

The exact Annex descriptions, oil-palm origin requirement and any medicinal-use or waste carve-out must be read with the code. Do not treat the list above as a generic chemical-family rule.

New additions with a later application date

Regulation (EU) 2026/2102 adds further downstream entries whose application is expressly deferred to 30 December 2027, including pathways within:

• ex 1516 20
• ex 1518
• ex 1520
• ex 2905 16, ex 2905 17, ex 2905 19
• ex 2915 39
• ex 2916 15, ex 2916 19 10
• ex 2921 19
• ex 2923 90
• ex 2924 19
• ex 3401 11, ex 3401 20
• ex 3824 99
• ex 3907 29

So “in Annex I” and “applies from the main 2026 EUDR date” must not be treated as the same field.

What does this mean for detergents and soap?

Finished detergent

Do not classify a finished detergent as an EUDR relevant product merely because its formulation contains palm-derived surfactants, glycerol, fatty acids or other palm-linked substances.

Classify the finished product itself. If its CN code is not represented by a current relevant-product entry, the ingredient's supply-chain origin does not on its own create finished-product EUDR scope.

Soap

The 2026 amendment adds specified 3401 soap pathways with a 30 December 2027 application treatment. If the product itself classifies within one of those new entries and satisfies the oil-palm conditions, that can create a future EUDR pathway.

Do not backdate that future addition to 2026.

Separately traded ingredients

If the business places a palm-derived ingredient on the market as its own product, classify that ingredient separately. A substance that is outside the finished detergent's route may still have its own Annex I pathway.

What should a business collect?

Only after current scope, timing and role are established should the EUDR evidence workflow begin. Depending on the applicable pathway and role, that can include supply-chain information, geolocation, production timing and due-diligence statement handling.

Do not ask every detergent supplier for EUDR plot data by default. That creates noise and can obscure the products that need the evidence.

Species and use carve-outs

The amended Annex introduces or clarifies species and use limitations in the palm area. Where an entry contains a medicinal-use carve-out or other explicit exclusion, preserve it in the classification rule. Do not simplify a bounded ex entry into an unconditional code match.

What this page does not do

This page does not decide the customs code for a particular formulation. It owns the worked EUDR boundary for palm-derived substances and detergent/soap products.

Use EUDR scope for the general classification method, the Annex I change owner for version history and the core EUDR page for due diligence and geolocation. For the separate passport question, see detergent ingredient information in the passport.

What would change this answer

A further Annex amendment, a relevant CN change or authoritative clarification of the deferred oil-palm entries would require this page to change.

Sources and legal basis

• Regulation (EU) 2023/1115 and Annex I
• Commission Delegated Regulation (EU) 2026/2102 amending Annex I