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

Summary

Commodity Oil palm In scope palm nuts and kernels, palm oil and its fractions, palm kernel and babassu oil, oilcake residues, glycerol at 95 per cent purity or more, palmitic and stearic acid and their salts and esters, industrial stearic, oleic and other fatty acids, industrial fatty alcohols Out of scope the finished detergent or cleaning preparation, because Chapter 34 is not in Annex I Applies from 30 December 2026, or 30 June 2027 for qualifying micro and small undertakings You must collect the eight categories in Article 9(1), on the derivative rather than on the bottle

The Annex I lines this rests on

Under the relevant commodity Oil palm, quoted from the annex as published. Check the consolidated Regulation before relying on a line.

1207 10 Palm nuts and kernels 1511 Palm oil and its fractions, whether or not refined, but not chemically modified 1513 21 Crude palm kernel and babassu oil and fractions thereof 1513 29 Palm kernel and babassu oil and their fractions (excluding crude oil) 2306 60 Oilcake and other solid residues of palm nuts or kernels ex 2905 45 Glycerol, with a purity of 95 % or more (calculated on the weight of the dry product) 2915 70 Palmitic acid, stearic acid, their salts and esters 2915 90 Saturated acyclic monocarboxylic acids, their anhydrides, halides, peroxides and peroxyacids and their derivatives, excluding a named list that includes palmitic and stearic acid, their salts and esters 3823 11 Stearic acid, industrial 3823 12 Oleic acid, industrial 3823 19 Industrial monocarboxylic fatty acids; acid oils from refining (excluding stearic acid, oleic acid and tall oil fatty acids) 3823 70 Industrial fatty alcohols

Three of these carry limits inside the line, and a business reading only the code will miss all three.

ex 2905 45 has a purity threshold. Glycerol is in scope at 95 per cent purity or more, calculated on the weight of the dry product. Below that it is not this line. So the same substance can be in or out on a specification, which means the specification is now a compliance record.

2915 90 and 3823 19 are written as exclusions. 2915 90 excludes, among others, palmitic and stearic acid and their salts and esters, because those are 2915 70. 3823 19 excludes stearic acid, oleic acid and tall oil fatty acids, because the first two are 3823 11 and 3823 12. Reading either line on its own gives the wrong answer; they only make sense as a set.

1511 covers palm oil not chemically modified. Chemical modification moves the product to a different heading, and whether that heading is listed is the question rather than whether palm is still in it.

Why the finished detergent is out, and what follows

A liquid detergent is Chapter 34. It is not in Annex I, so placing it on the market is not placing a relevant product on the market.

What is in scope is the fatty alcohol or the stearic acid you buy to make it. Three positions follow, and they are genuinely different:

1. You import a palm-derived chemical into the Union. You are the operator placing a relevant product, and the obligation is yours in full.
2. You buy that chemical inside the Union and formulate. It was already placed on the market. Your question is whether your supplier discharged the obligation, which is a contract question rather than a due diligence statement of your own.
3. You import the finished detergent. No relevant product is placed by you. The deforestation exposure is still in your product and a retailer will still ask.

The second case is the common one and the one most often mishandled, because the answer feels like "not us" and the commercial consequence is the opposite.

What you have to collect

Where you are the operator, Article 9(1) applies in full: the product description including trade name, type and species name; the quantity; the country of production and parts of it; the geolocation of all plots of land where the oil palm was produced with the date or time range of production; supplier and customer names and contact details; and the information demonstrating the commodity is deforestation-free and was produced in accordance with the law of the country of production.

The hard part for derivatives is that point (d) asks for the plot, and a fatty alcohol has been through a refinery and a splitting plant since the plot. Mass-balance and segregation models change what you can say about which plot a given batch came from, and that is a chain-of-custody question: chain of custody models. The precision the Regulation asks for is on how precise a plot geolocation has to be, and the four-hectare polygon threshold applies to oil palm.

If you also sell wooden or rubber goods

A cleaning products business with brushes, handles or packaging may be in wood as well: see wood products under EUDR, and note that the 4415 packing-material carve-out may take your own outer packaging out while leaving a wooden product in.

What this page does not do

It does not classify your chemical, and here the classification carries a purity threshold, so it is less of a formality than usual.

It does not restate the unpublished amendment: does the July 2026 change to Annex I apply yet.

It does not cover the detergents Digital Product Passport or the ingredient-disclosure rules, which are a different regime owned by the detergents category page.

What would change this answer

Recheck if:

• Annex I is amended in a way that touches a chapter 15, 23, 29 or 38 line, which is where

the July 2026 delegated act is reported to be active;

• the glycerol purity threshold changes;
• the application dates in Article 38 move.

Last verified 12 September 2026.

Sources and legal basis

• Regulation (EU) 2023/1115, consolidated text
• Regulation (EU) 2023/1115 as published, OJ L 150, 9.6.2023