Originally published in March 2025; updated September 2026 to reflect the current EUDR application dates.
The EU Deforestation Regulation (EUDR, Regulation (EU) 2023/1115) entered into force in June 2023. After two postponements, the latest by Regulation (EU) 2025/2650, its main obligations apply from 30 December 2026 for large and medium-sized operators and from 30 June 2027 for micro and small enterprises. It requires due diligence showing that palm oil — and six other commodities: cattle, cocoa, coffee, rubber, soya and wood — was not produced on land deforested after 31 December 2020 and was produced in line with the laws of the country of production. For procurement chains supplying European food manufacturers, the documentation requirement is substantially more demanding than what most palm oil buyers were used to.
RSPO MASS BALANCE: HOW IT WORKS AND WHERE IT FALLS SHORT
RSPO (Roundtable on Sustainable Palm Oil) Mass Balance certification allows a certified supply chain to mix certified and uncertified palm oil, tracking the certified proportion administratively rather than physically. Mass Balance has been a common model for European food manufacturers, but the EUDR goes further: it requires geolocation of every plot of land where the commodity was produced. Mass Balance, by design, does not maintain plot-level traceability, and the EUDR does not accept certification as a substitute for the operator's own due diligence.
SATELLITE MONITORING AND GEOLOCATION REQUIREMENTS
| Requirement | RSPO Mass Balance | EUDR |
|---|---|---|
| Plot geolocation | Not required | Required for every plot (polygon for plots over 4 hectares) |
| Deforestation cut-off | RSPO cut-off dates and HCV/HCS assessment | 31 December 2020 |
| Satellite verification | Not required | Common risk-assessment tool (e.g. the JRC global forest cover map as a non-binding reference) |
| Chain of custody | Certified volumes tracked administratively | Compliant product must not be mixed with product of unknown origin |
| Proof of compliance | RSPO certificate | Due diligence statement in the EU Information System |
DOCUMENTATION CHAIN FOR EUDR-COMPLIANT PALM OIL
An EUDR-compliant palm oil supply chain originating from a Malaysian or Indonesian mill typically needs: (1) geolocation data for each plot supplying fresh fruit bunches, including smallholders; (2) a risk assessment showing no deforestation after 31 December 2020 on any supplying plot, often supported by satellite imagery; (3) evidence that production complied with relevant local laws; and (4) a due diligence statement submitted in the EU Information System before the product is placed on the EU market or exported. Certification such as RSPO Identity Preserved or Segregated can help gather this information, but it does not replace the operator's own due diligence.
OPERATIONAL ADJUSTMENTS FOR PROCUREMENT CHAINS
European food manufacturers sourcing CPO or RBDPO through intermediaries should not assume their current RSPO Mass Balance certificates satisfy EUDR obligations — they do not. Segregated or Identity Preserved supply with plot-level geolocation data is the practical route for EU-destined volumes, and it usually costs more than Mass Balance oil. Buyers should confirm early in the RFQ which traceability data their supplier can provide, and XRT can discuss documentation requirements for EU-destined cargoes during the RFQ stage.