akar.earthCattle, Leather and Soy Under the EUDR: Indonesian Exposure
EUDR cattle and soy rules from an Indonesian view: limited direct exposure, where leather goods, soy imports and feed matter, and what exporters should check.
Cattle and soy are covered by the EUDR, but Indonesia’s direct exposure is small because it is a net importer of soybeans and live cattle and sends little beef or soy to the EU. Where Indonesian companies are exposed, it is mainly through leather and leather products, and through any EU-bound product made from imported soy, where the relevant plots are in the soy’s country of origin, not in Indonesia.
What the EUDR says about cattle and soy
The Regulation covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soy and wood. For cattle, Annex I lists live animals, beef and certain hides, skins and leather. For soy, it lists soybeans and products such as soybean oil and meal. The exact codes are in Annex I, which was updated by Delegated Regulation (EU) 2026/2102. Check Annex I for each product rather than relying on a summary.
Two rules differ for cattle:
- The 4-hectare polygon requirement does not apply to cattle. Geolocation refers to the establishments where cattle were kept.
- Cattle must be traced to all establishments where they were kept, which is harder for animals that moved between farms.
Soy follows the same plot-level rules as the other crops, including polygons for plots over 4 hectares.
Indonesia’s position
| Commodity | Indonesia’s role | EUDR exposure |
|---|---|---|
| Soybeans | Large importer for tempeh, tofu and feed; limited domestic production | Low for exports to the EU; relevant only if soy-derived products are sold to the EU |
| Soybean meal | Imported for poultry and aquaculture feed | Feed is not itself a covered product for the animal raised on it; check Annex I for the feed product |
| Live cattle and beef | Importer of feeder cattle and beef; small domestic herd largely smallholder | Very low for EU exports |
| Hides, skins and leather | Domestic tanneries using local and imported hides | Moderate: leather and some leather products may be covered |
This is a qualitative picture. We do not quote trade volumes here; check the current figures with Indonesia’s statistics agency or trade ministry.
Leather: the main pathway
Indonesia has a leather and footwear manufacturing sector that exports to the EU. If a product’s HS code is in Annex I, the EU importer must file a due diligence statement covering the cattle the leather came from.
For an Indonesian manufacturer, this raises a practical problem: hides often come from several countries, mixed in tanneries. The relevant geolocation is the establishments where the cattle were raised, which may be in Australia, Brazil, the United States or elsewhere. Traceability depends on the hide supplier.
What to do:
- Check whether each export product is listed in Annex I.
- For covered products, map hide sources by country and supplier.
- Ask hide suppliers what EUDR data they can provide.
- Keep EU-bound production on segregated, traceable hides. Mass balance is not accepted.
Soy: mostly an origin-country issue
Soy imported into Indonesia comes from producing countries with their own deforestation risk profile. If an Indonesian company exports a covered soy-derived product to the EU, the plot geolocation must come from where the soy was grown. In practice, few Indonesian soy-based products are sold to the EU in volumes that make this a priority, but food manufacturers should still check their product codes.
The country benchmarking category of the soy’s origin country, not Indonesia’s, then shapes the buyer’s due diligence.
Why this still matters to Indonesian groups
Large Indonesian agribusiness groups sometimes trade soy or meal internationally, or own EU-based subsidiaries. If a group entity places soy or cattle products on the EU market, it is an operator for those products with full duties. See operators and traders.
Companies whose main EUDR exposure is palm oil, coffee, cocoa, rubber or wood should focus there first. See palm oil and the EUDR and wood and the EUDR.
Other covered commodities in Indonesian food exports
Indonesian food exporters should also check whether their products contain other relevant commodities. Biscuits, snacks and instant noodles may use palm oil, and confectionery may use cocoa. A product is covered only if its own code is listed in Annex I, but ingredient suppliers may be asked for data by EU customers who make covered products. See palm oil derived products.
Next steps
Check each product’s HS code, map sources for covered products, and agree data templates with EU buyers. For the wider topic map, see the EUDR hub. To check where your company stands, use our EUDR readiness check or message us on WhatsApp about our EUDR compliance services.
Frequently asked questions
Does the EUDR cover cattle and soy?
Yes. Cattle and soy are two of the seven covered commodities, along with cocoa, coffee, oil palm, rubber and wood. Listed derived products such as beef, hides, leather, soybean oil and soybean meal are also covered.
Is Indonesia a major EUDR risk for cattle and soy?
Direct exposure is limited. Indonesia is a net importer of both soybeans and cattle and exports little beef or soy to the EU. Exposure comes mainly through leather and products made from imported soy.
Are Indonesian leather goods covered?
Certain hides, skins and leather are listed in Annex I. Whether a finished product such as footwear or a bag is covered depends on its HS code. Check Annex I for each product.
Does the polygon rule apply to cattle?
No. The 4-hectare polygon rule does not apply to cattle. For cattle, geolocation refers to the establishments where the animals were kept. Check the Commission guidance for details.