Which Palm Oil Products and HS Codes Fall Under the EUDR

Updated 2026-11-02 · 4 min read · By the akar.earth specialist team

EUDR HS codes for palm oil: crude and refined palm oil, palm kernel oil, kernels, cake and oleochemicals, and how to check Annex I for each Indonesian export.

Under the EUDR, palm products are covered only when their HS code is listed in Annex I of Regulation (EU) 2023/1115, which includes palm oil and its fractions (HS 1511), palm kernel oil (within HS 1513), palm nuts and kernels (within HS 1207), palm kernel oilcake (within HS 2306) and certain palm-derived oleochemicals. Check the current Annex I for the exact subheadings, because the list was updated by Delegated Regulation (EU) 2026/2102.

How Annex I works

Annex I lists “relevant products” by Combined Nomenclature (CN) or HS code, with a description. A product is covered if it falls under a listed code and is made from a covered commodity. If the code is not listed, the EUDR does not apply to that product, even if it contains palm oil.

This makes classification the first compliance step. The HS code on the export declaration from Indonesia and the CN code on the EU import declaration need to match what is filed in the due diligence statement. A wrong code is a common reason for statements being questioned.

Main palm products from Indonesia

We only name the headings we are confident about. For everything else, the safest instruction is to check Annex I for the specific code.

Why derived products are harder

Every covered palm product must be traceable to the plots that grew the fruit, whatever its form. For refined and fractionated oils, that means keeping traceability through:

• Bulking stations, where CPO from several mills is combined.
• Refineries, which run continuous processes and often blend oil from many mills.
• Fractionation, which splits oil into olein and stearin.
• Oleochemical plants, which split triglycerides into fatty acids and glycerol and may blend palm, palm kernel and other oils.

Mass balance is not accepted under the EUDR. A refinery producing EU-bound olein must be able to show which mills, and therefore which plots, supplied the CPO that went into it. In practice, this pushes refiners towards dedicated EUDR lines, batch processing or a fully verified supply base. See segregation.

The Indonesian downstream sector

Indonesia has built a large refining and oleochemical industry, partly through export levies that favour processed products over CPO. This means a high share of EU-bound palm leaves Indonesia as refined oil, fractions or oleochemicals rather than crude oil. For those exports, the Indonesian refinery or oleochemical producer becomes the point where data from many mills must be consolidated.

Steps for downstream producers:

1. List each product exported to the EU with its HS code and check it against Annex I.
2. For covered products, map the mills supplying each production line.
3. Obtain plot-level data from those mills. See palm oil due diligence.
4. Set up segregated tanks and production runs for EU-bound volume.
5. Keep batch records that link output to input mills and plots.

Products that are not covered

If a product’s code is not in Annex I, the EUDR does not apply to it, although EU buyers may still have their own no-deforestation policies. Biodiesel and some finished consumer goods may fall outside Annex I; check rather than assume. Other EU rules, such as those on renewable energy, apply separate requirements to biofuels.

A note on palm kernel products

Palm kernels follow a different route from CPO. Mills sell kernels to crushers, which may be far from the mill and blend kernels from many mills. For EU-bound palm kernel oil or expeller, crushers need mill-level and plot-level traceability for kernels too, not only for CPO.

Next steps

Start with the code. Then work back through the chain to the plot. See palm oil and the EUDR for the supply chain overview and the EUDR hub for the full topic map. For help connecting refinery output to mill and plot data, see our EUDR compliance services or message us on WhatsApp.