Guide to EUDR Palm Oil Compliance 

EUDR Palm oil compliance requires full supply chain traceability down to the plantation plot. Exporters, mills, and smallholders must provide polygon geolocation, prove no deforestation after 31 December 2020, and submit a Due Diligence Statement (DDS) in the EU TRACES system. Certifications like RSPO or ISCC may support risk mitigation, but do not replace DDS filings. Special attention is needed for Fresh Fruit Bunch (FFB) agents, who aggregate fruit from smallholders and often break traceability. Digital platforms such as TraceX streamline geolocation, risk assessment, supplier onboarding, and TRACES submissions for audit-ready EUDR Palm oil compliance. 

The EU is one of the largest global importers of palm oil, using it in food, cosmetics, biofuels, and industrial applications. Because palm oil cultivation has historically been linked to large-scale deforestation in Southeast Asia and increasingly in Africa, it is directly targeted under the EU Deforestation Regulation (EUDR). 

For palm oil exporters, this means strict new compliance rules: every shipment must be backed by geolocation data down to the plantation plot, legality verification, and a Due Diligence Statement (DDS) filed in TRACES. 

The risk of non-compliance is severe: rejected consignments, financial penalties, and loss of EU market access. For companies dependent on Europe as a buyer, EUDR palm oil compliance is now business-critical. 

Key Takeaways 

• Palm oil under EUDR must have plantation-level geolocation (polygons), proof of no deforestation after Dec 31, 2020, and a Due Diligence Statement (DDS) filed in the EU TRACES system. Certifications like RSPO/ISCC help but don’t replace DDS. 

• Fragmented farmer data, low digital adoption among smallholders, multiple FFB aggregation points, and high compliance costs create serious risks of shipment rejection and EU market loss. 

• With 40% of global palm oil produced by smallholders, and FFB agents aggregating fruit from hundreds of farmers, traceability often breaks without digital onboarding at this level. 

• TraceX integrates with ERPs, validates GeoJSONs, digitizes FFB agent and farmer data, automates DDS filings via TRACES API, and creates blockchain-backed audit trails — ensuring palm oil supply chains remain compliant and competitive.

What are the Compliance Requirements for EUDR Palm Oil? 

The Importance of Palm Oil in Global Markets 

In recent years, the palm oil industry has faced a multitude of challenges due to its environmental impact. As one of the most widely used vegetable oils globally, palm oil is found in everything from food products to cosmetics. However, its production has been closely linked to deforestation, biodiversity loss, and carbon emissions, particularly in Southeast Asia. This has raised alarms for regulators, consumers, and environmental activists alike.  

Palm oil is a major commodity in global trade, accounting for 35% of the world’s vegetable oil production. 

 Its versatility makes it an essential ingredient in a wide range of products, including: 

• Food:  More than two-thirds (68%) is utilized in various foods, including margarine, chocolate, pizzas, bread, cooking oils, and feed for livestock 

• Cosmetics: 27% is utilized in industrial uses and consumer items like soaps, detergents, cosmetics, and cleaning products 

• Biofuels: 5% is used as biofuels for transport, electricity, or heat. 

Retailers recognize that this is increasingly influencing consumer decisions. From shampoos to laundry soaps and from chocolates to biscuits, brands are working to remove palm oil from their offerings. 

Despite its prevalence, palm oil has earned a negative reputation due to its role in deforestation, particularly in Southeast Asia, where vast tracts of tropical forests have been cleared for palm plantations. 

As the two largest producers of palm oil, accounting for 85% of the world’s palm oil production, Indonesia and Malaysia are significantly affected by the EUDR. These countries account for a substantial portion of the world’s palm oil and biodiesel production. 

According to Global Forest Watch, palm oil production is responsible for 23% of deforestation in Southeast Asia alone. 

Given the scale of the problem, the EUDR represents a much-needed shift towards sustainability. But how can businesses ensure that their palm oil supply chains meet these stringent standards? 

Struggling with EUDR readiness?  

Dive deeper into our blog on EUDR compliance and learn how to stay audit-proof. 

Want to master due diligence under EUDR?  

Read our guide on building a compliant DDS step by step. 

Unlike past sustainability initiatives, the EUDR is not about broad pledges or certification logos — it’s about evidence. 

1. Geolocation of Plantations 
   The regulation requires polygon-level boundaries for every oil palm plot, not just a point on a map or the address of a warehouse. This shift matters: polygons can show exactly where palm grows and whether it overlaps with deforested land. It’s not enough to know “where” — the EU wants to know how much and on what land. 

2. Proof of No Deforestation After Dec 31, 2020 
   This isn’t retrospective sustainability branding — it’s a legal cut-off. Even one hectare cleared after the deadline could compromise an entire lot. Exporters and mills need systems that link harvest volumes to plots that can pass this scrutiny. 

3. DDS Filing in EU TRACES 
   Importers must submit a Due Diligence Statement (DDS) in TRACES, covering legality, risk assessment, and mitigation. This is not just paperwork — it’s a declaration of liability. If data is false or incomplete, the company is accountable, not the tech provider or the farmer. 

Why Certification Alone Is Not Enough 

Schemes like RSPO or ISCC remain valuable, but they are risk-mitigation tools, not substitutes for EUDR compliance. Here’s why: 

• Certifications verify practices at a cooperative or mill level, while EUDR demands farm-level traceability. 

• Certifications often audit management systems, not geospatial polygons or real-time deforestation alerts. 

• Regulators won’t accept “certified” as evidence. They want the underlying data — polygons, legality checks, and documented risk mitigation steps. 

 
The EUDR is forcing a mindset shift: compliance is no longer about trust in labels, it’s about proof in data. Certifications can open the door, but polygons and DDS filings are what let your shipment pass through it. 

What are the Challenges Faced by Palm Oil Agribusinesses in EUDR Compliance 

1. Fragmented Farmer Data & Missing Geolocation 
   Most smallholder plots are not digitally mapped. Records sit in notebooks, SMS logs, or with informal middlemen. Without clean polygon-level geolocation, shipments risk rejection in TRACES. 
   Compliance isn’t about gathering more data, it’s about structuring and validating the right data. 

2. Low Digital Adoption Among Smallholders 
   Many farmers lack smartphones, GPS tools, or connectivity. This makes capturing and transferring data across thousands of suppliers nearly impossible through manual systems. 
   The real innovation isn’t fancy dashboards for buyers — it’s farmer-first tools that work offline and bridge the last mile. 

3. Complex Supply Chains With Multiple Aggregation Points 
   Fresh Fruit Bunch (FFB) agents and middlemen mix fruit from compliant and non-compliant farms. By the time it reaches the mill, the original trail is often broken. 
   Traceability has to start at the source; if you wait until the mill, you’ve already lost the chain of custody. 

4. High Costs of Compliance for Smallholders & Exporters 
   Mapping, training, audits, and reporting are expensive. For exporters, scaling this across thousands of suppliers feels overwhelming. For smallholders, it feels exclusionary. 
   The real risk isn’t just cost, it’s exclusion. Without digital solutions that lower the barrier, millions of smallholders could be locked out of the EU market. 

This is where technology changes the game. A platform like TraceX turns these barriers into building blocks, digitizing farmer data, validating polygons, capturing FFB transactions, and automating DDS filings, so exporters stay compliant while smallholders stay included. 

What is the Role of Smallholders and FFB Agents in Palm Oil EUDR Compliance 

Roughly 40% of the world’s palm oil is grown by smallholder farmers cultivating a few hectares each, often with limited resources and little exposure to digital tools. They are critical to the industry, but also the most vulnerable under the EU Deforestation Regulation (EUDR). 

Because smallholders usually don’t sell directly to mills, their harvest flows through Fresh Fruit Bunch (FFB) agents, informal aggregators who collect fruit from dozens or even hundreds of farmers. This is where the risk emerges: 

• Mixing compliant and non-compliant fruit: A farmer with verified, deforestation-free plots can see their fruit mixed with that of a farmer lacking geolocation data. 

• Poor record-keeping: Agents often operate with paper notes or no records at all, breaking the link between product and origin. 

The result? By the time FFBs reach the mill, the traceability chain has already collapsed. Even if exporters want to file a Due Diligence Statement (DDS), they lack the farm-level evidence required. 

The success of EUDR compliance in palm oil doesn’t depend on the biggest mills or exporters — it depends on whether we can digitally onboard FFB agents and connect them to smallholders. Without them, the chain of custody is incomplete, and the EU market is at risk. 

Platforms from TraceX solve this last-mile problem by digitizing FFB transactions, mapping them to verified smallholder plots, and ensuring the chain of custody remains intact all the way to EU filing. 

RSPO and EUDR 

The RSPO is an international coalition aimed at ensuring sustainable palm oil production. The efforts of the RSPO align well with the objectives of the EUDR, both focused on halting deforestation. For this reason, the RSPO has backed the EUDR concept since it began. At the same time, the RSPO acknowledges potential adverse consequences of the regulation, including the risk of independent smallholder farmers being sidelined from the European market and the creation of alternative supply chains. 

Empowering Smallholders with Technology 

One of the key solutions to this challenge is digital farmer engagement platforms that help smallholder farmers adopt sustainable practices and track their progress. Through mobile apps and cloud-based platforms, farmers can receive training, access to financing, and real-time data on their environmental impact. This not only helps them meet EUDR standards but also improves their productivity and livelihoods. 

Economic Benefits of EUDR Compliance for Agribusinesses 

While complying with EUDR may seem like an additional burden for businesses, it also offers substantial economic benefits. By aligning with sustainability standards, companies can unlock new market opportunities, particularly in Europe, where consumers are increasingly demanding eco-friendly products. 

Additionally, adopting sustainable palm oil practices can lead to long-term savings by reducing environmental damage and improving soil health. Companies that lead in sustainability are also better positioned to attract investment and form strategic partnerships with NGOs and government bodies focused on environmental conservation.

How Digital Platforms with TraceX Help 

EUDR compliance is complex because it spans multiple players — farmers, FFB agents, mills, exporters, and EU importers. Manual systems can’t keep up. This is where digital platforms like the EUDR Compliance platform from TraceX transform the process: 

1. Auto-Import Supplier & Farm Data from ERP 
   Instead of re-entering supplier and transaction details, TraceX integrates with ERP systems to pull master data directly. This ensures consistency and saves hundreds of manual hours. 
   Compliance doesn’t have to mean duplication — it should flow seamlessly from the systems you already use. 

2. GeoJSON Validation & Deforestation Risk Checks 
   TraceX validates farm polygons for geometry errors and runs checks against EU deforestation datasets. This means only verified plots feed into Due Diligence Statements (DDS). 
   One invalid polygon can freeze a shipment at port — pre-validation prevents that risk. 

See how a Nigerian trading firm turned EUDR challenges into compliance success with TraceX. 

Read the full case study. 

3. Digital Onboarding for Smallholders & FFB Agents 
   The “last mile” is often the weakest. TraceX provides mobile-first tools so FFB agents and farmers can capture geolocation and transaction data, even offline. 
   True compliance isn’t top-down — it starts at the farm gate. 

4. DDS Automation + TRACES API Integration 
   Once data is validated, TraceX auto-generates DDS filings and submits them directly into the EU TRACES system. Importers get instant reference numbers and status updates. 
   Compliance in minutes, not weeks — and with no double data entry. 

5. Blockchain-Backed, Audit-Ready Records 
   Every transaction, certificate, and geolocation record is immutably logged. This creates a tamper-proof trail that regulators and buyers can trust. 

In an era of scrutiny, trust comes from evidence — not promises. 

With TraceX, palm oil exporters and importers don’t just stay compliant — they stay competitive. Compliance becomes a growth driver, opening access to EU buyers who demand deforestation-free supply chains.

Turning Palm Oil Compliance into Competitive Advantage 

EUDR Palm oil compliance is not just about avoiding penalties; it’s about building trust, ensuring market access, and securing the livelihoods of smallholders. By investing in traceability, digitizing supply chains, and onboarding FFB agents, exporters can transform compliance into an opportunity. With digital platforms like TraceX, achieving audit-proof DDS filings and EU market readiness becomes faster, easier, and more reliable. 

Don’t let bad polygons block your shipment.  

Read our blog on common GeoJSON errors and how to fix them before filing. 

Confused about DDS filing?  

Our step-by-step blog shows you exactly how to submit EUDR DDS in TRACES 

Traceability starts at the farm gate.  

Read how to onboard smallholder suppliers into your EUDR workflow. 

Frequently Asked Questions (FAQ’s)