EUDR and cosmetics: palm ingredients in Annex I

• On 17 September 2026 the Official Journal published Commission Delegated Regulation (EU) 2026/2102, which amends Annex I of Regulation (EU) 2023/1115 on deforestation-free products (EUDR). It entered into force the following day.
• The amendment clarifies that the glycerol, palmitic and stearic acids, their salts and esters, and the industrial fatty acids and alcohols listed in Annex I fall within the EUDR only when they "have been synthesized using oil palm". A new note specifies that oil palm means the genus Elaeis.
• From 30 December 2027, new palm derivatives are added: hydrogenated oils, lauryl, cetyl and stearyl alcohol, oleic acid, amines, quaternary ammonium salts, amides and soap.
• Perfumes, make-up and hair or bath preparations (chapter 33 of the Combined Nomenclature) are not listed in Annex I, either in its original version or after this amendment.

1. What was published

Delegated Regulation (EU) 2026/2102 was adopted on 13 July 2026 and published in the Official Journal on 17 September. Its Article 1 is a single sentence: Annex I to Regulation 2023/1115 is amended in accordance with its Annex. Its Article 2 sets entry into force on the day following publication.

Recital 2 summarises what it does: it introduces limited and targeted technical fixes to give legal certainty on which products are covered, adds and removes products in light of trade, environmental and economic data, and prevents derived products of the covered commodities from reaching the Union market without complying with the Regulation.

2. How the EUDR decides which products it covers

The EUDR covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood. Not everything that contains one of them is covered, though. Article 2, point 2, defines "relevant products" as products listed in Annex I that contain, have been fed with or have been made using those commodities.

Annex I is a table of codes from the Combined Nomenclature, the EU customs classification set up by Regulation (EEC) No 2658/87. A product without a code in that table is not a relevant product, even if it contains palm or cocoa among its ingredients. Chapter 33, where perfumes, make-up and hair and bath products are classified, does not appear in the table. This annex is not one of the annexes of the Cosmetics Regulation, which regulate which substances a cosmetic may contain, not where they come from.

What does appear are several raw materials used in cosmetics. The original annex lists, for example, cocoa butter (1804), soya-bean oil (1507) and, under oil palm, palm oil (1511), palm kernel and babassu oil (1513 21 and 1513 29), glycerol (ex 2905 45), palmitic and stearic acid with their salts and esters (2915 70), and industrial fatty acids and alcohols (3823 11, 3823 12, 3823 19 and 3823 70).

3. Oleochemicals: "synthesized using oil palm"

Several of those codes describe products that do not depend on one specific raw material. The stearic acid of code 2915 70, for example, can be obtained from palm, but also from other vegetable or animal fats. In the original version, most of those entries did not carry the "ex" prefix, which means that only part of the code is covered; glycerol already did.

Recital 7 of Regulation 2026/2102 addresses it: several codes listed under "Oil Palm" and "Rubber" encompass products that can be manufactured with commodities that are not relevant commodities, so it is necessary to clarify that those products fall within the scope of the Regulation only in so far as they are produced using a relevant commodity, by the addition of "ex" in front of several entries.

The rewritten entries read as follows, all with the condition "that have been synthesized using oil palm":

From 30 December 2027, cetyl alcohol, stearyl alcohol and oleic acid also get their own entries as separate chemically defined compounds (section 4).

A new note in the commodity column, note 2, reads: "This Regulation applies to oil palm of Elaeis spp. (including Elaeis guineensis). It does not apply to babassu oil from genus Attalea spp. (including Attalea speciosa) and other vegetable oils from other palm tree species." The descriptions of entries 1513 21 and 1513 29, and of the new 1516 20 and 1518 00, still mention babassu.

4. What is added from 30 December 2027

Recital 8 is about oleochemicals: compounds derived from natural oils and fats that are used as raw materials or intermediates in paints and coatings, pharmaceuticals, lubricants and food additives. Annex I did not contain all the palm oil derivatives of that supply chain, and the Regulation adds the following to the oil palm group, all applying from 30 December 2027:

Many of the palm entries, both rewritten and new, also carry an exclusion: they do not apply to the extent that the products are used in the manufacturing of medicinal products for human or veterinary use within the scope of Directive 2001/83/EC, Regulation (EC) No 726/2004 or Regulation (EU) 2019/6 (recital 9). That is the case, among others, for glycerol, palmitic and stearic acid, cetyl and stearyl alcohol and toilet soap. The Regulation provides no equivalent exclusion for cosmetics.

5. Soap

Recital 7 of Regulation (EC) No 1223/2009 lists "toilet soaps" and "deodorant soaps" among the examples of cosmetic products (we cover this in what is a cosmetic product and in our complete guide to Regulation 1223/2009). With entries ex 3401 11 00 (toilet soap) and ex 3401 20 (soap in other forms), soap becomes the only type of product named as a cosmetic by Regulation 1223/2009 that has its own entry in EUDR Annex I.

The condition in those two entries differs from the oleochemical one. It does not say "synthesized using oil palm" but soap "that contain or have been made using oil palm".

6. What is expressly left out

Regulation 2026/2102 adds one general exclusion to the annex, note 5, and several exclusions in specific entries. The ones closest to a cosmetic product:

• Samples of negligible value and quantity, and products that undergo examination, analysis or tests (recital 15 and note 5).
• Single-use packing material of paper, paperboard or wood used exclusively to support, protect or carry another product and presented with it (recital 16 and entries ex 4401, ex 4405, ex 4415, ex 4416 and ex 48). This exclusion concerns the EUDR only: cosmetic packaging has its own rules under Regulation (EU) 2025/40, which we explain in PPWR and cosmetics.
• Marketing and information materials, such as labels, when they exclusively accompany another product or are supplied free of charge for marketing or information purposes (recital 17 and entry ex 48).
• Waste within the meaning of Directive 2008/98/EC, in several entries.

7. Timeline

The rewritten oleochemical entries (section 3) carry no deferred application date.

8. What the INCI name does not tell you

The condition clarified by Regulation 2026/2102 depends on how an ingredient was made: whether it was synthesized using oil palm. That information is not part of the INCI name.

The copy of CosIng maintained by BD-API holds 33,640 active ingredients (measured on 8 October 2026). Of those, 116 carry "Elaeis" or "Palm" as a word or root in their name (Palm Oil, Palm Kernel, Palmate, Palmamide…), not counting palmitic acid derivatives. And not all of them refer to oil palm: Euterpe Oleracea Palm Heart Extract comes from the açaí palm heart.

The reverse also happens. Glycerin, Cetyl Alcohol, Stearic Acid or Behentrimonium Chloride describe a chemical identity, and the same name is used whatever the starting fat. Isopropyl Palmitate carries "palm" in its name because of palmitic acid, which can be obtained from different fats. Any of these names can be looked up in the BD-API CosIng search.

9. Frequently asked questions

Does the EUDR apply to cosmetics? Perfumes, make-up and hair and bath preparations (chapter 33) are not listed in Annex I. Soap is listed from 30 December 2027, when it contains or has been made using oil palm. Several cosmetic raw materials, such as cocoa butter, soya-bean oil or certain palm derivatives, are listed in the annex under their own codes.

Is glycerin covered? Code ex 2905 45 covers glycerol with a purity of 95 % or more that has been synthesized using oil palm, except to the extent that it is used in the manufacturing of medicinal products for human or veterinary use.

What about babassu? Note 2 to Annex I, added by Regulation 2026/2102, says the Regulation applies to oil palm of Elaeis spp. and that "it does not apply to babassu oil from genus Attalea spp.". The descriptions of entries 1513 21, 1513 29, 1516 20 and 1518 00 still mention babassu.

When does it apply? The general EUDR obligations apply from 30 December 2026, and from 30 June 2027 for operators that are natural persons, micro-undertakings or small undertakings, except for the products covered by the Annex to Regulation (EU) No 995/2010. The new entries of Regulation 2026/2102 apply from 30 December 2027.

Where is the official text? On EUR-Lex: Regulation (EU) 2023/1115, Regulation (EU) 2025/2650 and Delegated Regulation (EU) 2026/2102. The Commission publishes information on the EUDR information system, where statements are submitted.

10. In short

Regulation 2026/2102 does two things with palm derivatives. It clarifies that the oleochemicals already in Annex I count only when they have been synthesized using oil palm of the genus Elaeis. And it adds, from the end of 2027, new palm derivatives, soap among them. Chapter 33 cosmetic products remain outside Annex I; several of their raw materials do not.

Disclaimer. This article is for information only and does not constitute regulatory or legal advice. It describes the scope of Annex I to Regulation (EU) 2023/1115, not the obligations of each operator. The customs classification of a specific product depends on its characteristics and cannot be inferred from its INCI name. Only the text published in the Official Journal of the European Union is legally binding.