The scope of the EU Deforestation Regulation (EUDR) is expanding to cover additional palm-derived products, with important implications for the cosmetics and personal care industry.
Following updates adopted in 2026, several palm-derived chemical ingredients, including certain fatty alcohols, fatty acids, glycerol products, amines and soaps, have been added to or further specified under Annex I of the EUDR.
As a result, the regulation’s impact on cosmetics extends beyond the direct use of palm oil and increasingly reaches processed palm-derived raw materials used throughout cosmetic formulations.
What Is the EUDR?
Regulation (EU) 2023/1115, commonly known as the EU Deforestation Regulation, aims to ensure that relevant commodities and products placed on, made available on or exported from the EU market do not contribute to deforestation or forest degradation.
The EUDR covers seven key commodities:
- cattle,
- cocoa,
- coffee,
- oil palm,
- rubber,
- soy,
- wood,
as well as a range of products derived from these commodities and listed in Annex I.
For companies, determining whether a product falls within scope therefore requires more than identifying the commercial name of a raw material. CN/HS classification and the origin of the material are also key factors.
Why Does the EUDR Matter for the Cosmetics Industry?
Palm oil and palm kernel oil are widely used as feedstocks for numerous ingredients found in cosmetic and personal care products.
With Commission Delegated Regulation (EU) 2026/2102, the EU updated Annex I and expanded or clarified the coverage of a number of palm-derived chemical products.
Palm-Derived Ingredients Relevant to Cosmetics
The updated scope includes or further specifies several product groups relevant to cosmetic formulations.
Fatty Alcohols
Certain oil palm-derived fatty alcohols, including lauryl alcohol, cetyl alcohol and stearyl alcohol, are among the products addressed by the updated Annex I. These substances are commonly used as emollients, consistency agents and formulation aids in cosmetic products.
Fatty Acids
Certain palm-derived fatty acids and their salts and esters are also covered. These include products associated with palmitic and stearic acid, as well as additional palm-derived oleic, linoleic and linolenic acid products added under the updated scope.
Glycerol
Certain palm-derived glycerol products, including crude glycerol and related products, may also fall within the EUDR product scope. This is particularly relevant for cosmetic formulations in which glycerin is widely used as a humectant and functional ingredient.
Amines and Related Derivatives
The expanded list also includes certain oil palm-derived acyclic monoamines, quaternary ammonium salts and related chemical derivatives. Some of these substances may be used in surfactants, hair care ingredients and other functional cosmetic raw materials.
Soaps
Certain soaps containing or manufactured using oil palm have also been added to the updated Annex I product list.
When Will the New Palm-Derived Products Be Subject to EUDR?
It is important to distinguish the general EUDR application dates from the implementation date applying to newly added products.
The general application dates are:
- Large and medium operators: 30 December 2026
- Micro and small operators: 30 June 2027
- Certain micro and small operators previously covered by the EU Timber Regulation: 30 December 2026
However, the European Commission has provided an additional transition period for products newly added through Delegated Regulation (EU) 2026/2102.
Many of the newly covered palm-derived products, including certain fatty alcohols, amines and soaps, will become subject to the EUDR from 30 December 2027.
Companies should therefore assess the applicable CN code and specific Annex I entry for each raw material rather than applying a single compliance date across all products.
What Does the EUDR Require?
Operators placing relevant products on the EU market or exporting them must demonstrate that those products are:
- deforestation-free;
- produced in accordance with the relevant legislation of the country of production; and
- covered by the required due diligence process.
This involves collecting supply-chain information, assessing risk and, where necessary, implementing measures to reduce identified risks.
What Is a Due Diligence Statement?
One of the central EUDR obligations is the submission of a Due Diligence Statement (DDS).
Before placing or exporting an in-scope product, operators must complete the relevant due diligence requirements and submit the required statement through the EUDR information system where applicable.
For cosmetics companies, this means compliance may require more than confirming that an ingredient is palm-derived.
Businesses may also need to determine:
- where the relevant raw material originates;
- how it moves through the supply chain;
- which CN code applies;
- whether required traceability information is available;
- whether suppliers can provide the necessary EUDR documentation.
Why Is Raw Material Traceability Important?
Cosmetic ingredients with the same INCI name may originate from different feedstocks.
For example, glycerin may be derived from palm oil, other vegetable oils, animal sources or synthetic production routes.
Likewise, fatty alcohols and fatty acids can have different feedstock origins.
Therefore, an INCI name alone may not be sufficient to determine whether a raw material falls within the scope of the EUDR.
Companies may increasingly need to obtain information on:
- feedstock origin,
- CN/HS classification,
- manufacturing route,
- palm origin,
- supplier traceability documentation.
What Should Cosmetics Companies Do?
Cosmetic manufacturers, brand owners, importers, distributors and regulatory teams should consider beginning their EUDR readiness work well before the applicable deadlines.
Key actions may include:
- mapping palm-derived ingredients across the product portfolio;
- verifying relevant CN/HS codes;
- assessing Annex I applicability;
- requesting feedstock and origin information from suppliers;
- reviewing supplier traceability documentation;
- preparing internal processes for EUDR due diligence;
- assessing potential DDS obligations;
- identifying alternative raw materials or suppliers where necessary.
For companies using significant volumes of palm-derived raw materials, early supplier mapping and raw material mapping can reduce the risk of supply-chain disruption as the expanded product scope becomes applicable.
What Does the Expanded EUDR Scope Mean for Cosmetics?
The expanded EUDR scope demonstrates that deforestation compliance is increasingly moving beyond finished products and into the upstream chemical and raw material supply chain.
For cosmetics companies using palm-derived fatty acids, fatty alcohols, glycerol, amines or soaps, compliance may therefore require closer coordination between regulatory affairs, procurement, sustainability and supply chain teams.
Early traceability assessments and supplier engagement will be essential for preparing for the expanded EUDR requirements.