National authorities must work together to ensure consistent enforcement of EUDR
01/10/2026 (Oils & Fats International) - With the EU Deforestation Regulation (EUDR) coming into force from 1 January, national authorities need to be aligned to prevent palm oil entering Europe through more lenient entry points, the OFI Commercial/Technical conference heard in Amsterdam last week.
The conference was one of four held under one roof from 21-23 September at the OFI International 2026 show, which attracted more than 350 people from over 30 countries.
“The EUDR is a welcome and loved baby but its delivery has been long and painful,” said Ruben Brunsveld, deputy director, market transformation EMEA, the Roundtable on Sustainable Palm Oil (RSPO).
Originally due to take effect on 30 December 2024, the EUDR has been delayed twice but is now set to come into force for large- and medium-sized companies on 1 January, and for small and micro operators on 30 June 2027.
Companies placing palm oil, soya, cocoa, coffee, cattle, rubber or timber goods on the EU market will need to have a functioning due diligence system to prove these commodities are deforestation-free, legally produced and traceable to their source.
Brunsveld told the conference that while RSPO certification did not substitute an operator’s due diligence responsibilities, it could demonstrate compliance in required risk analysis, traceability and National Competent Authority (NCA) checks.
He identified three outstanding issues in the implementation of the EUDR – data sharing, the new Annex 1 to the EUDR, and different national approaches to implementation.
Data sharing: Under the EUDR, companies will need to submit due diligence statements (DDSs) into an EU information system, throwing up questions on who owns the data, who has access to it, and the protection of sensitive commercial information.
Annex 1: The July 2026 revision of Annex I - which determines which products fall within the EUDR - removed some products from scope and added others, including certain palm oil derivatives. The new products would become subject to the EUDR from 30 December 2027, and it remained to be seen how companies would respond to this, Ruben said.
National implementation: While the EUDR is an EU law, it is up to each country’s NCA to enforce it.
Ruben said NCAs needed to be aligned to prevent different entry points into Europe, especially if some NCAs were more lenient in enforcing the EUDR than others.
Marieke Leegwater, senior policy advisor at Solidaridad, added that there was increasing evidence that smallholders were being excluded from EU value chains because of lack of documentation and the complexities of organising data; and it was often unclear how farmer data ownership would be protected.
“For palm oil, smallholders are being pushed out of value chains to Europe. It started with the RSPO and the EUDR has made it worse.”
European palm oil volumes were now mostly supplied from bigger estates and a solution needed to be found to include smallholders, she said.
- EU-Indonesia palm oil trade
Relating to palm oil, Frans Claassen, managing director of MVO – the Netherlands oils and fats industry association – said the new the EU-Indonesia Comprehensive Economic Partnership Agreement (CEPA) could make Indonesian palm oil significantly more attractive for the EU.
“CEPA will introduce annual duty and levy-free export quotas for Indonesian palm oil to the EU. The quota starts with 1.9M tonnes and increases by 3% for nine consecutive years.”
The agreement – set to come into force in early 2027 – would abolish current 3.8% EU import duties on crude palm oil (CPO); 12.8% duties on solid fractions (immediate packings, maximum 1kg); 10.9% of ‘other’ solid fractions; 5.1% duties on refined/bleach/deodorised (RBD) palm oil or palm olein for non-food applications; and 9% duties for ‘other’ RBD palm oil or palm olein.
Claassen explained that Indonesia accounted for a 10% share of total EU CPO imports of 1.68M tonnes in 2025, and a 51% share of the EU’s total processed palm oil imports of 1.46M tonnes that year, giving it a 29% share of total EU imports of palm oil.
At the Indonesian September 2026 palm oil reference price of US$1,007.51/tonne, CEPA would remove US$268.90/tonne in export duties and levies on CPO, and US$176.75/tonne of export duties and levies on RBD palm oil, which could make Indonesian CPO significantly more attractive for the EU.
However, the actual benefits fully depended on how Indonesia allocated the quotas, and European processors needed clarity on the practical operation and allocation of quotas “without delay”, Claassen said.
Dr Fadhil Hasan, senior economist and head of foreign affairs at the Indonesian Palm Oil Association (GAPKI), said that CEPA was in the process of ratification in Indonesia and would be passed in March.
On policy changes related to palm oil, Dr Hasan said the country’s new state-owned entity - Danantara Sumberdaya Indonesia (DSI) – had been set up to improve governance in export activities and export earnings management, and to eliminate the risk of under-invoicing and transfer pricing.
“DSI is not the sole exporter of palm oil and other products.”
The government was also setting up a commodity exchange to make and strengthen palm oil price discovery.
And there was a shift in Indonesia’s mandatory biofuel blending programme to emphasise energy security, rather than as instrument to stabilise palm oil prices.
Dr Hasan added that due to strong El Niño effects this year, palm oil production would fall by 4-5M tonnes in 2027. Domestic consumption would increase by around 2M tonnes next year due to full B50 palm oil-based biodiesel mandatory blending, and exports would therefore decline next year.
Vegetable oil squeeze
Artem Hammerschmidt, head of vegetable oils and biofuels research at Cefetra Analytics, also spoke of a “major vegetable oil squeeze” in the next two years.
He said surging energy prices had strengthened the economic case for biofuels, raising the demand outlook for oils and fats.
In the USA, mandate-driven output requirements would rise by around 3M tonnes in 2026 and another 2M tonnes in 2027, forcing US biodiesel/HVO and SAF producers back into imported oils and fats. Indonesia’s palm oil use for biodiesel, driven by its B50 biodiesel mandate, was also set to lift domestic palm oil use for biodiesel to 16.8M tonnes, curtailing exports.
Hammerschmidt said total oils and fats requirements for FAME, HVO and SAF in 2025 totalled 58.9M tonnes but were forecast to jump by 6-7M tonnes in 2026 and by another 7M tonnes in 2027 to total 72.5M tonnes.
“The challenge is not absorbing one exceptional increase but doing so for two consecutive years.”
With El Niño setting the stage for a major vegetable oil squeeze, global production of oils and fats was expected to fall by 0.3M tonnes in 2026/27, exports could fall by 0.8M tonnes and stocks could plunge by 3.3M tonnes as demand jumped 5.7M tonnes, he said.
Limited global supply of used and waste oils also meant Europe would increasingly rely on rapeseed oil as a biofuel feedstock, with producers having to pay more for used cooking oil (UCO) as suppliers would need to go further afield to find and collect new supplies.
UCO
Because UCO is increasingly used as a raw material for biofuels, the EU was introducing new requirements for UCO imports, explained Steven Danneel, Coordinating Senior Inspector, Animal By-products, Tactical Direction & Expertise Division, Directorate Enforcement, of the Netherlands Food and Consumer Products Safety Authority (NVWA).
- Danneel told the OFI Commercial/Technical conference that UCO could originate from vegetable oils such as soyabean and palm oils, or animal-based sources such as tallow.
Under the new rules, due to come into force on 19 November 2027, UCO containing or consisting of animal-origin material would be considered as Category 3 material under the EU Animal By-products (ABP) regulation.
The imported ABP UCO had to originate from an ABP-approved or registered operator in the third country, which would be an issue, he said.
This was because UCO may be collected from many small sources; authorities in the exporting country would have to oversee the different operators and provide relevant information for EU purposes; and existing UCO supply chains may not be structured for this.
- Danneel added that as it was not always possible to test if UCO came from animal origins, traceability would need to be document-based, rather than from analysis of the product.
- The OFI Commercial/Technical Conference was organised by Oils & Fats International (OFI) and MVO - The Netherlands Oils and Fats Industry association.
- The conference and the OFI International 2026 show, held at the Amsterdam Congress Centre, was supported by the Netherlands Oils, Fats and Oilseeds Trade Association (NOFOTA) and FOSFA International. The event also featured a major exhibition of suppliers to the oils and fats industry and three other conferences organised by the German Society for Fat Science (DGF); Euro Fed Lipid (EFL) and Triact.