+34 603 445 673
Palm oil and its derivatives have been under the scrutiny of European environmental policy for years, but until now that pressure has mainly translated into voluntary certifications such as the RSPO. For cosmetics, that is about to change. Regulation (EU) 2023/1115, known as the EUDR, requires large and medium-sized companies, from 30 December 2026, to demonstrate – through parcel-level geolocation – that their palm-derived raw materials do not come from land deforested after 31 December 2020. Small companies have a somewhat longer deadline, until 30 June 2027.
What has put the regulation on the sector’s radar now is a recent decision: in July 2026, the European Commission expanded Annex I to include a longer list of palm oleochemical derivatives, including fatty acids, fatty alcohols, glycerine, amines and soaps. These are precisely the ingredients behind a large share of the surfactants and emulsifiers in any cosmetic formula. Many brands have not yet realised that their raw-material suppliers now fall under a regulation they previously associated only with palm oil as a food commodity.
What the EUDR is and what it requires you to prove
The EUDR regulates seven raw materials – cattle, cocoa, coffee, palm oil, rubber, soy and wood – and their derived products. It replaces the former Timber Regulation and goes considerably further: rather than requiring only legality of origin, it requires proof that the product is “deforestation-free”.
As a result, any company placing a product covered by Annex I on the European market must submit a due diligence statement (DDS) backed by geolocation data for the plot of cultivation. A third-party certification is not enough: traceability must reach the exact point of origin.
The deadlines every cosmetic brand should have marked
After two previous postponements, the timeline was set as follows:
- Large and medium-sized companies: obligations apply from 30 December 2026.
- Small companies and microenterprises: from 30 June 2027.
The European Commission has publicly stated that it will not reopen the text of the regulation, so these dates should be treated as final. However, given the regulation’s recent history – two consecutive delays since 2024 – it is worth keeping a close eye on any official updates.
The July 2026 expansion: more palm derivatives now under control
On 13 July 2026, the Commission adopted a delegated act adding a range of palm oleochemical derivatives to Annex I, including fatty acids, fatty alcohols, glycerine, amines and various forms of soap. As of now, the text remains under scrutiny by Parliament and the Council, with entry into force expected in mid-September 2026.
There is a nuance worth understanding here: products newly added to Annex I do not have to comply from December 2026, but from 30 December 2027 – one year after the general deadline. However, this should not be read as room to wait. Building a traceability system with parcel-level geolocation, by contrast, takes months of work with suppliers who have never had to provide that level of detail before.
What geolocated traceability actually requires
Unlike schemes such as the RSPO, which certify sustainable farming practices at plantation or cooperative level, the EUDR asks for something more specific: geolocation coordinates for each plot of origin, large enough to verify by satellite whether deforestation occurred after 31 December 2020. In addition, the due diligence statement must include a risk analysis of the country or region of production and the mitigation measures adopted.
For a cosmetic brand buying already-formulated glycerine or surfactants, this means asking its supplier for much more than an RSPO certificate. In practice, it requires tracing the chain back to the agricultural origin of the derivative – something many raw-material manufacturers have not yet resolved.
Which cosmetic ingredients fall under the radar
The list of derivatives included in the expanded Annex I directly affects ingredients commonly used in formulation:
- Stearic acid and palmitic acid, used as emollients and thickeners.
- Glycerine (glycerol), present in a huge share of cosmetic formulas.
- Fatty alcohols such as cetyl or stearyl alcohol, the basis of many emulsifiers.
- Palm-derived surfactants, including certain sodium and potassium soaps.
- Fatty amines, used in conditioners and hair-care products.
That said, one important clarification is needed: the obligation does not automatically fall on every finished cosmetic product, but on whoever places on the European market the derivative classified under an Annex I tariff code – typically the raw-material manufacturer or ingredient importer. Even so, as a brand, your exposure to risk depends directly on whether your suppliers can demonstrate that compliance, a raw-material traceability challenge similar to the one the sector is already facing with PFAS in cosmetic formulations.
Checklist: what to ask your raw-material suppliers
Before the end of 2026, it is worth reviewing your supply chain with specific questions:
- Is the derivative we purchase classified under any of the new Annex I codes?
- Can the supplier provide plot-level geolocation data for the origin of the palm oil used?
- Is there a due diligence statement (DDS) associated with the batch, including its reference number?
- Can the supplier confirm, with evidence, that there is no deforestation after 31 December 2020?
- Is an update to that documentation planned ahead of the December 2026 and December 2027 deadlines?
At Cosmeservice, we help cosmetic brands review this documentation and prioritise which references need immediate attention versus those that still have some leeway. If you would like an initial assessment of your EUDR exposure, you can write to us at info@cosmeservice.com.
FAQs
What is the EUDR and which cosmetic companies does it affect?
The EUDR (Regulation (EU) 2023/1115) is the European anti-deforestation regulation that requires companies to demonstrate, using plot-level geolocation, that certain raw materials and their derivatives do not come from land deforested after 2020. It affects any company placing a palm derivative classified under Annex I on the European market, including many cosmetic ingredient suppliers.
When does the EUDR come into effect for cosmetics?
Large and medium-sized companies must comply from 30 December 2026. Small companies and microenterprises have until 30 June 2027. Palm derivatives added in July 2026 have an additional deadline, until 30 December 2027.
Which palm-derived cosmetic ingredients are affected?
Among others, stearic acid, glycerine, fatty alcohols such as cetyl or stearyl alcohol, certain surfactants and soaps, and fatty amines used in hair-care products, provided they are classified under the tariff codes included in Annex I.
Is an RSPO certification enough to comply with the EUDR?
No. The RSPO certifies sustainable farming practices, but the EUDR also requires plot-level geolocation data and a specific due diligence statement, verifiable by European authorities.
Who is responsible for EUDR compliance, the brand or the raw-material supplier?
The legal obligation normally falls on whoever places the derivative on the European market, often the raw-material manufacturer or importer. Even so, the cosmetic brand depends on that documentation to protect its own supply chain.
Could the EUDR date be delayed again?
The European Commission has stated that it does not plan to reopen the text of the regulation, so the current dates should be considered final. That said, given that the regulation has already been delayed twice since 2024, it is worth following the Commission’s official communications.
References
- Regulation (EU) 2023/1115 of the European Parliament and of the Council of 31 May 2023 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation
- European Commission: “Commission updates product scope and tools to support EUDR” (13 July 2026)
