EUDR Scope Is Growing, Not Shrinking – What Palm Oil Soap and Instant Coffee Mean for Your Business

Stability, but not clarity

It’s positive news that no further changes are expected this round. The core EUDR text will not be reopened during the April 2026 review. The product scope is expanding via delegated act, with palm oil soap and instant coffee coming in. The direction is clear.

But stability in the legislative text is not the same as clarity in implementation. It’s the implementation that determines whether the EUDR becomes a functioning traceability system or a bureaucratic layer that primarily hits the companies already trying to do the right thing.

The most important open questions aren’t about what’s in scope. They’re about who carries responsibility, and how far the trail needs to go.

Traceability stops at importer + 1

The traceability requirement within the EU only extends to the importer’s first customer. Importer plus one. After that, the legally mandated traceability chain ends.

For the legislator, the logic is that the importer brings the product into the EU market and carries the primary responsibility. But for companies further down the chain, retailers, corporate groups, brands, this creates a gap.

Take a Danish retail group buying private-label products with palm oil derivatives from a European trader. In practice, they don’t automatically receive the due diligence documentation from the importer. They hold the product, but not the trail.

This is where digitalisation becomes decisive. When legislation only requires traceability one step, but the market demands it all the way, it’s the data infrastructure that determines who can deliver. And who can’t.

The SME gap: simplified DDS, but what about liability?

SME importers can carry out simplified due diligence. It’s a concession designed to protect smaller companies from disproportionate costs. The intention is understandable.

But it raises a critical question that remains unanswered: does responsibility shift forward in the chain until it hits the first non-SME operator? Or do goods passing through an SME importer effectively become “the wild west”, documented with simplified DDS but without full traceability?

For large operators and corporate groups, this isn’t a theoretical question. It’s a procurement question. If a corporate group buys goods imported via an SME with simplified DDS, and that group can still face fines for lack of traceability, the consequence is straightforward: the group will need to place demands on its suppliers that go beyond the legal minimum.

Legislation sets the floor. The market sets the standard.

Value chain complexity as risk parameter

The EUDR uses value chain complexity as a risk parameter. The more complex the chain, the greater the responsibility placed on large operators. It’s a principle most can get behind.

But the question is how large companies actually meet that responsibility if they don’t receive due diligence documentation with traceability from their suppliers. The legislation requires them to manage the risk. It doesn’t ensure they get the data necessary to do so.

This is where we see a shift. When legislation assigns responsibility but doesn’t secure the data flow, traceability becomes a market requirement, not just a legal one. Large companies will start demanding DDS with full traceability from their suppliers, further down the chain than the legislation prescribes. Not because they have to, but because they can’t fulfil their own obligations without it.

That’s a fundamental change. And it favours companies that have already invested in data infrastructure.

What companies should do now

The December 30, 2026 deadline for large and medium operators is fixed. For companies already in scope, the priority is clear: structure your supply chain data, map products to the correct HS codes and commodity groups, and establish supplier data collection workflows.

For companies entering scope due to the product list expansion, the window is narrower than it looks. A delegated act can take effect within months of proposal.

But more importantly: don’t plan only for the legal minimum. Plan for what your customers, and your customers’ customers, will demand from you. Traceability as a market requirement will arrive faster than traceability as a legal requirement. The company that can deliver DDS with full traceability on request has a competitive advantage that extends far beyond the EUDR.