EUDR and cosmetics: what changes for soap and raw materials

The European Union Deforestation Regulation, known as EUDR, also affects certain activities in the cosmetics industry. The recent Delegated Regulation (EU) 2026/2102 expands the list of relevant products and clarifies several exclusions. For companies, the first step is to identify which products and purchases are affected and their role in the supply chain.

Soap enters scope from 30 December 2027

The change concerns soap for toilet use in bars, cakes or moulded shapes under entry ex 3401 11 00, and soap in other forms under entry ex 3401 20, where it contains or has been made using oil palm. The application date is 30 December 2027, including for micro and small enterprises.

However, the word “soap” on a label is not enough. The assessment starts with customs classification and composition. Liquid or cream skin-cleansing preparations correctly classified under 3401 30 00 have not been added to the list. Likewise, shampoos and bath preparations classified under their respective Chapter 33 headings do not become subject to EUDR simply because they contain a palm-derived ingredient.

Solid surfactant-based cleansers require a specific assessment: the new EUDR description uses the term “soap” and does not automatically include every solid product under the same code. Interpretative clarification has also been requested on the meaning of “made using oil palm”. In the meantime, companies should trace the origin of their ingredients rather than relying solely on INCI names.

Not all raw materials can wait until 2027

Refined glycerine, certain fatty acids and industrial fatty alcohols derived from oil palm may already fall within EUDR scope. For these products, the general application date is 30 December 2026; the deferral to 30 June 2027 applies to micro and small operators meeting the specified conditions, with exceptions for products already covered by timber legislation.

Other derivatives are newly included and will become subject to the rules from 30 December 2027. These include crude glycerine, certain pure fatty alcohols and selected families of esters, amides and chemical preparations. Two ingredients with similar names may therefore have different deadlines. The oil palm concerned belongs to the genus Elaeis; babassu from the genus Attalea is excluded.

Who must submit a due diligence statement

A company directly importing an in-scope raw material or soap into the EU may be an operator. It must collect the required information, including the geographical origin of the source commodity, verify legality and the absence of deforestation, and submit a due diligence statement (DDS) in the EU system before the transaction, in accordance with the applicable rules.

A company manufacturing soap using relevant products that are all already covered by a DDS may instead be a downstream operator. The 2025 amendments removed the requirement for downstream operators and traders to submit a new routine DDS. However, traceability obligations, retention of information for at least five years and management of concerns remain. Non-SME entities must also register in the system. Being a distributor therefore does not mean being exempt from all obligations.

What about paperboard cartons

Packaging accompanying a cosmetic product and used exclusively to support, protect or carry it is excluded under the specified conditions. The same conclusion does not automatically apply to empty packaging imported or marketed separately. Display units, marketing materials and samples also require an assessment of their function and the specific exclusions.

Actions to start now

1. Map products and raw materials, including their customs codes and applicable deadlines.

2. Ask suppliers for the botanical origin of ingredients potentially derived from oil palm and clarify their EUDR role.

3. Distinguish importing, manufacturing and reselling activities to identify your company’s obligations.

4. Organise information, links to supplies and procedures before the respective application dates.

5. Update statements issued to customers: a blanket statement excluding the entire product range may no longer be correct.

The Cosmetic Solutions team helps companies assess their EUDR scope, liaise with suppliers and update documentation, taking account of the activities they actually perform. For information: info@consulting-in-cosmetics.com.